Modern Slavery Statement
This statement is made on behalf of Swift Haven (“Swift Haven”) and sets out the steps Swift Haven has to assess and address the risks of modern slavery in our operations and supply chains.
Our Commitment
Swift Haven is fundamentally committed to ensuring that there is no slavery or human trafficking in our supply chains or in any part of our business. As a professional services supplier we work to provide our clients with the highest levels of service attainable. We hold ourselves to the utmost standards of professional conduct and accept nothing less from our suppliers.
Our Organisation Structure and Supply Chains
Swift Haven is a Limited company registered in England
Swift Haven provides real estate services in the UK. Internationally, real estate services are provided by a network of separate and independent entities or practices, offering commercial and residential property services.
Swift Haven considers a supplier to be any contractor, consultant, supplier or other entity or individuals providing goods and/or services to Swift Haven, directly or indirectly.
Swift Haven operates a risk-based approach in relation to our supply chains. Our property and facilities management divisions are most likely to present a risk in relation to modern slavery, as Swift Haven procures services on behalf of clients, such as maintenance, security, concierge and utilities. Swift Haven also engages with suppliers to directly procure, for example, technology, marketing, HR and professional services and proactively works with these suppliers in order to ensure that persons working within these organisations are protected from modern slavery practices.
Our approach to combating slavery and human trafficking
As a property services firm, we recognise that there is a risk (albeit very small) of slavery or human trafficking occurring in our supply chain. Swift Haven will only work with suppliers who share our commitments. Regardless of the potential risk, Swift Haven takes the matter of modern slavery very seriously and has implemented a number of policies which are designed to ensure the firm’s compliance with its modern slavery obligations.
Our Purpose
Property is a part of everyday life and so much of what Swift Haven does with its clients directly impacts the surroundings in which we live and work. Swift Haven’s Purpose guides the way in which we work together, at our best – as individuals and as a business. Our Purpose is:
‘To work responsibly, in partnership, to enhance people’s lives and environment.’
We understand that we have a duty to make responsible and sustainable decisions, to collaborate effectively, to have a positive and meaningful impact on people’s lives and on the environment in which we live.
Our Policies
Swift Haven understands the importance of robust policies, not just for meeting our legal obligations, but also in maintaining the reputation. These policies are regularly reviewed and are approved by the Swift Haven Insurance and Risk Committee.
The relevant Swift Haven policies are as follows:
- Tendering and Responsible Procurement Policy – this includes our policy against modern slavery in the workplace and our supply chain;
- Social Ethical and Environmental Procurement Guidelines;
- Freedom of Association and Collective Bargaining Statement;
- Swift Haven Global Whistleblowing Policy; and
- Swift Haven Global Anti-Bribery and Corruption Policy
In addition, we require all of our employees to complete compliance and risk training annually, which includes sections on modern slavery.
Our Due Diligence Processes
To ensure all those in our supply chain comply with our policies, we carry out a clear onboarding process to ensure our suppliers match the standards we expect of them. During our tendering process, we expect suppliers to demonstrate their commitment to the prevention of modern slavery. Modern slavery is an agenda point in any meeting between Swift Haven’s procurement team and any of its suppliers.
When entering into new supplier contracts, we encourage all parties to contract on Swift Haven standard terms, which include obligations to comply with the Act and to comply with our policies in relation to the prevention of modern slavery. Where contracting on our supplier’s terms of business, Swift Haven ensures that similar obligations are included, requiring compliance with the Act.
In order to ensure that our supply chain remains free of modern slavery or human trafficking, Swift Haven regularly updates the procedures and policies of our procurement team to ensure we are meeting all the requirements under the Act. These requirements are built into every part of our supply chains, from supplier on-boarding, including all tendering processes, through to final appointment.
Our Risk Assessment and Management
Swift Haven’s property and asset management teams are at the greatest risk of exposure to modern slavery, given that they are the section of the Swift Haven business with the most extensive supply chains.
These teams (who provide both property and facilities management) engage with a number of suppliers for the provision of services such as security, cleaning, maintenance or concierge. This includes suppliers engaged through our subsidiaries. These services often utilise low-paid labourers and are at the greatest risk of exploitative labour practices. These teams look to minimise the risk of modern slavery in their supply chains by only working with companies on a Preferred Suppliers list. Among other requirements, companies are only included on this list where Swift Haven is confident they are equally committed to the prevention of modern slavery as Swift Haven is.
Other sections of the Swift Haven business do not work as regularly with suppliers and, more often than not, are working with suppliers of technology or cloud-based services, which are at lower risk of exposure to modern slavery. Nevertheless, the business divisions undertake the risk assessment and management steps outlined elsewhere in this statement. As an example, our HR team has recruitment guides to cover areas such as fair pay, equality and inclusivity, and the right to work when going through the recruitment process.
Swift Haven remains committed to conducting its business with integrity, and it looks forward to all further developments in this area.
This statement is made in relation to section 54(1) of the Modern Slavery Act 2015 for the financial year 1 April 2022 to 31 March 2023.