Wain Group Limited is the parent company of Wain Homes Limited (“Wain Homes”) and Wain Estates Limited (“Wain Estates”).
Pursuant to section 54 of the Modern Slavery Act 2015, this statement constitutes the Modern Slavery Statement of Wain Group Limited and its subsidiary Wain companies (together referred to as Wain Group) as specified below for the financial year ending 30 September 2023.
The Modern Slavery Act 2015 creates offences in respect of slavery, servitude, forced or compulsory labour and human trafficking ("Modern Slavery"). Wain Group is committed to combatting all such forms of Modern Slavery.
ABOUT WAIN HOMES
Wain Homes is a housebuilding and land and property business focusing on regeneration, commercial development and the promotion of mixed-use schemes.
The housebuilding aspect of Wain Homes operates in four regions in the North West, Severn Valley, South West of England and West Midlands and is focused on delivering quality homes for customers.
WAIN HOMES SUPPLY CHAINS
Wain Homes’ construction projects are developed through a combination of directly sourced materials and directly employed construction personnel and also through Wain Homes' relationships with contractors who provide supplies and services (including labour).
Significant supplies include, for example groundworks, bricks, fencing, roof trusses, tiles and other building supplies. At times those supplies and services are subcontracted however, as set out below, Wain Homes' permission is required for any such subcontracting. Wain Homes uses a restricted number of labour providers to support the developments of its development sites. In addition to the supplies and services procured in relation to the development of sites, Wain Homes relies on office supplies and facilities supplies to its premises in Warrington, Bristol and Exeter.
Whilst the Wain Homes projects are UK based and the number of suppliers used are limited, Wain Homes recognises that Modern Slavery is not a risk that is restricted to construction projects overseas and that supply chains extend globally.
ABOUT WAIN ESTATES
Wain Estates is a property development, regeneration and strategic land company.
WAIN ESTATES SUPPLY CHAINS
Wain Estates is developing a Supplier Code of Conduct which sets out the minimum standards suppliers need to achieve with respect to areas such as labour and employment rights, health & Safety, ethics, social responsibility and the environment.
The ability of organisations to comply with the Supplier Code of Conduct is a prerequisite to appointment for any Works or supply of materials. Wain Estates usually employ a main contractor who would organise significant supplies including groundworks, steel, cladding and other building supplies. They would do so in accordance with the Wain Estates Supplier Code of Conduct.
In addition to the supplies and services procured in relation to the development of sites, Wain Estates relies on office supplies and facilities supplies to its premises in Warrington. Whilst the Wain Estates’ projects are UK based and the number of suppliers used by the group is limited, Wain Estates recognises that Modern Slavery is not a risk that is restricted to construction projects overseas and that supply chains extend globally.
POLICIES AND PROCEDURES
The policies and procedures that Wain Group has to combat Modern Slavery in its business are set out below.
Anti-Slavery and Human Trafficking Policy
Wain Group is in the process of updating its suite of compliance policies and procedures and a part of that process will involve the introduction of an Anti-Slavery and Human Trafficking Policy. The policy will confirm Wain Groups' commitment to combatting all forms of Modern Slavery, require adherence by employees and suppliers and refer to the consequences of a breach.
Contractual controls
Wain Groups' contractual terms contain a number of requirements which are relevant to reducing Modern Slavery risk. These include the requirement on contractors to obtain Wain Groups' consent prior to subcontracting, which allows due diligence to be carried out, and also the reservation of audit rights in respect of employment records of contractors. Wain Group is in the process of reviewing those contractual provisions to increase protections in respect of Modern Slavery and expects to introduce revised standard terms shortly.
Due diligence of sub-contractors
Wain Group conducts due diligence in respect of sub-contractors including checks of corporate and tax records and also to confirm that the sub-contractor maintains adequate policies and procedures in respect of health and safety. These compliance checks give Wain Group a level of comfort in respect of the standing of the suppliers it works with. Wain Group is currently considering introducing further checks and diligence in respect of its supplier base relevant to Modern Slavery risk.
APPROVAL
This statement is made pursuant to section 54 of the Modern Slavery Act 2015 for the financial year ending 30 September 2023 and has been approved by the board of Directors of the following Wain Group companies.
Wain Homes (North West) Limited
Wain Homes (South West) Limited
Wain Homes (Severn Valley) Limited
Wain Estates Limited
Wain Estates (Property) Limited
Wain Estates (Carrington) Limited
Wain Estates (Land) Limited
Carrington Business Park Limited
Swinton Park Golf & Country Club 2017 Limited
Date: 1st October 2022