ABOUT THIS POLICY
Palace Auctions Group Limited and its subsidiary companies are all committed to conducting their businesses in a socially responsible way. Palace Auctions businesses seek to carry out their operations in accordance with appropriate ethical standards and be honest and fair in their relationships with customers and suppliers. As part of this, Palace Auctions is dedicated to ensuring that effective systems and controls are in place to safeguard against modern slavery and human trafficking occurring within our businesses or any of our supply chain.
Palace Auctions GROUP SLAVERY AND HUMAN TRAFFICKING STATEMENT
In accordance with the Modern Slavery Act 2015 (“Act”), Palace Auctions has published this statement on behalf of its relevant subsidiary companies (“Palace Auctions”). This statement sets the steps that members of the Palace Auctions Group has taken to prevent modern slavery and human trafficking from occurring within its business and supply chains.
Palace Auctions Group Businesses
Palace Auctions through its subsidiaries is a leading provider of property services to its key customer groups:
Palace Auctions’s financial reporting includes six divisions:
As at 1st December 2022, Palace Auctions Group through its subsidiaries employed circa 20 people across the UK, where its business operations are entirely based.
Palace Auctions Group Supply Chains
Members of Palace Auctions Group have established direct relationships with a number of primarily UK-based suppliers who deliver a variety of services including: professional services, utilities and telecoms, and facilities management. As part of its service delivery, members of Palace Auctions Group procure services not just for themselves, but also for the benefit of some of the customers of other group companies (for instance, engaging contractors to provide maintenance services to properties managed by the Group).
The vast majority of services are procured via specialist individuals employed or engaged by members of the Palace Auctions Group (senior team managers and heads of service).
Palace Auctions Group Policies and Contractual Provisions
The approach of members of Palace Auctions Group to the promotion of human rights and ethical issues is contained within Palace Auctions HR Policies which include but not limited to:
The Palace Auctions HR policies apply to all individuals employed or engaged by Palace Auctions and our subsidiaries. Employees can use the whistleblowing policy to report suspected concerns within the Palace Auctions businesses and supply chains.
Since the enactment of the Act members of the Palace Auctions Group have taken steps to seek to ensure that any new agreements with suppliers include an express obligation for suppliers to comply with the Act, to implement due diligence procedures within its own supply chains and notify Palace Auctions in the event of any actual or potential incidence of modern slavery (for instance, when contractors sign up on Palace Auctions Property Management’s portal they agree to terms which require them to comply with the Act). In the event of a breach of these provisions, members of Palace Auctions Group will seek to resolve any issues with its suppliers and it may also seek to terminate the relationship with the supplier where a resolution is not achieved. This provision is regularly reviewed, and relevant amendments made.
Palace Auctions Group Due Diligence
Members of the Palace Auctions Group have identified our supply chains as the main area of risk and exposure to modern slavery.
The suppliers used by Palace Auctions Group have been identified as low risk. The suppliers which provide manufactured goods to Palace Auctions Group are very few, limited to marketing and advertising providers (providing banners, posters etc), and facilities providers (providing toiletries, vending machine and drink machine products etc.) Other suppliers to Palace Auctions Group mainly provide in-person services, such as maintenance services and recruitment services. Contractors used by Palace Auctions pass through an on-boarding process, which includes terms requiring them to comply with the Act and provide a copy of their modern slavery statement where requested.
Palace Auctions Group Areas of Risk
Overall exposure to modern slavery for members of the Palace Auctions Group is lower than other sectors given the nature of the property services sector in which our businesses operate, the types of services we procure and the fact that our business operations and those of the majority of our suppliers are primarily based in the UK.
Notwithstanding the above, Palace Auctions Group is not complacent and understands that the procurement of recruitment and facilities services and the use of subcontractors are practices which may bring about increased risks of modern slavery within supply chains.
Accordingly, Palace Auctions is taking steps to mitigate such risks, including:
As part of this, Palace Auctions Group complies with all relevant legislation including the Immigration, Asylum and Nationality Act 2006 and ensures that all appropriate checks are carried out to maintain compliance. If further risks are identified, Palace Auctions Group will consider such risks and take appropriate steps to address any emerging risks.
Palace Auctions Group Training
Palace Auctions Group understand the importance of training employees to enable them to be able to identify risks of modern slavery. Palace Auctions Group employees receive information that allows them to understand the requirements under the Act in the form of this policy. They also receive our whistleblowing policy, which would allow them to raise concerns anonymously.
KPI Monitoring
The Palace Auctions Board appreciates that the approach to combatting modern slavery will have to adapt over time in response to findings following the completion of various risk assessments.