Modern Slavery & Human Rights

This statement is made pursuant to Part 6 of the 2015 Modern Slavery Act (the ‘Act’) and sets out the steps Annington Limited (the ‘Company’) and its subsidiaries have taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of the business.

Annington’s Operations

Annington is one of the largest private real estate owners in the UK. Our aim is simple: to accelerate the refurbishment, re-development, rental or sale of affordable ex-MOD homes to families who need them. We have a portfolio of over 38,000 properties worth c.£7.4bn, most of them rented by the MoD to provide quality, reasonably priced housing to Service Families. It makes us strong and stable and gives us a real sense of social purpose. Our operations are entirely UK based and we want to work with vendors who will partner with us, share our ethics and values.

What is Modern Slavery

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Victims are coerced, deceived and forced against their free will into providing work or services. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Due diligence processes

Annington conducts an annual review of its business and operations including risks associated with modern slavery. This work identified that Annington remains a low-risk business but that the areas of highest risk exists around our contracting activities and the possible use of slave / trafficked labour on site or within the Company’s supply chain. When considering the risks associated with the various areas of the business, the Company’s established policies covering Anti-Slavery and Human Trafficking, Whistleblowing, Supplier Code of Conduct and Sustainable Procurement form the backbone of the review.

Within Annington’s core refurbishment and new build operations, the scale of work carried out each year varies considerably due to two factors. Firstly, the numbers of sites and homes returned to Annington by the MoD and secondly, the condition in which they are handed back. In order to manage this and the fact that the release of properties to Annington is entirely at the discretion of the MoD, Annington has determined that the most effective and efficient method of procuring the refurbishment work is to outsource it to pre-selected contractors and suppliers. The year April 2023 to March 2024 saw the MoD hand a number of properties back to Annington.

During the year Annington ensured that it remained compliant with the legislation by ensuring all new building contractors completed the pre-qualification questionnaire which covers modern slavery legislation and that all engaged building contractors certify that they have the relevant policies and procedures in place and that they will abide by the Annington Supplier Code of Conduct. Other building contractors taken on via managing or property agents are vetted on Annington’s behalf and asked to confirm they have appropriate policies and procedures in place.

Recruitment & Training

Annington’s operations are rated low risk however, we manage the risk of modern slavery by ensuring the people we employ have the right to work and that their basic rights as workers are protected. Annington continues to raise awareness of slavery and trafficking issues amongst its staff and contractors through training. Training on slavery and human trafficking for all staff is delivered as part of the Company’s annual training programme, so that they can understand the risks involved and know how to make the organisation aware of issues so they can be addressed.

Annington Supply Chains

Annington will continue to monitor and assess its performance in this area through the following measures:-

• Engagement with building contractors to raise awareness of the Modern Slavery Act and our Supplier Code of Conduct. This is done through an agreement to our Schedule of Rates contract and pre-commencement meetings with building contractors to ensure they are aware of Annington’s policies and are abiding by their own policies
• Continuing to focus on our supplier due diligence process to ensure that we engage appropriately with any new suppliers and contractors.
• We are able to suggest suitable Anti-Modern Slavery Training to any of our key building contractors to raise awareness around modern slavery and human trafficking.

Annington strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain and is committed to implementing systems and controls and delivering training aimed at ensuring that modern slavery is not taking place anywhere within its organisation or in any of its supply chains. The Director of Projects and Sales has responsibility for ensuring that the contractors and suppliers used in the refurbishment of properties comply with Annington’s policies, including our Slavery and Human Trafficking policy. The Chief Operating Officer has responsibility to the Annington board for oversight of the Act across the Group.

Our future plans

Annington will continue to develop our approach to preventing modern slavery by continuing to enhance external due diligence of our supply chain.

This statement represents Annington’s statement in accordance with Section 54 of the Modern Slavery Act 2015 for the financial year 1 April 2024 to 31 March 2025 and has been approved by the Board of Directors.

 Ian Rylatt

CEO

On behalf of the Board of Annington Limited

30 April 2024