Slavery and Human Trafficking Statement

1. Introduction from the Chairman

2. Organisation structure

3. Our supply chains

4. Our policies on slavery and human trafficking

5. Due diligence processes for slavery and human trafficking

6. Our risks and how we manage this

7. Supplier adherence to our values

8. Our effectiveness in combatting slavery and human trafficking

9. Training

1. Introduction from the Chairman

Modern slavery is a global and growing issue. No sector or industry can be considered immune or untainted. We have a zero tolerance to modern slavery and we are committed to improving our practices to combat slavery and human trafficking both in our organisation and supply chain.

We all have a responsibility to be alert to the risks, however small, in our organisation and the wider supply chain. Employees are expected to report concerns using the appropriate reporting channels and management are expected to deal with them.

2. Organisation structure

We are an investor and provider of development, management and construction services in the property sector.

We are the parent company of the Seven Capital Group (the Group). The Group consists of SevenCapital; SevenHomes; SevenLiving; Colmore Tang Construction and then we set up a SPV for each construction project we undertake.

The Group operates throughout the UK and has a global annual turnover of over £87 million.

3. Our supply chains

Our supply chains include suppliers of building and construction materials, those who work in the building and construction sector, as well as professional advisers.

4. Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our organisation.  Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Our Anti-slavery Policy is available to all our staff and we inform our suppliers of our commitment to preventing modern slavery.

5. Due diligence processes for slavery and human trafficking

As part of our initiative to identify and mitigate risk we have in place systems to:

• Identify and assess potential risk areas in our supply chains;
• Mitigate the risk of slavery and human trafficking occurring in our supply chains; and
• Monitor potential risk areas in our supply chains.

6. Our risks and how we manage this

We have identified our building and construction arm as an area of risk.  We ensure, as far as we can, that we appoint reputable suppliers, who are appointed following a rigorous appointment process.

7. Supplier adherence to our values

We have zero tolerance to slavery and human trafficking.  To ensure all those in our supply chain and contractors comply with our values, we have in place a supply chain compliance programme.  This consists of a rigorous appointment programme which includes supplier self-certification of compliance, together with standard clauses in contracts.

We are committed as an organisation to tackling modern slavery and human trafficking and want to work with suppliers who share our values.

We also have a dedicated compliance team which consists of involvement from the legal, department.

8. Our effectiveness in combating slavery and human trafficking

In order to assess the effectiveness of the measures taken by us we will be reviewing the following key performance indicators:

• Staff training levels;
• Actions taken to strengthen supply chain auditing and verification;
• Steps taken to upskill our high risk suppliers; and
• Investigations undertaken into reports of modern slavery and remedial actions taken in response.

9. Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, we intend to roll out training to our staff on this. All staff will be encouraged to attend training in this area to better understand the risks and how we as an organisation are working to manage this.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2021.

Seven Capital PLC

22nd March 2022