Modern Slavery Statment
Slavery and Human Trafficking Statement
The Modern Slavery Act 2015 (the “Act”) defined modern slavery as offences of “slavery, servitude and forced or compulsory labour”, which have no place in a modern society. The Act sets out to improve transparency by requiring reporting of the steps public and private companies that carry on a business (in whole or part) in the UK and with an annual turnover of over £36 million have taken to prevent modern slavery from occurring in their supply chains. This statement is therefore made in respect of CLS Holdings plc (the “Company” or “CLS”). CLS has a zero tolerance towards modern slavery, and expects our employees, and those we deal with to uphold our high values. We are fully committed to ensuring that there is no modern slavery or human trafficking in our supply chains, and that everyone’s fundamental rights are respected.
Our Business
CLS is a property investment company that has been listed on the London Stock Exchange since 1994. From our head office in London, we invest mainly in commercial buildings in the UK (predominately in London), Germany and France. We specialise in owning and managing office buildings, with a range of lease lengths, in order to achieve stable cash flows. Our established local management teams operate from offices in London, Paris, Lyon, Hamburg, Dusseldorf and Luxembourg. Their priority is to meet the requirements of our tenants by providing high quality, cost-effective premises, with efficient and proactive management services. We aim to hold, develop and refurbish our property investments to obtain long-term asset growth.
In the UK, as an accredited Living Wage Employer, certified by the Living Wage Foundation, we ensure that all of our employees and anyone who works in a third-party contractor role primarily located at one of our managed assets will be paid the Living Wage (as determined by the Living Wage Foundation) or the London Living Wage, as applicable. This applies to both our employees and contractors as well as anyone who works for a third party delivering regular site services. This commitment to the Living Wage represents another key control in ensuring slavery does not take place within our business or supply chain. There is no similar scheme in our other jurisdictions where we operate.
Further details can be found on our website www.clsholdings.com.
Modern Slavery Policy
We have implemented a Modern Slavery Policy (the “Policy”) which we expect all CLS employees to abide by. We believe in an open culture where all our employees are encouraged to come forward if they discover any malpractices in our business. The Policy is made available to all employees on the staff intranet.
In identifying modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations, the Policy, as noted above, is supported by the Whistleblowing Policy, whereby any employee who believes that they know of any modern slavery incident, potential or actual, can report it in a confidential (or anonymous) manner, supported by an independent hotline that is also available on-line. All reports will be investigated fully and appropriately in accordance with the Whistleblowing Policy and, if made in good faith, will not have any adverse effects on that employee. If an employee feels uncomfortable reporting a matter to their Line Manager, the Chief Executive Officer or the Company Secretary, they can contact the Senior Independent Director.
Our Supply Chain and Supplier Due Diligence
General approach
CLS aims to take a risk-based approach to the actions it takes to prevent, mitigate and manage the risk of modern slavery in its supply chain, focusing on those elements of its supply chain that are considered to pose a potentially higher risk from a modern slavery risk perspective.
As an overarching aim, we seek to source goods and services efficiently and fairly, in accordance with our Procurement Policy. When a contract is entered into between a new supplier and CLS, we undertake a due diligence process with the supplier to determine whether they operate good business practices. In the UK, this includes requiring that the supplier provides us with evidence of their own modern slavery policy. Where they do not have one, the supplier will be informed of the standards set out within CLS’s Policy and of the expectation that they act in accordance with them.
As a group operating across jurisdictions, CLS has subsidiaries which are located and operate in Germany, France and Luxembourg and which do not carry on a business in the UK and therefore do not fall within the scope of the Act). Nevertheless, our subsidiaries are expected to implement suitable and sufficient processes to adhere to applicable local laws and requirements (including in respect to modern slavery) and to promote CLS’s zero tolerance approach to modern slavery.
UK third party contracted staff
As an accredited Living Wage Employer, CLS has recognised the potential presence of low wage contracted staff. As such, for contracts entered into by CLS with third party suppliers that have contract staff that work regularly for CLS in the UK (e.g. for contracted cleaning or catering services)., CLS requires (as a condition of entering into an agreement with them), that the supplier commit to paying their employees the Living Wage.
Developments and refurbishments
When we undertake the redevelopment or refurbishment of our buildings, we enter into a construction contract with the contractor (usually based on one of the JCT standard forms of contract).
We require that these contracts contain clear terms setting out our requirements in relation to modern slavery.
Spring Mews Hotel and Student Accommodation
Our Spring Mews development consists of student accommodation and a 93 bed hotel. For the continued operation of these two businesses we have separate management partners. We have received confirmation from our management partners that they have their own modern slavery policy that they follow, and that there have been no contraventions during the year. It is our process to seek such assurances on an annual basis.
Next steps in 2024
Whilst there have been no instances of modern slavery reported to the Company during 2023, we seek to continually improve and develop our processes. We will undertake a review of how we can improve the effectiveness of our internal processes relating to Modern Slavery with the aim of simplifying the collation of documentation provided by suppliers as part of CLS’s due diligence and onboarding processes, and the subsequent oversight and monitoring of them.
We will continue have regular contact with our suppliers to reinforce the importance we place on combating modern slavery, and to ensure that they are compliant with their own policy, or our own.
We also plan to offer training to key staff involved with our supply chains and contractors so that there is a clear message on our zero tolerance to modern slavery.
This statement is made in accordance with section 54 of the Act and relates to the Company. It is made in respect of its financial year ended 31 December 2023 and will be reviewed and updated in 12 months.
Approved by the Board on 14 May 2024.
Fredrik Widlund
Chief Executive Officer
