Modern Slavery Act
CLV UK Holdings Limited – Modern Slavery Statement
Who are we:
Campus Living Villages (CLV) is an owner, developer and operator of student accommodation currently managing over 10,496 beds in the United Kingdom. CLV is committed to improving its practices to combat slavery and human trafficking.
The CLV group extends globally, with offices and beds in Australia, New Zealand, and the United States. The group employs over 978, with 276 of those being in the UK business.
CLV UK has an annual turnover of £37.9 million.
Our business:
As a specialist in student accommodation, CLV has established itself as a leading provider of quality facilities and exciting student communities. CLV launched in the UK in 2008 and has student villages in 9 locations, comprised of 50 buildings including Bournemouth, Leeds, Newport, Manchester, Liverpool, and multiple London sites.
Our supply chains:
CLV UK’s supply chains include construction contractors, facilities management services to maintain sites, cleaning, and linen services, as well as goods such as furniture and whitegoods. The majority of CLV’s supply chain are UK based.
Our policies on slavery and human trafficking:
CLV UK has committed to business practices to protect workers and has taken steps to ensure that there is no modern slavery or human trafficking in our supply chains or in any part of our business. 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.
Due diligence processes for slavery and human trafficking:
Within CLV UK’s business there are processes in place to ensure that workers are not exploited and are protected from poor labour practices.
As part of our initiative to identify and mitigate risk we have taken steps to eradicate any slavery or human trafficking from our supply chain, with most of CLV UK’s procurement being performed centrally by a procurement team.
The CLV UK Procurement Team has been assessing modern slavery risks by means of due diligence mandatory questions undertaken for every supplier onboarded and used across the UK Region for a number of years.
Through the combined efforts of the CLV UK Procurement Team, the UK Legal Team, and the group wide ESG governance initiative, this has been further extended to include a risk analysis of CLV UK’s current suppliers and new suppliers. This covers numerous risk indicators including checking the nature of services / products; source of services / products originating from a ‘high-risk country’, and whether the supplier operates under a ‘high-risk’ business model.
This risk analysis is used to indicate any high-risk suppliers currently within CLV UK’s supply chain, as well as any potential suppliers going forward. It is followed up with a two-stage Modern Slavery Questionnaire process, an approach which further scrutinises a supplier’s compliance with Modern Slavery best practices. The Phase 1 Questionnaire is a requirement for all suppliers, should these initial responses highlight potential concerns, the Phase 2 Questionnaire will be used – which includes a more specific series of questions, focusing on the intricacies of the supplier’s practices relating to Modern Slavery compliance.
Amongst other items, the questionnaire includes requests for additional information, specifically surrounding the supplier’s own modern slavery policy, modern slavery statement (if applicable) and further details that may be relevant to the supplier in question.
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.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
Supplier adherence to our values and ethics:
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. As part of the procurement process, all bidders are required to complete at least the Phase 1 Questionnaire as set out above, answering questions that are targeted towards checking and encouraging a supplier’s compliance with the Modern Slavery Act 2015 (“Act”).
CLV UK does not engage suppliers who do not comply with the Act.
We also include, where possible, contractual terms in our agreements with suppliers imposing ongoing obligations on the supplier to comply with the Act and to notify CLV UK if the supplier becomes aware of any circumstances within its own supply chain that could constitute an offence under the Act.
Training:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we are committed to ongoing staff training and implemented a training program which commenced in the 2020/2021 financial year. Currently 95% of UK staff members have now completed this training so far.
A unified approach:
CLV UK operates in conjunction with CLV Australia, CLV NZ, and CLV US, providing quality accommodation to the global student population. While only the UK and Australia have active Modern Slavery legislation, we are committing to identifying, actioning, and monitoring risks across all regions and supply chains.
To do this we established a dedicated Governance project working group as part of our broader ESG strategy. This group is responsible for coordinating and refining our Modern Slavery reporting process so as to ensure the processes outlined above can be extended across the Group; and so the Group can confidently and consistently address Modern Slavery risks.
Further steps:
A key goal for CLV for 2020/2021 was to roll out Modern Slavery training. This has been successfully rolled out with 95% of UK staff having completed this training so far; it is also a mandatory requirement for any new staff member. This approach helps to provide an understanding of this important issue, as well as to work with the wider CLV group to combat slavery and human trafficking.
Actions going forward for 2021/2022 will include a full sweep of every CLV UK supplier, including a strategic annual review of any ‘higher risk’ suppliers for Modern Slavery compliance.
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 30th June 2020. It was approved by the board on 11th October 2021.
Lee McLean (Director)
CLV UK Holdings Limited
Signed:
Date: 11th October 2021