Slavery and Human Trafficking Statement 2020/2021
This statement is made by Shelbourne Estates Group on its own behalf and on behalf of the subsidiary companies (as listed on the final page). The Board of each of the companies listed have approved this statement which is made in accordance with section 54 of the Modern Slavery Act 2015 (the MSA) and covers the financial year 1st May 2020 to April 2021.
Shelbourne Estates does not allow the use of modern slavery and human trafficking in our operations and supply chain. We will continue to review and update annually this statement in accordance with the MSA.
Shelbourne Estates Group and its subsidiary companies develop homes and neighbourhoods in the UK. Shelbourne Estates’s business model recognises that it operates in a cyclical property market where developments can take a number of years to progress from inception, through planning and construction, to completion.
Shelbourne Estates regional development companies in Wilmslow, Rugby and Bedford administer a database of approved construction sub-contractors on behalf of the Group. Initial vetting of contractors before their use on developments is a key function performed by Commercial Directors within each operating division. Sometimes main contractors are used by the divisions where construction requires a single point of contact with design responsibility or there is a single end-user. While there are some limited aspects of the supply chain that are unique to the individual operating companies (for example requirements to use local labour under planning agreements), most of Shelbourne Estates companies’ supply chains are appointed through regional call-off agreements.
A limited quantity of material is sourced directly from suppliers, with the majority of the materials being procured by the contractors engaged to carry out works. Therefore Shelbourne Estates can be several steps removed from the procurement of labour and materials. Nonetheless Shelbourne Estates exercises some degree of control over the sourcing of supplies used on developments and has a long history of sourcing sustainable materials for use on its developments.
One of Shelbourne Group’s key objectives is to make a significant, long-term contribution to the environment and the social and economic fabric of communities in which it works and its goals is to work with its supply chain to achieve this.
During the year we reviewed our Anti-Slavery, Human Trafficking and Human Rights Policy, Whistleblowing and Disclosure and Bullying and Harassment policies. Ongoing work will continue on this to ensure they are embedded into the workplace. Work is currently being undertaken on a new Company Intranet site which will then ensure availability to all out employees. We expect everyone work with us or on behalf of us to support and uphold our policies in relation to modern slavery.
Risk Assessment & Due Diligence
During 2019, we reviewed our processes and systems. In terms of our supply chain and structure there is currently a low overall risk of modern slavery and human right abuses occurring in our own operations. In addition we do not deem our national suppliers to be high risk, given the amount of business we do with them. Many of these national suppliers will have produced their own Modern Slavery Statements.
As part of our initiative to identify and mitigate risk we have in place the systems to;
- Identify and assess potential risks areas in our supply chain
- Mitigate the risk of slavery and human trafficking occurring in our supply chains
- Monitor potential risk areas in our supply chains
- Protect Whistle blowing
We have zero tolerance to slavery and human trafficking.
During 2020 we will risk assess new suppliers and request information from existing suppliers on a regular basis.
Acts to address risks
We are taking all reasonable levels of assurance and are undertaking the following activities on an ongoing basis to assess and address these risks;
- Conducting an internal risk assessment to identify the Group’s suppliers.
- Consulting with any Suppliers whom we identified as a risk
- Reviewing the Groups existing contractual arrangements
- Reviewing anti-slavery training
During 2019 we have evaluated the training needs of the Company employees and training provided to employees to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business.
During 2020 we will be embedding this with a review of e-learning facilitation.
In order to monitor the effectiveness of our approach to modern slavery we propose the following steps for 2020:
- We will look to engage more with our suppliers and contractors to seek further assurances
- We will further embed employee understanding by training
- We will continue to monitor changes within its supply chain and update its approach accordingly
This statement has been approved by the Board of Shelbourne Estates Limited and the subsidiary companies listed below and will be reviewed and updated annually.
Group Finance Director
Companies on behalf of which this is made:
Shelbourne Group Ltd
Shelbourne North Ltd
Shelbourne Eastern Ltd
Shelbourne Midlands Ltd
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If any provision of these Site Terms is deemed unlawful, void or for any other reason unenforceable then that provision shall be deemed severable from these Site Terms and shall not affect the validity and enforceability of any remaining provisions.
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Shelbourne Ltd, Morland House, Altrincham Road, Wilmslow, SK9 5NW. Registered in England, No. 05026617
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Shelbourne Group Tax Strategy
This strategy applies to Shelbourne Group Ltd and to the group of companies headed by Shelbourne Group Ltd (“the Group”) in accordance with paragraph 16 of Schedule 19 to the Finance Act 2016. A list of the entities to which it applies is set out below. The strategy has been published in accordance with paragraph 16 of the Schedule.
This strategy applies from the date of publication until it is superseded. References to ‘UK Taxation’ are to the taxes and duties set out in paragraph 15(1) of the Schedule which include Income Tax, Corporation Tax, PAYE, NIC, VAT, Insurance Premium Tax and Stamp Duty Land Tax. All references relate to UK taxation as the Group has no subsidiaries incorporated or operating outside of the UK.
The Group is committed to full compliance with all statutory obligations and full disclosure to tax authorities.
Governance & Risk Management in relation to UK Taxation
- Ultimate responsibility for the Group’s tax strategy and compliance rests with the Group Board;
- Executive responsibility and day to day management of the Group’s tax is delegated by the Board to the Group Finance Director, who is also the Group’s Senior Accounting Officer;
- The Group operates a system of tax risk assessment and controls as a component of the overall internal control framework applicable to the Group’s financial reporting processes;
- The Group seeks to reduce the level of tax risk arising from its operations as far as is reasonably practicable by ensuring that reasonable care is applied in relation to all processes which could materially affect its compliance with its tax obligations;
- Processes relating to different taxes are allocated to appropriate process owners, who carry out a review of activities and processes to identify key risks and mitigating controls in place. These key risks are monitored for business and legislative changes which may impact them and changes to processes or controls are made when required;
- Advice is sought from external professional advisors where appropriate.
- We obtain advice from appropriately qualified external advisors on specialist tax matters which forms part of our tax return process and we see the input of external advisors as a key source of specific tax expertise to supplement the skills of our own finance team in appropriate cases.
Tax Planning and level of risk
The Group manages risks to ensure compliance with legal requirements in a manner which ensures payment of the right amount of tax.
We seek to minimise the risk of a dispute with HMRC by being open and transparent about our tax affairs. At all times we seek to fully comply with our regulatory and other obligations and to act as a responsible corporate citizen.
Relationship with HMRC
The Group strives to have a transparent and constructive working relationship with HMRC, built on integrity and consistency of approach.
When submitting tax computations and returns to HMRC, all relevant facts are disclosed and transactions or issues where it is considered that there is potential for the tax treatment to be uncertain, are identified.
Any inadvertent errors in submissions made to HMRC are fully disclosed as soon as reasonably practicable following identification.
List of entities covered by this strategy
- Shelbourne Group Ltd
- Shelbourne Ltd
- Shelbourne (North) Ltd
- Shelbourne (Midlands) Ltd
- Shelbourne (Eastern) Ltd
- Shelbourne Developments Ltd
- Shelbourne (Milton Keynes) Ltd
- Shelbourne (Kettering) Ltd
HBF and MHCLG launch Charter for Safe Working Practice
To support the return to work of housebuilders, the HBF has been working with government to develop a ‘Charter for safe working practice – Covid-19’.
The document demonstrates a commitment from housebuilders and the wider industry to safe working whilst Covid-19 remains prevalent. It also demonstrates government support for house building and sales activity and outlines the measures that should be in place.
As a member of the Home Builders Federation we are committed in our compliance to this Charter. The safety and health of our valued customers, staff and contractors is of the utmost importance to us. We are, and will continue to follow the advice of the government and have implemented all practical measures to help protect our communities.
The intention is that housebuilders will display the Charter on their sites, reinforcing their commitment to safe working and helping reduce concerns that their workforce, communities and customers may have at the current time.
Copies of the charter can be found in all of our marketing suites as well as on the HBF website.