Urban Splash

Urban Splash is a purpose led regeneration and property group that wants to leave a positive mark on the world by using great design and transformative ideas to breathe new life into undervalued buildings and places.

Urban Splash is committed to conducting its business ethically. We will use this statement to set out the actions taken so far to combat slavery and human trafficking, and the steps that we will take in the future to improve our practices in this area.

The size and complexity of some of our projects means that it can take a number of years for schemes to reach completion. For this reason, the turnover of subsidiary companies within our group, and of the group overall at a consolidated level can vary from year to year, taking us above and below the £36m reporting threshold of the Modern Slavery Act 2015.

In 2023, our group turnover was below £36 million. Although we are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.

Urban Splash Group Holdings Limited makes this statement on behalf of our subsidiary companies, all of which adopt these terms.

Urban Splash is a privately owned group with offices in the United Kingdom. Urban Splash operates through subsidiary operating companies, which for the most part share similar boards of executive directors and shareholder directors.

We recognise that as we operate within the construction and property management sector, there is an enhanced risk of modern slavery and human trafficking in our supply chains – including high levels of contract workers. We will therefore work with our suppliers, adopting a risk-based approach to assessing and managing our relationships with them. We are committed to opposing modern slavery in each of its forms, and we expect our suppliers to adopt the same high standards as we do.

As an employer of skilled and qualified people, the risk of modern slavery or human trafficking existing within our own business is low. We also have robust employment policies and procedures in place to further reduce the risk.

Each of our employees is paid fairly for the work performed. We pay the Real Living Wage or above to all of our own employees, and we ensure that those working for our suppliers maintaining our head office space also receive a fair wage from their employers.

We have reviewed our workplace policies and procedures to ensure their effectiveness in identifying and tackling modern slavery issues. We are confident that our policies and procedures demonstrate our commitment to acting ethically. We have direct relationships with our suppliers, and only senior employees are permitted to agree terms with suppliers – once due diligence has taken place.

Our employee handbook makes it clear that, in addition to any penalties that might be imposed by the law, any employee who violates our policies may be subject to disciplinary procedures (up to and including termination of employment).

Our people and our suppliers will therefore be expected to report, at the earliest opportunity, any activity or behaviour that might lead to (or suggest) slavery or human trafficking in any part of our business or its supply chains.

Urban Splash is committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery (of whatever form) is taking place within Urban Splash or its supply chains – including if the report is mistaken.

Our Bribery and Corruption Policy, and our Whistleblowing Policy, both reinforce these commitments. These are published and available to all of our people on our software portal, People HR.

As stated above, Urban Splash has assessed the risk of slavery and human trafficking within its own business to be low.

As part of our process of identifying and mitigating risk levels, we will continue to develop our processes to:

• Identify and assess potential risk areas in our supply chains

• Mitigate any risk areas identified in our supply chains

• Monitor potential risk areas in our supply chains

We have a ‘zero tolerance’ approach to slavery and human trafficking. Where reasonably practicable and appropriate, our contracts with suppliers will include specific provisions against slavery and human trafficking, with the option for us to terminate an arrangement if the supplier breaches its obligations under the Modern Slavery Act 2015.

We will also check that each supplier has published its own modern slavery and human trafficking statement (where they are required to do so), and review copies of any statements that exist.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our business and its supply chains, we provide training and guidance to our people. This includes ensuring that all of our people are aware of our stance on slavery and human trafficking, and ensures that those who have responsibility for procuring goods and services are prioritised for appropriate training and guidance.

Following a review of our policies and procedures, we intend to take the following steps to allow us to combat slavery and human trafficking:

• Create a specific Anti-Slavery and Human Trafficking Policy, to be published on our on our software portal, People HR.

• Develop our procurement practices – to include carrying out risk assessments on our existing suppliers, and on any new suppliers, to identify those we consider to be most at risk of having slavery or human trafficking in their own businesses

• Where risks are identified, we will obtain and review the modern slavery statements for those businesses, and/or seek assurances that they are taking active steps to ensure there is no slavery or human trafficking within their own businesses or supply chains

Board approval

This statement has been approved by the Executive Board, and is signed on behalf of Urban Splash by:

Julian Curnuck, CEO