This Statement is made by the Directors of Shropshire Homes Limited pursuant to Section 54 of the
Modern Slavery Act 2015.
Introduction
Shropshire Homes Limited is committed to preventing slavery and human trafficking in its corporate
activities and to ensuring that its supply chains are free from slavery and human trafficking. This
statement outlines our procedures for evaluating and assessing potential risk in order to ensure that
our business does not engage in or endorse modern slavery or human trafficking.
Organisational structure and supply chains
This statement covers the activities of the Organisation, the Organisation is a private residential
property developer, employing approximately 90 people across Shropshire & surrounding Counties.
For the year ending 31 Dec 25, the Organisation had an annual turnover of circa £40.5m.
Countries of operation and supply
The Organisation currently operates in the following continents/countries:
• United Kingdom
The following is the process by which the Organisation assesses whether or not particular activities
or countries are high risk in relation to slavery or human trafficking:
Countries which are within the European Union, and other western countries such as the USA are
deemed to be low-risk countries.
Particular attention will be given to countries with a known poor record on human rights or labour
conditions when deciding whether or not to engage with such suppliers. A decision will then be
taken by the Directors based upon intelligence gathered pursuant to the process above.
Any supplier or potential supplier from a high-risk territory who is not able to demonstrate that it
has taken/is taking measures to minimise slavery and human trafficking will be required to
demonstrate that such steps have been taken prior to the Organisation engaging with such a
supplier.
High-risk activities
The following activities are considered to be at high risk of slavery or human trafficking:
• Procurement of building supplies from high-risk territories.
• Risk of non-adherence to labour laws and breach of environmental laws by suppliers.
• Procurement of natural resources (timber etc.) from high-risk territories.
• Use of ‘gangmasters’ to provide labour on construction sites.
Responsibility
Responsibility for the Organisation's anti-slavery initiatives is as follows:
• Policies: Richard Shackleton Managing Director, Howard Thorne Chairman
• Risk assessments: James Fogg Health & Safety Manager
• Investigations/due diligence:
Richard Shackleton Managing Director
Tom Cox Commercial Director
• Training: Group – wide awareness training to be delivered in 2026 for new starters and
existing staff.
Relevant policies
The Organisation operates the following policies that describe both its approach to the identification
of modern slavery risks and also steps to be taken to prevent slavery and human trafficking in its
operations:
Whistleblowing policy
The Organisation encourages all its employees, customers and other business partners to report
any concerns related to the direct activities, or the supply chains of, the Organisation. This includes
any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The
Organisation's whistleblowing procedure is designed to make it easy for employees to make
disclosures, without fear of retaliation. Employees, customers or others who have concerns can
contact their line manager, the H&S Manager or the Managing Director.
Anti-Bribery & Corruption policy
The Organisation's policy makes clear to employees the actions and behaviour expected of them
when representing the Organisation. The Organisation strives to maintain the highest standards of
employee conduct and ethical behaviour when operating and managing its supply chain.
Procurement Process
The Organisation is committed to ensuring that its suppliers adhere to the highest standards of
ethics. Suppliers are required to demonstrate that they provide safe working conditions where
necessary, treat workers with dignity and respect, and act ethically and within the law in their use
of labour. The Organisation works in partnership with suppliers to ensure that they meet the
standards of procurement process. Failure to observe the terms and conditions of the Procurement
Process may result in the termination of the business relationship.
Recruitment policy
The Organisation uses only specified, reputable employment agencies who meet the criteria defined
by our preferred supplier list to source labour.
Employment Contracts
The Organisation’s employment contracts clearly state that the Organisation has a strict anti-bribery
and corruption policy in line with the Bribery Act 2010, which all employees agree to adhere to. The
Organisation’s employment contracts also make clear employees’ leave entitlement, which is in
excess of the statutory minimum requirement. Employment contracts also state employees’
probationary periods and make clear that at the end of such probationary period, employees will
be eligible to join the Organisation’s pension and healthcare schemes, both of which offer generous
packages to employees which comply with the relevant statutory provisions.
Due diligence
The Organisation undertakes due diligence when considering taking on new suppliers, and regularly
reviews its existing suppliers. The Organisation's due diligence and reviews include:
• Implementing the introduction of a modern slavery questionnaire to be provided to all
suppliers, requiring all suppliers to confirm that they are not engaged in the practice of
modern slavery and/or human trafficking and that they have taken reasonable steps to
minimise the risk of the same within their own supply chains;
• mapping the supply chain broadly to assess particular product or geographical risks of
modern slavery and human trafficking;
• evaluating the modern slavery and human trafficking risks of each new supplier;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain
mapping;
• conducting supplier audits or assessments through the Organisation's own staff, which have
a greater degree of focus on slavery and human trafficking where general risks are identified;
• the intention of creating an annual risk profile for each supplier;
• taking steps to improve substandard suppliers' practices, including providing advice to
suppliers and requiring them to implement action plans; and
• invoking sanctions against suppliers that fail to improve their performance in line with an
action plan or seriously violate our supplier code of conduct, including the termination of
the business relationship.
Performance indicators
The Organisation regularly reviews its key performance indicators in line with business objectives.
As a result, the Organisation is committed, as follows:
• to ensure all employees deemed relevant will have completed training on modern slavery
by the end of 2026;
• to developing a system for supply chain verification expected to be in place by the end of
2026, whereby the Organisation evaluates potential suppliers before they enter the supply
chain; and
• to reviewing its existing supply chains which is expected to be completed by the end of 2026,
whereby the Organisation evaluates all existing suppliers.
Training
• The Organisation requires all employees within the Organisation to complete training on
modern slavery.
The Organisation's modern slavery training which will be completed by the end of 2026, will
demonstrate the following to our employees:
• our business's purchasing practices, which influence supply chain conditions, and which
should therefore be designed to prevent purchases at unrealistically low prices, the use of
labour engaged on unrealistically low wages or wages below a country's national minimum
wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the
business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within
the organisation;
• what external help is available, for example through the
o Modern Slavery Helpline - 08000 121 700,
o Gangmasters and Labour Abuse Authority (GLAA) - 0800 432 0804
o and "Stronger Together" initiative - 01276 919090
• what messages, business incentives or guidance can be given to suppliers and other business
partners and contractors to implement anti-slavery policies; and
• what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Organisation's supply
chains.
• Awareness-raising programme
• As well as training employees, the Organisation commits to raising awareness of modern
slavery issues by circulating a series of emails to all employees and using a poster campaign.
The campaign will explain to employees
• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the
relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.
• Board/Member approval
• This statement has been approved by the organisation's Board of Directors who will review
and update it annually.
This statement was approved by the Board of Shropshire Homes on 8th October 2026.
Signed: Richard Shackleton - Managing Director