Modern Slavery Statement

Organisation

This statement applies to all companies within and associated to The Ashville Group (referred to in this statement as “The Group”). The information included in the statement refers to the financial year March 2026.

Definitions

The Group considers that modern slavery encompasses:

  • human trafficking
  • forced work, through mental or physical threat
  • being owned or controlled by an employer through mental or physical abuse or the threat of abuse
  • being dehumanised, treated as a commodity or being bought or sold as property
  • being physically constrained or to have restriction placed on freedom of movement.

Commitment

The Group acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. The Group understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

The Organisation does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to the Group in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Group strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom, and in many cases exceeds those minimums in relation to its employees.

Organisational structure

The Group’s operational arm, Ashville Asset Management Limited, operates primarily from it’s Head Office in Vintry Building, Wine Street, Bristol BS1 2BD.  A small number of employees, but ones closely involved in procurement and selection of contractors, are based on site at assets under management in Cardiff, Bristol and Southampton.  Employees on site are overseen by Property Managers working out of the Head Office whom sign off on significant procurement decisions.  All staff are subject to training, including the Board.

The primary relevant tasks undertaken by Ashville Asset Management Limited are:

  • Contract of Services – Appointment of cleaning, engineering and security contracts for commercial and residential sites under management.
  • Project Coordination – The appointment and ongoing oversight on behalf of clients of consultants and property professionals in the provision of advice and Project Management in the refurbishment, management and/or construction of commercial property in the United Kingdom.

The labour supplied to the Group in pursuance of its operation is carried out in the United Kingdom.

Supply chain structure

In order to fulfil its activities, the main supply chains of the Group include those related to the provision of Asset Management, Property Management and Property Development. We understand that a proportion of the Group’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.

Organisational policies

The Group has the following policies which further define its stance on modern slavery:

  • Code of Conduct
  • Whistleblowing Policy
  • Anti-Corruption & Bribery

Assessing and managing risk

The Group considers its main exposure to the risk of slavery and human trafficking to exist in the procurement of services such as cleaning and in the development supply chain, whilst noting that it only undertakes works within the United Kingdom.

In general, the Group considers its exposure to slavery/human trafficking to be relatively low.   Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Due diligence in relation to modern slavery

The Group carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers.

Contractors and suppliers are subject to ongoing scrutiny for their compliance with all their legal requirements, including Modern Slavery, Health & Safety and meeting their obligations to all employees and their supply chain in all of their activities.

Training

The Group provides the following training to staff to effectively implement its stance on modern slavery with annual training for all staff within the Group.

Monitoring and evaluation

The Group has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Group or its supply chains.

The Group relies upon the informed awareness of all its staff, consultants and suppliers to identify and raise any potential concerns over Modern Slavery.  To support this it requires suppliers and consultants to confirm their compliance with the Modern Slavery Act 2015 and their disclosure of their Modern Slavery Policy and Statement.  Further, all staff are trained to identify potential indicators and the topic is on the agenda of the H&S/Property Management Committee which meets every 6 months.

Steps

The Group has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, the Group  has taken the following steps to ensure that modern slavery is not taking place:

  • Reviewing supplier contracts to include termination powers in the event that the supplier is, or is reasonably suspected to be, involved in modern slavery.
  • Reviews in discussion on a 6 monthly basis contracts considered at risk of including Modern Slavery.
  • Training all staff on awareness about and providing clear guidance on what to do in the event of suspected Modern Slavery by a supplier.
  • Establishing and communicating to all stakeholders a commitment to an absolute zero tolerance stance by the Group towards Modern Slavery.

Modern slavery compliance officer

The Group has a modern slavery compliance officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to the Organisation’s obligations.

This statement is made in pursuance of s.54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Date of approval: 01/04/2025