ABOUT THIS POLICY
The Wise Group is committed to conducting its businesses in a socially responsible way. We seek to carry out their operations in accordance with appropriate ethical standards and be honest and fair in their relationships with customers and suppliers. As part of this, WISE GROUP is dedicated to ensuring that effective systems and controls are in place to safeguard against modern slavery and human trafficking occurring within our businesses or any of our supply chain.
WISE GROUP SLAVERY AND HUMAN TRAFFICKING STATEMENT
In accordance with the Modern Slavery Act 2015 (“Act”), WISE GROUP has published this statement on behalf of all entities within its family of companies, including Wise Group Holdings Limited, Wise Living Developments and their subsidiaries (“WISE GROUP”). This statement sets the steps that members of the WISE GROUP have taken to prevent modern slavery and human trafficking from occurring within its business and supply chains.
WISE GROUP Businesses
WISE GROUP through its subsidiaries is a leading provider of property services to its key customer groups:
- Services provided to consumers include real property auctions (buying and selling real property) and property management services (lettings management including property maintenance through Wise Maintenance); and;
- Services provided to investors(identifying potential opportunities, supervising development and providing lettings and asset management)
As at 1st September 2021, WISE GROUP through its subsidiaries employed circa 98 people across the UK, where its business operations are entirely based.
Wise Group Supply Chains
Members of WISE GROUP have established direct relationships with a number of primarily UK-based suppliers who deliver a variety of services (for example professional services, utilities and telecoms, and facilities management). As part of its service delivery, members of Wise Group procure services not just for themselves, but also for the benefit of some of the customers of other group companies (for instance, engaging contractors to provide maintenance services to properties managed by the Group).
The vast majority of services are procured via specialist individuals employed or engaged by members of Wise Group (relationship managers).
Wise Group Policies and Contractual Provisions
The approach of members of Wise Group to the promotion of human rights and ethical issues is contained within WISE GROUP HR Policies which include but not limited to:
- Anti-Bribery and Corruption Policy
- Equal Opportunities Policy
- Recruitment Policy
- Whistleblowing Policy
- Grievance Policy
- Anti-Bullying and Harassment Policy
The WISE GROUP HR policies apply to all individuals employed or engaged by WISE GROUP and our subsidiaries. Employees can use the whistleblowing policy to report suspected concerns within the WISE GROUP businesses and supply chains.
Since the enactment of the Act members of the Wise Group have taken steps to seek to ensure that any new agreements with suppliers include an express obligation for suppliers to comply with the Act, to implement due diligence procedures within its own supply chains and notify WISE GROUP in the event of any actual or potential incidence of modern slavery In the event of a breach of these provisions, members of Wise Group will seek to resolve any issues with its suppliers and it may also seek to terminate the relationship with the supplier where a resolution is not achieved. This provision is regularly reviewed, and relevant amendments made.
Wise Group Due Diligence
Members of the Wise Group have identified our supply chains as the main area of risk and exposure to modern slavery.
The suppliers used by Wise Group have been identified as low risk. The suppliers which provide manufactured goods to Wise Group are very few, limited to marketing providers (providing posters etc), and facilities providers (providing toiletries, vending machine and drink machine products etc.) Other suppliers to Wise Group mainly provide in-person services, such as maintenance services and recruitment services.
Contractors used by WISE GROUP pass through an on-boarding process, which includes terms requiring them to comply with the Act and provide a copy of their modern slavery statement where requested.
Wise Group Areas of Risk
Overall exposure to modern slavery for members of the Wise Group is lower than other sectors given the nature of the property services sector in which our businesses operate, the types of services we procure and the fact that our business operations and those of the majority of our suppliers are primarily based in the UK.
Notwithstanding the above, Wise Group is not complacent and understands that the procurement of recruitment and facilities services and the use of subcontractors are practices which may bring about increased risks of modern slavery within supply chains.
Accordingly, WISE GROUP is taking steps to mitigate such risks, including:
- Requiring suppliers to implement due diligence procedures for its own suppliers and subcontractors.
- Having in place stringent checks on our recruitment agencies and ensuring our own internal recruitment processes meet the minimum legal requirement.
As part of this, Wise Group complies with all relevant legislation including the Immigration, Asylum and Nationality Act 2006 and ensures that all appropriate checks are carried out to maintain compliance. If further risks are identified, Wise Group will consider such risks and take appropriate steps to address any emerging risks.
Wise Group Training
Wise Group understand the importance of training employees to enable them to be able to identify risks of modern slavery. Wise Group employees receive information that allows them to understand the requirements under the Act in the form of this policy. They also receive our whistleblowing policy, which would allow them to raise concerns anonymously.
Monitoring
The Board appreciates that the approach to combatting modern slavery will have to adapt over time in response to findings following the completion of various risk assessments.
