Modern Day Slavery Policy

July 2024

ABOUT THIS POLICY

Wise Lettings & Management Ltd is committed to conducting its businesses in a socially responsible way. We seek to carry out operations in accordance with appropriate ethical standards and be honest and fair in their relationships with customers and suppliers.

As part of this, Wise 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.

SLAVERY AND HUMAN TRAFFICKING STATEMENT

In accordance with the Modern Slavery Act 2015 Act, Wise has published this statement on behalf of Wise Lettings & Management Ltd and all associated entities including Wise Living Developments. This statement sets the steps that members of Wise have taken to prevent modern slavery and human trafficking from occurring within its business and supply chains.

WISE LETTINGS & MANAGEMENT LTD

Wise Lettings & Management Ltd is a leading provider of property services to its key customer groups:

• Property management services (lettings management including property maintenance through Wise Maintenance)
• Services provided to investors (identifying potential opportunities, supervising development and providing lettings and asset management)

As of 1st July 2024, Wise Lettings & Management Ltd employed circa 50 people across the UK, where its business operations are entirely based.

WISE SUPPLY CHAINS

Wise Lettings & Management Ltd have established direct relationships with several primarily UK-based suppliers who deliver a variety of services (for example professional services, utilities and telecoms, and facilities management).

Many services are procured via specialist individuals employed or engaged by members of Wise (relationship managers).

WISE POLICIES AND CONTRACTUAL PROVISIONS

The approach of Wise to the promotion of human rights and ethical issues is contained within Wise 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 HR policies apply to all individuals employed or engaged by Wise Lettings & Management Ltd. Employees can use the whistleblowing policy to report suspected concerns within the business and supply chain.

Since the enactment of the Modern Slavery Act 2015 Act members of Wise 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 in the event of any actual or potential incidence of modern slavery.

In the event of a breach of these provisions, members of Wise 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 DUE DILIGENCE

Wise have identified our supply chains as the main area of risk and exposure to modern slavery.

The suppliers used by Wise have been identified as low risk. The suppliers which provide manufactured goods to Wise are very few, limited to marketing providers (providing posters etc), and facilities providers (providing toiletries, snack foods and drink machine products etc.) Other suppliers to Wise mainly provide in-person services, such as maintenance services and recruitment services.

Contractors used by Wise 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 AREAS OF WORK

Overall exposure to modern slavery for Wise 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 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 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 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 will consider such risks and take appropriate steps to address any emerging risks.

WISE TRAINING

Wise understand the importance of training employees to enable them to be able to identify risks of modern slavery. All 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

Wise 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.