Introduction

This statement is made on behalf of Beal Securities Limited in compliance with the Modern Slavery Act 2015 (‘the Act’) and constitutes our slavery and human trafficking statement for the financial year ended 31 st December 2018.

We are committed to ensuring that there is no Modern Slavery or Human Trafficking throughout any group company or our supply chain.

Our Structure

Beal Homes is a trading name of the group’s sole trading entity Beal Developments Limited. Beal Developments Limited is a subsidiary of the group’s ultimate parental entity Beal Securities Limited. Beal Homes operates solely in East Yorkshire and North Lincolnshire and directly employs approximately 150 employees at any one time.

Our Supply Chain

Our supply chain includes building contractors, sub-contractors, agencies, material suppliers and professional consultants.

Our Policies

The Employee Handbook contains the policies adopted by Beal Developments Limited regarding recruitment, employee conduct, whistleblowing and corresponding enforcement standards. Each policy has been updated to make specific reference to this Act.

All employees must provide evidence of their Right to Work before commencing employment. We comply with, and often exceed, all other minimum legislative requirements regarding minimum pay, benefits and working conditions. No employee may work in excess of working time regulations unless they give their explicit consent to opt out.

Every order placed via our supply chain by Beal Developments Limited includes our standard Terms and Conditions. These terms specify our expectation that all suppliers and / or subcontractors must comply with this Act.

We aim, wherever possible, to source materials and products from established UK suppliers and endeavour to build and maintain longstanding trading relationships with such suppliers.

Due Diligence

In compliance with this Act, we continually undertake and review a robust Risk Assessment to assess any area which may be vulnerable to Modern Slavery and Human Trafficking. Due to the internal policies and controls we have in place, we are confident that the prospect of non-compliance from within is extremely unlikely.

We will seek to appoint established subcontractors and agencies in all instances. In order to for a subcontractor or agency to be approved they must supply documented evidence of Right to Work checks, staff National Insurance numbers and confirm that they comply with National Minimum Wage rates of pay. All subcontract and agency workers must also prove CSCS card accreditation to demonstrate their ability to perform the work for which they are employed.

Many of our suppliers are large national and multi-national companies or PLCs with rigorous compliance departments, supplying organisations on a day to day basis with similar obligations to fulfil under this Act. As such we remain extremely confident that any risk posed by such suppliers is low. Nevertheless, each appointment made or order placed by the company includes our standard Terms and Conditions stating all entities supplying the company must comply with the Act regardless of size or nature.

We have identified the greatest risk of non-compliance results from smaller suppliers, many of whom may not be set up or obliged to report on their compliance. Such suppliers will still be expected to abide by our Terms and Conditions or risk their contract being terminated. As we may be several steps removed from the production and distribution of their products, proof of compliance may be difficult to ascertain in all circumstances. As part of our procedures in this area we will request information regarding higher risk areas we have identified in addition to our usual procedural checks. It should be noted however that a certain amount of reliance that must be placed on the honesty and transparency of each supplier. To mitigate this we try use established UK suppliers already known to the business wherever possible.

Training

We have initiated a programme of on-going training for all employees in a position to uphold our compliance with the Act. All employees are made aware of their obligations under the Act and the importance of its adherence by virtue of any updates made to our Employee Handbook as and when required.

We will offer appropriate support to any entity throughout our supply chain who, in the first instance, does not appear to have met our standards in this area. We will work to inform them by issuing the appropriate guidelines and offering access to policies and training materials as may be required.

Ongoing Development

Beal Securities Limited and its subsidiaries have zero tolerance for Modern Slavery and Human Trafficking and are committed to raising awareness and understanding of such illegal practices across all employees and everyone within our supply chain. We recognise that this is an evolving process and will annually audit the effectiveness of our procedures as well as monitoring guidance from the Home Office to ensure that we continue to adopt best practice.

This statement has been approved by the board of directors on 29th March 2019 and signed on its behalf by:

Richard Beal

Chief Executive

29th March 2019