Modern Slavery Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Aims

Northlight Estates is committed to conducting business in an ethical manner, upholding basic human rights in all its operations so that its staff and workers including those of its supply chain are not subject to behaviour or threats that amount to modern slavery, human trafficking or forced labour.

Our Business

Northlight Estates operates in the UK providing commercial and residential property investment opportunities.

Managing Risk

The directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The directors all have a day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and for maintaining awareness of the issue of modern slavery in supply chains.

We expect our suppliers to hold their own suppliers to the same high standards.

Our Policies

Northlight Estates's Modern Slavery Policy, along with our Anti-Bribery, Anti-Tax Evasion and Whistleblowing policies demonstrate our commitment to acting ethically and with integrity in all our business relationships.

Our Procedures

In order to assess the risk of modern slavery, we plan to implement the following processes:

• Identify and assess potential risks when taking on new suppliers
• Regular reviews of our existing supply chains
• Protection for whistleblowers

We have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain.

Training

To highlight awareness of modern slavery and human trafficking the Modern Slavery Policy has been included in the employee handbook.

Periodic review

This policy will be reviewed annually, or more frequently in the event of any changes to statutory requirements or any evidence that the policy is not fully effective.

On behalf of Northlight Estates