This voluntary statement is made in accordance with Section 54 of the Modern Slavery Act 2015 (‘the Act’). It sets out the actions Round Hill Capital ( “Round Hill” or the “Company”), has taken to date, including in the financial year to 31 December 2019 , and is proposing to take in the coming financial year, to address the risk of slavery or human trafficking occurring in its business or supply chains. This statement, and the policies and procedures described in it to prevent slavery and human trafficking, are intended to cover all of Round Hill Capital’s subsidiaries. Round Hill does not currently have a legal obligation to make this statement but has elected to do so voluntarily.
At Round Hill we are committed to preventing slavery and human trafficking in our business and will seek to ensure that our supply chains are free from slavery and human trafficking.
Round Hill is a global property investment and development company based in London.
Our supply chain
Round Hill is committed to ensuring that its suppliers adhere to the same high standards of ethics as Round Hill. In order to supply goods or services to Round Hill, an organisation must complete a third party take-on questionnaire to be a preferred supplier. Individuals and organisations are required to confirm that they provide inter-alia, (i) safe working conditions, (ii) treat workers fairly, (iii) pay the minimum wage and (iv) comply with all local employment-related regulations. Round Hill periodically makes enquiries of suppliers to ensure appropriate policies are in place and adhered to. Where a supplier is suspected of failing to maintain or comply with such policies, or comply with applicable laws or regulations, action will be taken to investigate the issue and appropriate steps taken to address it.
Round Hill undertakes appropriate due diligence on each supplier prior to engagement, and regularly reviews its existing suppliers. Due diligence and periodic reviews cover, among other areas, the following policies and risks:
- Health and safety
- Employment conditions including payment of the minimum wage
- Anti-bribery and corruption
- Payment practices.
Questions relating to Modern Slavery and related offences have been added to the Round Hill Third Party Service Provider questionnaire and all suppliers are required to confirm their compliance with the Act and all applicable laws. Responses to our enquiries have not identified any high-risk areas in our supply chain.
Round Hill Capital has 200+ employees globally. Round Hill’s code of conduct makes clear the actions and behaviour expected of employees when representing the Company. We strive to maintain the highest standards of employee conduct and ethical behaviour in business dealings and managing our supply chain.
The Company adheres to all relevant employment legislation and we are committed to creating a work environment where everyone is treated with dignity and respect. The Human Resources team, supported by the compliance team, oversees the induction and training of all staff in the Company’s anti-corruption policies and the code of ethics.
Round Hill has a Whistleblowing Statement including a clear escalation process for employees and contractors to raise concerns relating to the Company’s business practices, including the crimes of modern slavery and human trafficking. No reports concerning modern slavery or human trafficking have been received to date.
Round Hill Capital is an Appointed Representative of Thornbridge Investment Management LLP and as such adheres to the Thornbridge Code of Ethics, which is updated and distributed annually. The code of ethics requires all employees to apply honest and ethical standards to all day to day activities with mutual respect a core tenet for the Round Hill group of companies.
Round Hill uses only specified, reputable employment agencies to source temporary or permanent employees.
We are confident that there is a very low risk of slavery or human trafficking in the employment or engagement of our own employees.
To ensure a good level of understanding of the risks of modern slavery and human trafficking in our business and supply chains, we will provide appropriate specialist training on modern slavery and human trafficking to relevant members of staff and a general briefing on the issues to all employees.
As we seek to continually improve our approach to and identification of the risks of modern slavery, we intend to:
- continue to work with our Framework Contractors and Non-Framework Contractors to monitor and identify any emerging risks of slavery and human trafficking in our construction supply chain;
- monitor our preferred suppliers for adherence to best practice;
- focus on specialist training for colleagues with responsibility for supply chain management and procurement; and
- provide induction and refresher training for all employees.
Date: 1 June 2020