Modern Slavery Statements

Although not required to publish a human trafficking statement by the requirements of the Modern Slavery Act 2015 (the “Act”), Resolis takes its commitments to understanding and preventing Modern Slavery (as defined in the Act) very seriously and is attempting through all reasonable means to ensure there is no Modern Slavery in the Company or in its related supply chains.

Resolis Modern Slavery Statement

This Modern Slavery Statement (the “Statement”) is made on behalf of Resolis in line with the principles of the Act.

Company Overview

Resolis is a management and fund support services business, specialising in private finance initiatives and public-private partnership assets and was established in early 2021. The Company is part of the Dalmore Capital Group (“Dalmore”), which focuses on investment in low-volatility infrastructure assets in the UK and Europe.

Resolis is located in Edinburgh and operates across the UK and Northern Ireland.

Resolis Culture, Principles and Values

Resolis is creating a strong sense of identity which will develop over time with the fostering of a Company-wide culture, values and behaviours that are integral to all activities and decision-making within the business.

The key aim of Resolis is to professionally manage and support infrastructure assets throughout their lifecycle, whilst supporting all asset stakeholders. In order to achieve this alongside Dalmore, the Company will complement Dalmore’s own values and behaviours to develop and promote a feeling of connection and shared goals. Resolis’ culture is governed by a core set of values, being Partnership, Integrity and Resolve:

Partnership long-term relationships built on collaboration, trust and alignment of interests

Integrity honest, open, respectful and professional approach with all partners

Resolve diligently and efficiently working through stakeholder issues.

Given Resolis’s culture and values, paying due consideration to environmental, social and governance (“ESG”) factors is a matter of strategic priority. Consideration of ESG factors forms part of ongoing management responsibility. As with Dalmore, Resolis’s ESG focus areas include:

 

  • The promotion of diverse and inclusive workplaces;
  • Fair and rewarding employment; and
  • Respect for human rights.
Due Diligence Procedures

The Company undertakes a rigorous due diligence process when considering taking on new suppliers, employees and managed services agreements, and management remains alert to the risk of financial crime and the risk of Modern Slavery. The Company regularly reviews its existing and proposed suppliers, and its due diligence and KYC procedures are rigorous.

Staff Training & Hiring Policy

Staff Training

The Company undertakes a rigorous due diligence process when considering taking on new suppliers, employees and managed services agreements, and management remains alert to the risk of financial crime and the risk of Modern Slavery. The Company regularly reviews its existing and proposed suppliers, and its due diligence and KYC procedures are rigorous.

Hiring Policy

The Company is presented with a Modern Slavery risk when hiring new staff. In order to mitigate this, the Company has strong management systems and controls in place. These include:

 

  • Ensuring compliance with all of the Company’s legal obligations in the recruitment and onboarding process, with a confirmation of the employee’s right and eligibility to work in the relevant country or jurisdiction; and
  • Ensuring the Company conducts detailed due diligence on prospective employees prior to joining the Company.
Governance & Controls

The Company is developing a strong culture of ethical behaviour and embedded compliance culture, all augmented by a strong set of systems and controls designed to allow senior management to have effective control and oversight of the business. These controls and reports enable the Company to challenge the way it approaches and responds to risks (including Modern Slavery).

In the unforeseeable event that a specific area of our business is at risk of Modern Slavery and/or human trafficking, it would be identified in our due diligence procedures, escalated to senior management and appropriate mitigants would be established and implemented.

Whistleblowing Policy

Resolis has a whistleblowing policy in place and encourages an open compliance culture from the top down. The Company encourages all its employees, suppliers and other business partners to report any concerns. The whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. It requires employees to blow the whistle if they come across any activity or information which they believe tends to show that one or more of the events noted below has been or is likely to be committed:

 

  • A criminal offence;
  • A failure to comply with any legal obligation;
  • A miscarriage of justice;
  • The putting of the health and safety of an individual in danger;
  • Damage to the environment; or
  • Deliberate concealment relating to any of the above five matters.
Employee Handbook, Policies and Procedures

Staff are expected to comply with the Company’s Employee Handbook and all Policies and Procedures. The Company makes clear to staff the behaviour expected when representing the Company. The Company strives to maintain the highest standards of employee conduct and ethical behaviour.

Peterborough Prison Modern Slavery Statement

Peterborough Prison Management Limited (“the Company”) Modern Slavery Statement and Human Trafficking Statement for the financial year to 31 March 2023.

Introduction

This Modern Slavery Statement (the “Statement”) is made on behalf of the Company pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). The Company takes its commitments to understanding and preventing Modern Slavery (as defined in the Act) very seriously.

The Company welcomes the transparency encouraged by the Act and this Statement sets out for the public, its stakeholders and Business Partners the steps that the Company is taking in this regard.

The Company is party to an agreement (the “Project Agreement”) pursuant to which the Company is tasked with the design, construction, finance, operation and maintenance of the subject project (the “Project”). The Company is also party to an agreement (the “MSA”) pursuant to which the Company has appointed Resolis as the management services provider of the Project.

The Company does not have any employees but has contractual arrangements with its Business Partners to deliver the required services described in the Project Agreement.  The Business Partners have direct responsibility for their employees and their activities.  The Business Partners also have a responsibility to ensure that their work is effectively undertaken to prevent Modern Slavery and that there is cooperation and coordination between the parties to achieve this objective.

Commitment

The Company is committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Act in any part of its business or in its supply chain. 

The Company aims to ensure that in its policies, due diligence, contractual arrangements, training and reporting regimes, it is implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place in any part of its business or in its supply chain. 

Communications

The Company’s commitment to addressing the issue of Modern Slavery in its business and supply chain is communicated to all Business Partners at the outset of its business relationship and reinforced as appropriate thereafter. 

Resolis employees are also assisted by the Resolis Speak Up Policy which provides a framework for all Resolis employees to be confident in the knowledge that if they consider it is appropriate to raise a concern about another employee’s behaviour or practices, which they reasonably believe to be illegal, dangerous or unethical, that they can report this without fear of retribution, victimisation or detriment.

Supply Chain

The Company’s supply chain is very limited. The Company does not act as a producer, manufacturer or retailer of any physical goods.  Where the Company enters into a direct contract with a Business Partner, the Company will seek to select those who tackle the threat of human trafficking and modern slavery in accordance with international environmental, social and ethical standards.

The Company only uses reputable companies for the provision of services which have been assessed as suitable prior to them undertaking any work on the Company’s behalf.

Staff Training

The Company expects that its Business Partners will provide training and awareness as appropriate on the Act and the risk of Modern Slavery in the Company’s supply chain and that this training will form part of that Business Partner’s induction process for any individual who works on behalf of the Company.

Reporting

Where instances of Modern Slavery or any potential risks of Modern Slavery occurring within the Company’s supply chain, or other areas of its business, are identified, this information is escalated to the Board to determine the appropriate action(s) to be taken.

Review

This statement was approved by the Board of Directors on 22 November 2023.

Signed for and on behalf of the Company by Kevin Cunningham, Director.

Next Review: November 2024.

Ashford Prison Modern Slavery Statement

Ashford Prison Services Limited (“the Company”) Modern Slavery Statement and Human Trafficking Statement for the financial year to 31 March 2023.

Introduction

This Modern Slavery Statement (the “Statement”) is made on behalf of the Company pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). The Company takes its commitments to understanding and preventing Modern Slavery (as defined in the Act) very seriously.

The Company welcomes the transparency encouraged by the Act and this Statement sets out for the public, its stakeholders and Business Partners the steps that the Company is taking in this regard.

The Company is party to an agreement (the “Project Agreement”) pursuant to which the Company is tasked with the design, construction, finance, operation and maintenance of the subject project (the “Project”). The Company is also party to an agreement (the “MSA”) pursuant to which the Company has appointed Resolis as the management services provider of the Project.

The Company does not have any employees but has contractual arrangements with its Business Partners to deliver the required services described in the Project Agreement.  The Business Partners have direct responsibility for their employees and their activities.  The Business Partners also have a responsibility to ensure that their work is effectively undertaken to prevent Modern Slavery and that there is cooperation and coordination between the parties to achieve this objective.

Commitment

The Company is committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Act in any part of its business or in its supply chain. 

The Company aims to ensure that in its policies, due diligence, contractual arrangements, training and reporting regimes, it is implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place in any part of its business or in its supply chain. 

Communications

The Company’s commitment to addressing the issue of Modern Slavery in its business and supply chain is communicated to all Business Partners at the outset of its business relationship and reinforced as appropriate thereafter. 

Resolis employees are also assisted by the Resolis Speak Up Policy which provides a framework for all Resolis employees to be confident in the knowledge that if they consider it is appropriate to raise a concern about another employee’s behaviour or practices, which they reasonably believe to be illegal, dangerous or unethical, that they can report this without fear of retribution, victimisation or detriment.

Supply Chain

The Company’s supply chain is very limited. The Company does not act as a producer, manufacturer or retailer of any physical goods.  Where the Company enters into a direct contract with a Business Partner, the Company will seek to select those who tackle the threat of human trafficking and modern slavery in accordance with international environmental, social and ethical standards.

The Company only uses reputable companies for the provision of services which have been assessed as suitable prior to them undertaking any work on the Company’s behalf.

Staff Training

The Company expects that its Business Partners will provide training and awareness as appropriate on the Act and the risk of Modern Slavery in the Company’s supply chain and that this training will form part of that Business Partner’s induction process for any individual who works on behalf of the Company.

Reporting

Where instances of Modern Slavery or any potential risks of Modern Slavery occurring within the Company’s supply chain, or other areas of its business, are identified, this information is escalated to the Board to determine the appropriate action(s) to be taken.

Review

This statement was approved by the Board of Directors on 22 November 2023.

Signed for and on behalf of the Company by Kevin Cunningham, Director.

Next Review: November 2024.

Dudley Hospital Modern Slavery Statement

Summit Healthcare (Dudley) Limited (“the Company”) Modern Slavery Statement and Human Trafficking Statement for the financial year to 31 March 2023.

Introduction

This Modern Slavery Statement (the “Statement”) is made on behalf of the Company pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). The Company takes its commitments to understanding and preventing Modern Slavery (as defined in the Act) very seriously.

The Company welcomes the transparency encouraged by the Act and this Statement sets out for the public, its stakeholders and Business Partners the steps that the Company is taking in this regard.

The Company is party to an agreement (the “Project Agreement”) pursuant to which the Company is tasked with the design, construction, finance, operation and maintenance of the subject project (the “Project”). The Company is also party to an agreement (the “MSA”) pursuant to which the Company has appointed Resolis as the management services provider of the Project.

The Company does not have any employees but has contractual arrangements with its Business Partners to deliver the required services described in the Project Agreement.  The Business Partners have direct responsibility for their employees and their activities.  The Business Partners also have a responsibility to ensure that their work is effectively undertaken to prevent Modern Slavery and that there is cooperation and coordination between the parties to achieve this objective.

Commitment

The Company is committed to ensuring that there is no slavery, servitude, forced or compulsory human labour, abuse of power over vulnerable individuals, human trafficking or any other form of exploitation as contemplated by the Act in any part of its business or in its supply chain. 

The Company aims to ensure that in its policies, due diligence, contractual arrangements, training and reporting regimes, it is implementing and enforcing effective systems and controls to ensure Modern Slavery is not taking place in any part of its business or in its supply chain. 

Communications

The Company’s commitment to addressing the issue of Modern Slavery in its business and supply chain is communicated to all Business Partners at the outset of its business relationship and reinforced as appropriate thereafter. 

Resolis employees are also assisted by the Resolis Speak Up Policy which provides a framework for all Resolis employees to be confident in the knowledge that if they consider it is appropriate to raise a concern about another employee’s behaviour or practices, which they reasonably believe to be illegal, dangerous or unethical, that they can report this without fear of retribution, victimisation or detriment.

Supply Chain

The Company’s supply chain is very limited. The Company does not act as a producer, manufacturer or retailer of any physical goods.  Where the Company enters into a direct contract with a Business Partner, the Company will seek to select those who tackle the threat of human trafficking and modern slavery in accordance with international environmental, social and ethical standards.

The Company only uses reputable companies for the provision of services which have been assessed as suitable prior to them undertaking any work on the Company’s behalf.

Staff Training

The Company expects that its Business Partners will provide training and awareness as appropriate on the Act and the risk of Modern Slavery in the Company’s supply chain and that this training will form part of that Business Partner’s induction process for any individual who works on behalf of the Company.

Reporting

Where instances of Modern Slavery or any potential risks of Modern Slavery occurring within the Company’s supply chain, or other areas of its business, are identified, this information is escalated to the Board to determine the appropriate action(s) to be taken.

Review

This statement was approved by the Board of Directors on 14 November 2023.

Signed for and on behalf of the Company by Matthew Templeton, Director.

Next Review: November 2024.

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