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 Group Modern Slavery Statement

Peterborough Prison Management (Holdings) Limited & Peterborough Prison Management Limited (together “Peterborough Group”) Modern Slavery Statement & Human Trafficking Statement for the financial year to 31st March 2021.

Company Overview

Peterborough Group was formed as a Private Finance Initiative special purpose vehicle, whose purpose was to design, construct, finance and provide management services to a prison, HMP Peterborough, following the entry into a 25 years contract (“the PFI Contract”) with the Secretary of State for Justice (the “Authority”) for such services.

The Company operates a number of policies to ensure that it is conducting business in an ethical and transparent manner, including anti-bribery, Health & Safety, and Data Protection. The policies explain the manner in which we behave as an organisation and how we expect our suppliers to act.

The Company has no direct employees; however, it does have in place two Management Services Agreements.  The first agreement is with Resolis Limited (“Resolis”), which provides the services of a Finance Officer, Company Secretary and other management staff.  The second is with Sodexo Limited (“Sodexo”), which provides the services of the General Manager and again, other management staff.  Both Resolis and Sodexo operate robust recruitment policies including eligibility to work in the UK, checks for all employees to safeguard against human trafficking or individuals being forced to work against their will, and whistle-blowing.

Statement Overview

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that the Peterborough Group has taken and is continuing to take, using all reasonable endeavours, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.  Peterborough Group has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Supply Chain

The Company works with key supply chain partners.

Under the PFI Contract, construction and long-term facilities management subcontracts were put in place at the time when the PFI Contract was signed.  Due diligence was undertaken into the financial status, operating policies and practices (including ethical) of the subcontractors prior to the subcontracts being signed.  The principal subcontractors were pre-approved by both the Peterborough Group and the Authority to ensure they held any required accreditations or appropriate qualifications for the services that they would deliver.

Under the PFI Contract, the principal supplier of construction services was Interserve Construction Limited (“ICL”) which built the prison. Sodexo is the provider of facilities management services to the prison for the life of the concession.

The Peterborough Group recognises that there is a risk of slavery and human trafficking in the construction and facilities management sectors, and therefore expects both ICL and Sodexo to adhere to a policy of zero tolerance to slavery and human trafficking both within their own organisations and in any of their own supply chain partners who may provide services on their behalf to the prison or for the PFI Contract. The Board of the Peterborough Group has sought and received assurances and evidence of their policies and operational practices in this respect.

In addition, the Peterborough Group has an agreement in place with Lenders to provide credit facilities; the Board believes this area of activity is very low risk in relation to slavery and human trafficking.

The Peterborough Group intends to provide this statement to its key supply chain partners and to monitor their policies.

This statement will be reviewed on an annual basis.

This statement was approved by the Board of Directors on 26th May 2021

Signed for and on behalf of Peterborough Prison Management Holdings Limited & Peterborough Prison Management Limited.

By Kevin Cunningham, Director

Next Review: May 2022

Environments for Learning Limited Modern Slavery Statement

Environments for Learning Limited (“the Company”) Modern Slavery Statement & Human Trafficking Statement for the financial year to 30th September 2020.

Statement Overview

This statement is made pursuant to s.54 of the Modern Slavery Act 2015 which requires all trading companies with a net turnover of more than £36 million AND which carry on a business or part of the business in the UK (“the two criteria”), to adopt a Modern Slavery Statement (“Statement”). It sets out the steps that the Company has taken and is continuing to take using all reasonable endeavours to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.  The Company has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

Company Overview

The Company was formed to act as the Holding Company for a number of special purpose vehicle subsidiaries (“SPVs”), together the “Group”, whose business is to develop contracts with local authorities to build schools, learning and leisure facilities of excellence.  As of 30th September 2020, the Group has developed contracts for building and operating schools with the following clients: Sandwell Metropolitan Borough Council, Leeds City Council, St. Helens Borough Council and Plymouth City Council.

These contracts include PFI projects to:

  • Design, build, finance and operate 1 school in Sandwell;
  • Design, build, finance and operate 5 schools, 1 well-being centre and 2 leisure centres in Leeds;
  • Design, build, finance and operate 1 school in St. Helens;
  • Design, build, finance and operate 2 schools in Plymouth.

In addition, the Company has 4 design, build and operate contracts in Sandwell and several design and build contracts (D&B Contracts) for schools in Leeds, Sandwell, Plymouth and St Helens.

The Company operates a number of policies to ensure that it is conducting business in an ethical and transparent manner, including anti-bribery, Health & Safety, and Data Protection. The policies explain the manner in which we behave as an organisation and how we expect our suppliers to act.

The Company has no direct employees; however, it does have in place a Management Services Agreement with Resolis Limited (“Resolis”), which provides the services of a Finance Officer, Company Secretary, General Manager and other management staff to the Company.  Resolis operates a robust recruitment policy, including eligibility to work in the UK, and checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.

Supply Chain

The Company works with key supply chain partners.

Under the PFI projects, long-term construction and facilities management subcontracts were put in place at the time when the PFI contracts were signed.  Due diligence was undertaken into the financial status, operating policies and practices, including ethical, of the subcontractors prior to the subcontracts being signed, with the principal subcontractors requiring to be pre-approved by both the SPVs and our clients and to hold any required accreditations or appropriate qualifications for the services that they would deliver.

Under the PFI contracts, the principal supplier of services is Tilbury Douglas Construction Limited (“TDCL”), formerly known as Interserve Construction Limited, who provides the construction and facilities management services throughout the life of each project.  TDCL also supplies construction services for the design and build elements for the D&B contracts.

The Company recognises that there is a risk of slavery and human trafficking in the construction and facilities management sectors, and therefore expects ICL to adhere to a policy of zero tolerance to slavery and human trafficking both within its own organisation and in any of its own supply chain partners who may provide services on its behalf to the PFI or D&B contracts, and has sought and received assurances and evidence of its policies and operational practices in this respect.

In addition, the Company and each PFI contract have agreements in place with Lenders to provide credit facilities; the Company believes this area of activity is very low risk in relation to slavery and human trafficking.

The Company intends to provide this statement to its key supply chain partners and to monitor their policies.

This statement will be reviewed on an annual basis.

This statement was approved by the Board of Directors on 14th September 2021

By Kevin Cunningham, Director

Signed for and on behalf of Environments for Learning Limited. Date: 14th September 2021.

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