Blue Coast Capital Properties Limited Modern Slavery and Human Trafficking Statement 2021

Introduction

This Modern Slavery and Human Trafficking Statement relates to actions and activities during the financial year 2021.

The statement sets out Blue Coast Capital Properties Limited’s commitment to preventing slavery and human trafficking in our business activities and the steps we have put in place with the aim of ensuring that there is no slavery or human trafficking in our own business and supply chains. We all have a duty to be alert to risks, however small. Staff are expected to report their concerns and management to act upon them.

Organisational structure and supply chains

This statement covers the business activities of Blue Coast Capital Properties Limited which are as follows:

Blue Coast Capital Properties Limited is a holding company for the property development and hospitality and investment business of the wider group.

The Company currently operates across Europe, Asia and the US.

The following is the process by which the Company assesses whether particular activities or countries are high risk in relation to modern slavery or human trafficking:

• Review of the business activities of the company and its subsidiary group to identify areas of potential risk or exposure;
• Oversight and review of third-party suppliers, agents and partners;
• Regular monitoring of industry news and developments;
• Training on Modern Slavery practices and high risk areas for all staff;
• Regular review and updating of internal policies and procedures.

High Risk Activities

The following activities are considered to be at high risk of modern slavery or human trafficking within our corporate group:

• The engagement of third-party suppliers and agents within the value chain of the business, in particular agency companies used for maintenance of the Company’s and corporate group’s property portfolio;

Responsibility for the Company’s anti-slavery initiatives is as follows:

1. 1. Policies: The HR department are responsible for creating and reviewing policies. The process by which policies are developed is a collaboration between different group departments, including both operational and compliance functions;
   2. Risk assessments: The Procurement team is responsible for risk assessments in respect of human rights and modern slavery;
   3. Due diligence: Human Resources is responsible for due diligence in relation to known or suspected instances of modern slavery and human trafficking.

Training

To ensure a good understanding of the risks of modern slavery and human trafficking in our business and supply chains, the Company requires all staff to complete annual online training courses as well as participate in any ad-hoc courses or review periodic training material.

Policies

The Company is committed to ensuring that there is no modern slavery or human trafficking in our business or our supply chains. This Statement affirms its intention to act ethically in our business relationships.

The following policies set out our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:

2. 1. Whistleblowing; the Company encourages all its workers, customers and other business partners to report any concerns related to its direct activities or its supply chains.
   2. Employee and Company Conduct; Company policies set out the actions and behaviour expected of employees when representing the Company.

Due Diligence Processes for Slavery and Human Trafficking

The Company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The Company’s due diligence process includes a thorough review of any third-party suppliers own policies and procedures, pre-take-on suitability review forms, building long-standing relationships with suppliers and making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier, and invoking sanctions against suppliers that fail to improve their performance in line with an action plan provided by us, including the termination of the business relationship.

This Modern Slavery and Human Trafficking Statement will be regularly reviewed and updated as necessary. The board of directors of the Company endorses this policy statement and is fully committed to its implementation.

This Modern Slavery and Human Trafficking Statement has been approved and authorised by the board of the Company.