Introduction

Modern slavery is a heinous crime and a morally reprehensible act that deprives a person's liberty
and dignity for another person's gain. It is a real problem for millions of people around the world,
including many in developed countries, who are being kept and exploited in various forms of slavery.
Every company is at risk of being involved in this crime through its own operations and its supply
chain.

At Alby Estates Ltd, we have a zero-tolerance approach to modern slavery and are fully
committed to preventing slavery and human trafficking in our operation and supply chain. We have
taken concrete steps to tackle modern slavery, as outlined in our statement. This statement sets out
the actions that we have taken to understand all potential modern slavery risks related to our
business and to implement steps to prevent slavery and human trafficking during the financial year
2021.
Our business and supply chains

[Brief details of:
• Your company
• Your company’s business activities
• The countries/locations where your company operates]

We establish a relationship of trust and integrity with all our suppliers, which is built upon mutually
beneficial factors. Our supplier selection and on-boarding procedure includes due diligence of the
supplier's reputation, respect for the law, compliance with health, safety and environmental
standards, and references.

[We haven't been made aware of any allegations of human trafficking/slavery activities against any
of our suppliers, but if we were, then we would act immediately against the supplier and report it to
the authorities.]

Risk assessment
In the past year, we conducted a risk assessment of our supply chain by taking into account:
• The risk profile of individual countries based on the Global Slavery Index
• The business services rendered by the suppliers
• The presence of vulnerable demographic groups
• A news analysis and the insights of labour and human rights groups
This assessment will determine our response and the risk controls that we implement.

Policies

Alby Estates Ltd operates the following policies for identifying and preventing slavery and human trafficking
in our operations:
• Whistleblowing Policy - we encourage all employees, customers and suppliers to report any
suspicion of slavery or human trafficking without fear of retaliation. We provide a
confidential helpline to protect the identity of whistle-blowers.
• Code of Conduct - our code encourages employees to do the right thing by clearly stating the
actions and behaviour expected of them when representing the business. We strive to
maintain the highest standards of employee conduct and ethical behaviour when operating
abroad and managing our supply chain.
• Purchasing Code - we have updated our Purchasing Code and supplier contracts to make
explicit reference to slavery and human trafficking.

Supplier due diligence

Alby Estates Ltd conducts due diligence on all new suppliers during on-boarding and on existing
suppliers at regular intervals.

This includes:
• Assessing risks in the provision of particular services
• Auditing the suppliers, and their health and safety standards, labour relations and employee
contracts
• Requiring improvements to substandard employment practices
• Sanctioning suppliers that fail to improve their performance in line with our requirements
We require all suppliers to attest that:
• They don't use any form of forced, compulsory or slave labour
• Their employees work voluntarily and are entitled to leave work
• They provide each employee with an employment contract that contains a reasonable notice
period for terminating their employment
• They don't require employees to post a deposit/bond and don't withhold their salaries for
any reasons
• They don't require employees to surrender their passports or work permits as a condition of
employment
Awareness
Alby Estates Ltd has raised awareness of modern slavery issues by putting up posters across our
facilities and sending an email that is focused specifically on modern slavery to all our staff, which
explains:
• Our commitment in the fight against modern slavery
• Red flags for potential cases of slavery or human trafficking
• How employees should report suspicions of modern slavery

This statement covers 1 April 2020 to 31 March 2021 and has been approved by the board of
Alby Estates Ltd.