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Company Name: Hansteen Holdings PLC

Place of Registration: England and Wales

Registered Number: 05605371

Registered Office Address:

1st Floor, Pegasus House,
37-43 Sackville Street
London W1S 3DL

Telephone: +44 (0)207 408 7000
Fax: +44 (0)207 408 7001

VAT number 872 5613 11

Regional offices

Modern Slavery Act Disclosure

Slavery and Human Trafficking Statement


This slavery and human trafficking statement is made by Hansteen Holdings plc ("Hansteen" or the "Company") pursuant to section 54(1) of the Modern Slavery Act 2015 and relates to the Company and its subsidiaries in respect of the financial year ended 31 December 2016. This statement sets out the measures that Hansteen has taken to address the risk of slavery and human trafficking taking place in our business and within our supply chain through 31 December 2016.

Our Position on Human Rights

The principle of respect is one of Hansteen’s key tenets and this includes respect for human rights, including the right to be free from slavery and servitude. Hansteen’s Human Rights Policy recognises and seeks to safeguard the human rights of those the Company has contact with and responsibility for in the business areas in which we operate. We support the principles set out in the United Nations' Universal Declaration of Human Rights and the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. Our Human Rights Policy is built on these foundations, and supports the principles of equal opportunity, collective bargaining, freedom of association and protection from forced adult or child labour. The Policy is being extended to embrace the specific concerns of the Modern Slavery Act 2015.

Hansteen is committed to act with integrity and this is central to the way we do business and crucial to our external credibility and reputation in the market place. As a business operating in the property investment market in the UK, Germany, the Netherlands, France and Belgium, Hansteen’s exposure to human rights risks, including modern forms of slavery, is limited. One area of vigilance is unpaid labour. Hansteen is specifically committed to ensuring there is no unpaid labour of any kind, both in our own business and in our supply chain.

Our Employee Handbook sets our expectation that our employees will maintain high standards when it comes to ethical business conduct and requires that our relationships with competitors, suppliers and clients must be based on high standards of personal and professional ethics. All of our employees have an important role to play in the management of risk and this includes being alert to the risk of slavery, forced labour and human trafficking in our business and in the wider supply chain.

Our People

We believe that the risk of any slavery or human trafficking in the employment or engagement of our own employees is low. Hansteen operates a robust recruitment and engagement programme and we have provided guidance and training to our employees with hiring and procurement responsibilities to support our expectations and legal obligations in respect of equal opportunities and fair labour practices. We also have in place a range of supporting employment policies, processes, procedures and guidelines which reflect current legislation and best practice and which are targeted at safeguarding the interests of employees and potential employees and other people (such as contractors) who work for our business. These include policies addressing: Diversity and Inclusion, Equal Opportunities, and Dignity at Work.

Our Supply Chain

We manage our business through our experienced regional teams working with trusted suppliers. The Hansteen philosophy is to develop long-term partnerships with suppliers whose policies, values and cultures, including respect and integrity, are complementary to our own.

Hansteen expects its suppliers to reflect our standards, including paying a fair wage to their workers, respecting Human Rights, meeting their obligations under employment legislation and investigating their own supply chains for slavery and human trafficking issues and risks.


Any employee or any person engaged in our supply chain who has any concerns with our organisation or our supply chain may and is expected to raise their concerns directly with the Director of Operations or by making a report in accordance with the Hansteen’s Whistleblowing Policy to the Designated Whistleblowing Officer. All such reports will be investigated by the relevant person.

This Statement was approved by the Board on 19 March 2017