Modern slavery policy
- Retirement Villages Group Modern Slavery and Human Trafficking Statement – September 2026
Retirement Villages Group is committed to preventing modern slavery, human trafficking, forced labour, servitude and exploitation in our own operations and throughout our supply chain. This policy and statement set out the steps we take to identify, assess, manage and reduce modern slavery risk across our business, our sites and the suppliers who support our residents, colleagues and communities.
This statement is published in line with section 54 of the Modern Slavery Act 2015 and reflects current UK Government guidance on transparency in supply chains. It is intended to provide clear, practical and transparent disclosure on the actions we take, the controls we operate and the improvements we will continue to make. - About Retirement Villages Group
We operate retirement villages across the UK, providing homes, services and support for older people who want an active, rewarding and purposeful life connected to thriving local communities. Our operations are supported by a broad supplier base including facilities management, care and wellbeing services, construction and maintenance, food and hospitality, waste management, cleaning, technology, professional services and other operational suppliers. - Our commitment to the principles of the Modern Slavery Act 2015
We have a zero-tolerance approach to modern slavery and human trafficking. We expect the same standard from our employees, agency workers, contractors, suppliers and business partners. We will not knowingly work with any organisation involved in slavery, servitude, forced or compulsory labour, child labour, human trafficking, worker exploitation, deceptive recruitment practices or the withholding of wages, identity documents or freedom of movement.
As an equal opportunities’ employer, we are committed to providing a respectful, safe and non-discriminatory working environment. We encourage colleagues and workers in our supply chain to raise concerns without fear of retaliation, and we will investigate credible concerns promptly, fairly and sensitively.
Our recruitment and people management processes are designed to ensure that all prospective employees have the legal right to work in the UK, are employed voluntarily, are paid in line with applicable wage legislation and are protected from abuse, coercion, intimidation or exploitation.
Where concerns are identified, we will take proportionate action. This may include requiring corrective action plans, enhanced monitoring, suspension of new work, escalation to senior leadership, termination of contractual arrangements and, where appropriate, reporting to relevant authorities or support agencies - Our policies in relation to the Modern Slavery Act 2015
Our approach is supported by policies and procedures made available to colleagues through our staff handbook, procurement processes and supplier onboarding controls. These include:
Relevant policies and controls include our:
- Code of Conduct and standards of ethical behaviour
- Ethical Conduct Policy
- Whistleblowing Policy and reporting channels
- Equal Opportunities, Diversity and Inclusion, and Bullying and Harassment policies
- Recruitment and Selection Policy, including right-to-work checks
- Procurement Policy, supplier onboarding and contract approval processes
- Supplier Code of Conduct and contractual compliance requirements - Due diligence and supplier onboarding
Risk-based supplier onboarding checks, including confirmation of legal trading status, insurance, relevant accreditations and acceptance of our supplier standards.
Modern slavery declarations or equivalent assurance requirements for suppliers in higher-risk categories or where contract value, labour intensity or service criticality justifies enhanced review.
Contract clauses requiring suppliers to comply with the Modern Slavery Act 2015, maintain adequate policies and procedures, cascade equivalent obligations through their own supply chains and notify us of any actual or suspected modern slavery issue.
Enhanced scrutiny for higher-risk sectors, including labour-intensive services, temporary labour, cleaning, facilities management, care-related services, construction, maintenance, hospitality, laundry, waste and logistics.
Ongoing supplier management through contract reviews, service meetings, issue logs, corrective action plans and escalation routes where concerns or control gaps are identified.
A requirement that procurement decisions consider ethical, legal, operational and reputational risk, not cost alone - Risk Assessment and management
We recognise that modern slavery risk can exist in any supply chain, particularly where work is low paid, outsourced, seasonal, geographically dispersed, subcontracted or reliant on migrant or temporary labour. We will continue to assess risk by considering supplier category, country of operation, workforce model, subcontracting arrangements, contract value, operational dependency and any concerns raised through audits, site feedback, complaints or whistleblowing channels.
Where a supplier or category is assessed as higher risk, we may require additional evidence such as modern slavery statements, workforce policies, recruitment practices, right-to-work controls, subcontractor oversight, training records, audit outcomes or corrective action plans. Failure to provide adequate assurance may affect supplier approval, renewal or continued engagement - Training and awareness
We will provide proportionate modern slavery awareness and guidance to colleagues involved in procurement, recruitment, contract management, supplier onboarding and site operations. Training will help colleagues recognise potential indicators of exploitation, understand escalation routes and apply procurement controls consistently. - Reporting concerns and remediation
Colleagues, workers, suppliers and third parties are encouraged to report any concern relating to modern slavery, human trafficking or worker exploitation. Concerns may be raised through line management, Procurement, People, Legal, senior leadership or the whistleblowing process. We will assess concerns promptly and, where people may be at risk of harm, prioritise safeguarding, specialist support and appropriate escalation.
Our response will be proportionate to the circumstances and may include supplier engagement, root cause review, corrective action plans, contract suspension, termination, notification to authorities or referral to specialist support services. We will seek to avoid actions that may worsen harm to affected workers - Monitoring effectiveness
We will monitor the effectiveness of our approach using practical indicators such as completion of supplier onboarding checks, inclusion of modern slavery clauses in relevant contracts, completion of training by targeted colleagues, review of high-risk supplier categories, number and nature of concerns raised, resolution of corrective action plans and progress against annual procurement compliance activity. - Our supply chain
We expect suppliers to operate ethically, comply with all applicable labour, employment and human rights laws, maintain effective controls to prevent modern slavery and ensure
equivalent standards are applied to their subcontractors and supply chains. Suppliers must notify us immediately if they become aware of any actual or suspected modern slavery issue connected to the services or goods they provide to us. - Continuous improvement priorities for 2026/2027
- Strengthen supplier onboarding questions and evidence requirements for higher-risk categories.
- Improve visibility of key suppliers and subcontracting arrangements in labour-intensive service areas.
- Increase awareness among procurement, site and contract management colleagues.
- Embed modern slavery risk considerations into supplier reviews, contract renewals and procurement decision-making.
- Track agreed actions and improvements through procurement compliance monitoring - Approval and Review
This policy and statement will be reviewed annually and updated where required to reflect changes in legislation, government guidance, business operations, supply chain risk and RVG’s internal control framework. This Modern Slavery Policy and Statement has been reviewed by the Executive Board and approved by the Board of Directors of the relevant reporting entity for publication on behalf of Retirement Villages Group.
Signed:
Tim Seddon
Chief Executive Officer
For and on behalf of Retirement Villages
