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Modern Slavery and Human Trafficking Statement
The concept of “modern slavery” encompasses behaviours such as forced, compulsory or coerced labour, deprivation of personal freedom or facilitating the movement of people for exploitation. In accordance with section 54 (1) of the Modern Slavery Act 2015 (the “Act”), M7 Real Estate Ltd (“M7RE”), and its subsidiaries, collectively (the “M7 Real Estate Group” or “M7 Group” or “M7”), denounces and is committed to combatting slavery in all forms, and will take the necessary steps to ensure that such activities are not found within our businesses or supply chains.
M7RE is a private limited company, incorporated in England and Wales, and is the parent company of the M7 Real Estate Group. M7 Real Estate Financial Services Ltd (“M7FS”), a wholly owned subsidiary of M7RE, is regulated by the Financial Conduct Authority and has been established to conduct regulated investment activities within the M7 Group. M7 has offices in the United Kingdom, Croatia, Denmark, Dubai, France, Germany, Hungary, Ireland, Luxembourg, Poland, Portugal, Spain, Netherlands, and Hong Kong.
Services and Supply
M7 is one of Europe’s leading real estate investment fund managers and as of this statement’s date manages c. €6.9 billion assets under 44 operating mandates.
The services M7 utilises itself are office based and its supply chain consists mainly of other regulated professional services (Chartered Surveyors, Law Firms, Accountancy Firms and Banks). M7 further procures goods and services in the following areas: technology, commercial real estate, facilities, cleaning, security, business travel, delivery and courier service, printing, and the hiring of temporary contractors and agency workers.
M7 considers these to be very low risk in relation to slavery and human trafficking so takes no specific action beyond what would be considered appropriate due diligence for the size and nature of the M7 business in respect to these relationships. Given that our business is the provision of professional services, the risk of Modern Slavery within our business generally or our supply chain is low but we are conscious that Modern Slavery occurs in different forms throughout the world (including the UK).
The majority of other services supplied to or on behalf of M7 are from the real estate industry in the UK and across Europe. Given the extremely low risk profile of anyone supplying us with services being involved in slavery and/or human trafficking, we believe that our current procedures and ability to rely on regulatory oversight in relation to professional services are sufficient. These procedures remain under constant review.
Firm and Staff Manuals
M7’s Employment Manual and Compliance Manual clearly sets out the firm’s expectation for employees to conduct business honestly and with integrity within their individual business units, and when engaging in business with any firm affiliates or third-party goods and/or service providers. Employees are expected to report anything which contravenes this standard and are directed to report any concerns through the firm’s whistleblowing process.
An M7 whistleblowing process has been established to allow for anonymous reports to be to be made to M7’s whistleblowing champion, M7’s Head of Compliance, or a member of M7’s Legal Team in their absence. It is Head of Compliance’s responsibility to investigate and report violations to the relevant authority. Staff may also report to the Financial Conduct Authority or the whistleblowing charity Protect
To promote and encourage ethical behaviour M7 has established a zero-tolerance approach to any form of bribery and corruption, and has committed to acting professionally, fairly, and with integrity in all its business dealings and relationships wherever it operates. M7 undertakes an appropriate level of due diligence on third-parties in determining potential compliance risks.
The majority of goods supplied to M7 are for use in an office environment. Given the low risk profile of suppliers of such goods, no specific training is provided or undertaken by M7 staff in relation to these matters.
Training of Staff
M7 aims to raise awareness of the Act by providing employees and management with training on a range of compliance matters including their obligations and responsibilities under the Act, particularly in relation to mitigating risks within supply chains where possible.
In the ongoing course of our business M7 commits to undertaking the following actions to mitigate any risk within its own business or associated when selecting or engaging in business with suppliers or contractors:
- Continual promotion of topic awareness and understanding amongst all M7 staff.
- Review of any published statements of suppliers or contractors, or any policies establishing ethical obligations.
- Implementing contractual clauses in supplier contracts forbidding the use of any form of slavery and human trafficking.
- Reviewing M7 policies and procedures established to uphold firm standards and ensure that obligations that arise from these are clearly communicated to and understood by the appropriate individuals.
- Regular review of M7 supplier base.