The Dandara Group, founded in 1987 includes a property development and management portfolio that spans the residential and commercial sectors, across the for sale and rental markets. In the years since the company began, we have developed and delivered thousands of homes and won numerous industry awards. We operate in the Isle of Man, Jersey and across the UK. Our workforce is made up of permanent and temporary, office and site-based roles employed both directly by the companies within The Dandara Group and via our supply chain partners.

The Dandara Group directly employs approximately 1,000 people within the Dandara Group. In addition, we use the services of Labour Supply Agencies to supply labour, trades and logistics and site services personnel as required across our sites. Furthermore, we have a diverse sub-contractor labour force, supporting over hundreds of sub-contractor companies across our divisions, including groundworkers, housebuilding trades and security personnel.

Due to a range of different contracts that those working with and for us are on, we work with our supply chain partners to ensure that our due diligence extends beyond the first tier of the recruitment process. We apply appropriate employment practices and policies for each jurisdiction we work in and uphold high quality labour standards across the Group.

The following Statement sets out the steps we have taken so far in our FY24 and what we plan to do during 2024 - 2025 to advance our objectives around preventing modern slavery and human trafficking. It has been reviewed and approved by Steven Hannah, Director.

The Dandara Group of companies have developed a suite of policies, procedures and commitments that support and respond to our compliance and governance requirements. These include but are not limited to the Dandara Housebuilding Governance Statement or Dandara Living Sustainable Procurement Policy . Where appropriate, these are signed by the appropriate member of the executive team and available on the relevant website(s) or by request. This Modern Slavery Statement forms part of this suite of documents.

Our Commitments outline the expected compliance requirements for workers’ welfare and conditions of employment and are reviewed annually. Our onboarding and procurement processes are aligned with these commitments and thus our supply chain partners are required to abide by this suite of documents as appropriate within each jurisdiction.

Within the Dandara Group, due diligence by key departments is carried out to prevent modern slavery & human trafficking. Different departments across the business have varying responsibilities in relation to prevention of modern slavery risk. Individuals from Human Resources (HR), Health, Safety & Environment (HSE), Compliance, Commercial, Construction, Procurement, Legal and Environmental Social & Governance (ESG) are responsible for reviewing our current approach to preventing modern slavery within the Dandara Group.

Recruitment & Labour Supply

The Human Resources (HR) and Recruitment team play a critical role in combatting modern slavery by implementing and monitoring practices that reduce the risk of exploitation. Common modern slavery checks conducted by the HR & Recruitment team at Dandara include:

• Upfront due diligence - at the very start of the recruitment process including “right to work checks” and verification of personal documents to prevent illegal recruitment practices.
• Ensure that contracts clearly outline job roles, pay, working hours, and entitlements.
• Highlight red flags, such as shared addresses, bank accounts, or irregular documentation.
• Check housing conditions for compliance with health, safety, and dignity standards (Jersey / Isle of Man).
• Worker Engagement – educating colleagues on rights and providing information about grievance mechanisms and whistleblowing policies.

In relation to the recruitment of site / short term workers, in general, the Dandara Group work with several labour supply agencies. We require our labour supply agencies to ensure that staff: are legally able to work within the jurisdictions where we operate; have written employment contracts; and have not had to pay for the opportunity to work. Some of the labour supply agencies we utilise subject employees to checks to ensure they are genuine applicants including verification checks. Other agencies also operate a supplier / subcontractor verification process which as well as the normal checks also include due diligence and a review of the controls undertaken by the supplier / subcontractor. In the Isle of Man and Jersey, these checks are carried out by our in-house team.

Construction site personnel are required to carry up to date Construction Skills Certification Scheme (CSCS) Card in the UK. Workers in Jersey are required to complete the required Jersey Safety Awareness Training (JSAT). As well as helping to demonstrate a level of competence amongst personnel to safely perform a specific job, these cards help confirm identity and right to work status. Once on site, personnel undergo a Site Induction, which includes a section on Modern Slavery including how to report concerns.

In September 2024, Dandara Housebuilding division appointed a Recruitment Process Outsourcing (RPO) organisation. As part of their scope of work, the RPO will provide an independent compliance audit service to help ensure compliance across our recruitment supply chain / labour supply agencies. The RPO will work with our labour supply agencies during FY25 to assist in the reduction of modern slavery risk on an ongoing basis with reviews / audits carried out every 6 months.

Procurement

Since 2023 we require that the labour supply agencies complete a Pre-Qualification Process (PQQ) which incorporates specific due diligence queries on modern slavery. Throughout the UK, our sub-contractors must also go through the PQQ Process and need to respond directly to questions on preventing of modern Slavery.

During FY24 we conducted specific audits of the labour supply agencies and recruitment companies that we work with. The purpose of these audits was to ensure that agencies carry out their own robust checks in relation to reducing the risks associated with modern slavery. The findings from these audits can be seen in the Risk Management & Mitigation section below.

The Dandara Group spends a significant proportion of revenue within our supply chain, through the procurement of goods and or services from our supply chain partners. Our supply chain is an integral part of our operations, and our success and reputation are linked to their performance and ethics. Our supply chain partners range from large global companies to small and medium businesses and social enterprises. The Dandara Group has developed strong, long-term relationships with many of these partners.

We understand that construction is a high-risk sector in relation to modern slavery due to complex supply chains and labour practices and we are committed to preventing slavery and human trafficking within our activities and those of our supply chain.

For our construction sites, our onsite suppliers are required to go through the PQQ Process which aims to reduce the risk of modern slavery occurring on our sites. Volume suppliers (paper, sundries, consumables, cleaning products suppliers etc) are currently being reviewed with the aim of being included in a future version of the PQQ process.

This Statement is published on our website(s) and will be issued in electronic format to suppliers as part of the onboarding process of new suppliers.

Training and Awareness

All new direct employees that are office and site-based will attend an induction event where the topic of modern slavery is covered along with the response requirements should anyone suspect modern slavery. Existing staff have been recently mandated to complete a modern slavery e-learning module that will enable them to:

• increase awareness of how people become vulnerable
• inform participants how to spot the signs of modern slavery and
• give participant guidance on what to do in a suspected case of modern slavery.

All sub-contractors and site personnel must go through a site induction process before working on our sites. This site induction includes the topic of modern slavery and attendees must sign that they have understood the process relating to modern slavery and human trafficking.

The HSE Team include a module on Modern Slavery as part of their Toolbox Talks series and the HSE team include Modern Slavery Information Bulletins as part of their updates to sites. The ESG team also commenced a series of ESG related presentations for site-based teams which incorporate modern slavery risks and reporting requirements.

We know that key activities, such as the procurement of materials, and the use of subcontractors and labour agencies, increase the risk of modern slavery occurring within the construction industry. To mitigate this risk, we inform stakeholders that, The Dandara Group have a zero-tolerance approach to modern slavery and will not work with supply chain partners or source materials from those who do not make efforts to reduce modern slavery risks associated with their own business and supply chain. In addition, we ensure that risks of modern slavery are covered within our PQQ and Onboarding processes. Appointment of a RPO will also help ensure a more comprehensive approach to due diligence and risk mitigation across different labour supply agencies.

The following table outlines the identified risks of FY23 and what we did in FY24 to manage and mitigate these risks.

We have evaluated and understand the risks of modern slavery within The Dandara Group and within our supply chain. However, we understand the need to continue to review our processes and procedures and those of our supply chain and on our sites on a regular basis to enable us to better spot the signs of exploitation.

We set KPIs on modern slavery and each year, as part of our continuous improvement attempts, we will review and edit or add new KPIs as necessary.

There are several ways we encourage those who work with and for us to raise their concerns, based on the level of seriousness. These have been communicated to our colleagues via our intranet and information bulletins across sites within The Dandara Group.

The process includes:

• Immediate safeguarding concerns should be reported to the police on 999.
• Where modern slavery is suspected but there are no immediate safeguarding concerns, parties should report via the whistleblowing phone number or email address. (Specific contact details have been provided on the intranet & information bulletin).

Alternatively, concerns can be reported to the Gangmasters and Labour Abuse Authority via 0800 432 0804 .

This statement is made and published in accordance with Section 54 of the UK Modern Slavery Act 2015 and constitutes The Dandara Group’s Modern Slavery and Human Trafficking Statement for the financial year ending June 2024. The content was agreed by teams across the business and will be reviewed and updated annually.

Steven Hannah
Finance Director

17 December 2024

• Modern Slavery Statement 22-23