This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 for the financial year ended 31 December 2017.
Structure, business and supply chains
The PBSA Group, trading as Student Roost, owns and operates purpose-built student accommodation across the United Kingdom and is headquartered in Birmingham. We have 45 properties across the UK, providing 16,580 beds to students, with a further 3,858 rooms in development. Student Roost is ultimately owned by Brookfield Asset Management Inc., a global venture capital investor that has its corporate headquarters in Toronto, Canada.
We recognize the need to engage with the issues of modern slavery and human trafficking and drive improvements through transparency. We are committed to ensuring there is no modern slavery in our business and our supply chains.
We procure goods and services from third-party suppliers based within the UK. Student Roost’s third-party suppliers provide a variety of goods and services for the effective running of our business, including professional services, property development and refurbishment and property preventative maintenance services.
Slavery and Human Trafficking Policies
We have a Code of Business Conduct & Ethics and Anti-bribery & Corruption policy that set standards of ethical behaviour. Team members are expected to conduct business in a manner consistent with the highest ethical and professional standards, which includes always acting with honesty and integrity. There are systems in place to encourage team members to report unethical behaviour and suspected breaches of policies, including a confidential whistleblowing hotline.
The business has undergone significant staff and operational changes over the past 18 months and work is in progress to develop and improve the controls environment, which is still immature. This includes developing a specific anti-slavery and human trafficking policy plus a procurement policy and guidelines, including supplier evaluation criteria and a code of conduct outlining the standards and behaviours that we expect of all our suppliers.
Due diligence processes in relation to slavery and human trafficking in our business and supply chains
Student Roost only employs staff within the UK. As part of the recruitment process we check that all prospective employees are legally entitled to work in the UK. Before starting work all new team members are required to produce original identity documents (from the list of acceptable documents issued by the Home Office). The validity of the documents is checked in the presence of the holder, we make and retain a clear copy and record the date the check was made. If a team member only has a temporary right to work in the UK we conduct follow-up checks. Suppliers of agency labour are expected to carry out the same right to work checks.
A supplier vetting process and due diligence checks will be implemented as part of the new procurement policy and guidelines currently being developed. This will help the business assess a potential supplier’s suitability and its compliance with applicable laws, including the Modern Slavery Act.
Identifying, assessing and managing risk
Due to the nature of our business, we assess that there is low risk of slavery and human trafficking in our employee base. Our largest exposure will come from our third-party supply chain.
As stated previously, we are actively developing a procurement policy and guidelines that will improve our supplier processes and practices to deliver a more standardised approach to monitoring and compliance within our supply chain.
Key suppliers will be expected to share the same values as Student Roost and will not be permitted to subcontract work unless authorised in advance. We are developing new terms and conditions of purchase and will ensure they contain a clause confirming our commitment to ensuring slavery and human trafficking is not taking place.
To ensure a sound level of understanding of the risks of modern slavery and human trafficking and its impact upon our business, we are planning to develop training on the subject for senior management and the procurement team.
This statement will be reviewed and published annually.
Chief Executive Officer
24 May 2018