Modern Slavery Act

Roost Topco Limited issues this statement in accordance with Section 54(1) of the Modern Slavery Act 2015. This is a group statement that covers all subsidiary entities (collectively referred to as “Student Roost”) for the financial year ending on 31 December 2024.

At Student Roost, we have a zero-tolerance approach to modern slavery and human trafficking. We remain committed to understanding and mitigating the risks within our operations and supply chains. Our policies, due diligence processes, and continuous improvements reflect our responsibility to prevent modern slavery in all its forms.

In 2024, challenges such as the cost-of-living crisis, inflation, and energy security concerns increased the risk of modern slavery. Acknowledging the critical need for prevention, we remain committed to eliminating any potential instances of modern slavery or human trafficking within our operations. Our approach is rooted in continuous improvement across all areas of our business, with a steadfast dedication to eradicating slavery in all its forms.

Outlined below are the steps we have taken, and are undertaking, to prevent modern slavery within our group and supply chain.

OUR BUSINESS OPERATIONS AND STRUCTURE

Student Roost is a leading provider of purpose-built student accommodation in the United Kingdom, and is headquartered in Birmingham.

Student Roost is recognised for its award-winning student accommodations, offering well-designed facilities that provide a comfortable home for students. Since its establishment in 2017, the company has expanded significantly, now operating in 22 locations across the UK with over 20,000 beds. This growth has been driven by strong partnerships with third-party entities, collaborations with universities, and relationships with national and international agents who assist students in securing accommodation in the UK.

Utilising its asset management and regeneration expertise, Student Roost enhances the property portfolio, leveraging its human capital, relationships, and financial resources to drive value creation and income growth. Core activities encompass two primary areas: managing the property portfolio's occupational leases and fostering relationships with occupants to sustain and enhance income; and the development, refurbishment, and acquisition of properties with future regeneration potential, alongside divesting those with limited prospects to deliver superior long-term returns.

In the execution of its business operations, Student Roost engages a range of external suppliers, including:

1.  Property management suppliers and maintenance contractors.
2.  Professional advisors e.g. lawyers, accountants, valuers, agents, auditors, and design professionals.
3. Building contractors within the construction industry.

Student Roost is persistent in its commitment to conducting business ethically and with integrity, continuously improving practices to identify and address the risks of modern slavery and human trafficking. The company actively promotes measures to ensure such practices are absent within its operations and supply chain.

OUR POLICIES

We understand the role our business has in addressing modern slavery and playing our part in identifying and preventing risks. We have remained focused on responding to and addressing the subject with respect to our business operations, our employees, and our supply chain.
As part of our commitment to eliminate modern slavery and human trafficking, we have the following policies to assist in making clear our expectations:

•  Anti-slavery and Human Trafficking Policy – this makes our employees aware of their responsibilities in relation to modern slavery and human trafficking and outlines the process for reporting concerns or suspicions that modern slavery or human trafficking is taking place
• Whistleblowing Policy – encourages staff to raise any issues or concerns in confidence and provides protection for qualifying disclosures.
•  Equal Opportunity Policy – this makes clear that we will always seek to avoid unlawful discrimination in any aspect of the employment of our staff and embrace the principles of equality and diversity.
• Anti-Bribery and Corruption Policy - explains that it is unacceptable for anyone connected to Student Roost to pay or receive a bribe, or otherwise engage in corrupt practices.
•  Code of Conduct – makes clear our expectation that all employees conduct business in a manner consistent with the highest ethical, professional, and legal standards, and outlines the process for reporting issues or concerns when they arise.
• Respecting People Policy – stipulates that we will not tolerate any form of bullying or harassment inside the business or when dealing with third parties and highlights our commitment to creating a working environment where everyone is treated with dignity and respect.
• Grievance Policy – provides a formal route to raising and resolving complaints about Student Roost or other employees.
• Procurement Policy - sets out that promoting zero tolerance of modern slavery in our business and supply chain is one of Student Roost’s key supplier conditions encouraging transparency in our supply chains, along with ethical business practices and anti-bribery and corruption.

OUR PEOPLE
Our workforce comprises c.660 employees who, alongside our supply chain, oversee the management of our property portfolio and developments. They cultivate robust relationships with occupants, third-party professionals, our supply chain, and local communities. All our direct employees are UK-based and employed, predominantly site and office-based. Each member of the Student Roost team receives remuneration exceeding the minimum wage.

Our employees embody our values and play a pivotal role in delivering personalised service to our customers. As an employer, we acknowledge the importance of reflecting diversity within our workforce to effectively cater to a varied population. One of our core values, "You, do You," underscores our commitment to recruiting individuals with distinct characters and diverse backgrounds.

This vision is fortified by our core values:

• Commit to Growth: Encouraging our team members to be themselves, fostering personal and professional growth, and challenging conventions while respecting others.
• Play to Win: Emphasising success through contribution rather than merely tracking hours worked, ensuring a work environment that is both competitive and enjoyable.
• Do the Right Thing: Upholding integrity, even in the absence of supervision, and promoting a culture where individuals feel empowered to voice concerns and strive for continuous improvement while prioritising safety, legality, and compliance.

Through the diligent execution of these values, we strive to cultivate a workplace culture where our employees feel valued and take pride in their association with us.

We promote a culture of openness within our business so that employees can report any concerns, with confidence that they will be treated seriously and with respect. Our employees are required to read, understand and comply with our Anti-Slavery and Human Trafficking Policy. Our employees are encouraged to raise any concerns or report a suspected breach of the Anti-Slavery and Human Trafficking Policy using through a variety of communication channels, including speaking to their line manager or a member of the Legal team or a member of the People team or reporting via our whistleblowing hotline.

Based on our continuous risk assessments and existing measures, we remain confident that there is no modern slavery or human trafficking occurring within our workforce.

ASSESSING MODERN SLAVERY RISKS IN OUR SUPPLY CHAIN

Our supply chain predominantly consists of UK-based suppliers, including construction and specialised contractors involved in property development and refurbishment. Additionally, we engage broader service providers for facilities and property management, encompassing preventative and reactive maintenance, utilities, health and safety, cleaning, and laundry, as well as suppliers of goods such as furniture and electricals, white goods, office supplies. We have minimal contact with countries that are generally considered to have a risk of modern slavery.

We've adopted a risk-based approach to evaluate our supply chain, pinpointing areas where modern slavery or human trafficking may occur. Our assessment highlights potential higher risks within the supply chains of our construction contractors and property management service providers, particularly those involved in cleaning and security services and such services are assessed proportionally to mitigate the increased level of risk.

Our Procurement Department has identified certain supplier categories where a heightened risk of modern slavery is perceived. These types of business tend to pay lower wages and rely on labour from outside the country to undertake their business. We manage this risk through our supplier selection and onboarding processes.
 

•  Cleaning;
•  Security;
• Sub-contractors for construction activities;
• Grounds Maintenance services;
• Overseas companies supplying outsourced business processing services; and
• Products typically manufactured in developing countries, such as furniture or textiles.

At Student Roost we recognise the importance of addressing modern slavery and human trafficking issues transparently within our supply chain. Our procurement team drives open and transparent supplier engagement, ensuring that new suppliers demonstrate compliance with our business standards and ethical working practices. Our onboarding process includes the supplier completing a questionnaire and due diligence on their reputation, compliance with health & safety standards and the risk of modern slavery in their supply chain. We strictly refrain from engaging with suppliers who do not comply with the Modern Slavery Act 2015, and clauses pertaining to modern slavery prevention are integral parts of all our supplier contracts.

To bolster awareness and understanding of modern slavery risks, our comprehensive training program mandates all employees to undergo training on this subject. This ensures that every team member is equipped with the knowledge to identify signs of modern slavery or human trafficking and knows the appropriate channels for reporting concerns.

Our commitment to maintaining ethical standards and fulfilling our obligations under modern slavery and human trafficking legislation is paramount to us, our customers, and stakeholders. We continuously monitor our practices as part of our broader commitment to being a responsible and sustainable business.

To proactively identify and mitigate risks within our supply chain, we have implemented systems to:
 

• Identify, assess, and continuously monitor potential risk areas within our supply chains.
• Implement measures to mitigate the risk of human trafficking occurring within our supply chains.
• Cultivate long-term relationships with UK-based suppliers and contractors to enhance our customer offerings and integration.
• Safeguard whistleblowers and encourage the reporting of concerns.

We regularly review our risk assessment processes and monitor our activities as part of our broader commitment to ensuring sustainability and responsible business practices.

Based on our ongoing procedures and measures, we maintain our belief that the risk of modern slavery or human trafficking within our supply chain remains low.

OUR TRAINING
We offer comprehensive training to our employees covering various topics, including whistleblowing, our organisational values, health and safety protocols, fire security measures, inclusion and diversity practices, anti-bribery and corruption guidelines, and well-being initiatives. Additionally, we provide specialised training for employees who work remotely to ensure they can fulfil their roles safely and efficiently outside of the office environment.

Furthermore, all employees are required to undergo recertification at least annually in key areas such as anti-bribery and corruption. We ensure visibility of our whistleblowing policy by displaying informative posters at each of our properties and our head office.

OUR EFFECTIVENESS IN COMBATTING SLAVERY AND HUMAN TRAFFICKING

We use the following key performance indicators (KPIs) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

•  Number of cases of modern slavery discovered in our supply chains as a result of the procurement team’s due diligence work: 0
• Cases reported through our whistleblowing hotline where reporters have specifically alleged a breach of the Modern Slavery Act 2015: 0

OUR FUTURE PLANS

Despite the progress made in the current financial year, we recognise our ongoing responsibility to combat modern slavery and human trafficking. We remain committed to continuously improving our systems, processes, and policies to mitigate these risks within our business and supply chains.
To strengthen our approach, we will frequently review supplier onboarding processes to ensure they remain proportionate and fit for purpose. Category Management activity will identify areas of high risk, which will be monitored accordingly. Additionally, future tendering requirements will assess whether mandatory pass/fail criteria are necessary.

As part of our commitment, we plan to update the supplier onboarding questionnaire to incorporate extended due diligence checks on potential suppliers. These checks will cover Equality and Diversity, activities in countries where trade sanctions may apply, sustainability standards, and bribery and corruption policies.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Student Roost group’s slavery and human trafficking statement for the financial year ended 31 December 2024. It was approved by the Board of Directors on 19 June 2025.

Tom Goodwin
Director
Roost Topco Limited