Modern Slavery Policy

Eco World-Ballymore Holding Company Limited
Modern Slavery and Human Trafficking Statement

This Statement applies to Eco World- Ballymore Holding Company Limited and its subsidiaries (the “Company”, “EcoWorld Ballymore”) and is intended to be read alongside our Modern Slavery Policy.

At EcoWorld Ballymore we recognise that slavery and human trafficking are significant human rights issues and are committed to taking appropriate and proportionate steps to mitigate the risk of these occurring within our business and our supply chain.

As a property developer operating within the UK, the key areas of our operation that could be affected by slavery and human trafficking are our directly hired employees, agency workers working on our behalf, contractors, subcontractor operatives working on our sites, and the workforce of our supply chain who supply materials to our business. The steps that we take to mitigate risks in relation to each of these areas are as follows:

Contractors and Subcontractors:

  • We require Contractors and Subcontractors to ensure their employees have the right to work in the UK.
  • We consider Contractor’s and Sub-contractors’ approaches to employee rights and any breaches of human rights related legislation during our selection process.
  • We ask all site operatives to provide evidence of their CSCS cards.
  • We want all Contractors and Sub-contractors that purchase materials for use on our sites to consider the risk of modern slavery in their supply chain.


  • We procure the majority of our directly sourced materials from UK based organisations that are required to comply with UK laws on forced labour. Where materials are directly sourced from outside of the UK we consider the risk of slavery and human trafficking as part of our selection process.


  • Our whistleblowing procedure allows any employee or third party to confidentially raise a concern.

Internal Auditing

  • Our internal risk review process means that we are collectively and continually monitoring our supply chain and ensuring the effectiveness of our approach.
  • As a business we engage staff at the appropriate stages to ensure our approach is consistent and actively enforced.

This statement will be reviewed and updated as necessary. Accountability for compliance with this statement rests with the Board of EcoWorld Ballymore.

Eco World-Ballymore Holding Company Limited
Modern Slavery Policy

Modern slavery is an international crime and a violation of fundamental human rights. It is a global problem that transcends age, gender and ethnicities. It may take various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. It permeates many aspects of the legitimate economy, including our property development sector whereby our supply chain’s industry, notably the construction industry, is one of the many industries in the UK targeted by traffickers and illegal/unlicensed gangmasters.

The Modern Slavery Act 2015 (the “Act”) was introduced in the UK in October 2015 with the aim of stamping out slavery and trafficking and created a number of new criminal offences. It also increased penalties and strengthened the powers of the police and border forces. The Act also contains a number of measures intended to encourage businesses to take steps to address modern slavery. In particular, commercial organisations supplying goods or services with a total turnover of £36 million or more must now comply with disclosure requirements.

The purpose of this policy is to provide information and guidance on how Eco World- Ballymore Holding Company Limited and its subsidiaries (the “Company”, “EcoWorld Ballymore”) deals with modern slavery and the role that all individuals involved with our business must play in ensuring compliance with the Act.

Our Policy Statement

EcoWorld Ballymore takes a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Act. We expect the same high standards from all of our contractors, sub-contractors, consultants, suppliers, service providers, joint venture partners and other agents, third-party representatives and business partners, and expect our supply chain to impose the same standards on their own supply chain. We therefore require this policy to be included in our supply chain contracts and appointments, and to be complied with.

Policy Application

This policy applies to all persons working for EcoWorld Ballymore or on our behalf in any capacity and within any part of our business, including Personnel at all levels, employees, directors, officers, committee members, agency workers, seconded workers, volunteers and our supply chain including all contractors, sub-contractors, consultants, suppliers, service providers, joint venture partners and any other agents, third-party representatives and business partners, (together “Personnel”).

This Policy is overseen by the Board of Directors of the Company and implemented by the relevant Development Manager (‘DM’) for each of our sites.

Compliance with this Policy

All Personnel must read, understand and comply in all respects with this policy. Any activity which could lead to or suggest a breach of this policy is strictly prohibited. It is the responsibility for all those that either work for or with EcoWorld Ballymore to ensure the prevention, detection and immediate reporting of any possible breaches of this policy.

All our Personnel are encouraged to raise any concerns about any issue or suspicion of modern slavery at the earliest possible stage. EcoWorld Ballymore encourages openness and transparency and any person that raises a genuine concern in good faith under this policy will be supported by the business, even if they turn out to be mistaken. We will investigate all genuine concerns which are raised in connection with this policy and our Personnel are encouraged to act without any fear of reprisal. If our Personnel believe or suspect that there has been a breach of this policy, or a breach may occur in the future, they must report their concerns as soon as possible, with reference to the Reporting Concerns section of the Code of Conduct and Business Ethics available on EcoWorld Ballymore’s website.

EcoWorld Ballymore will do everything it can to protect confidentiality if this has been requested by its Personnel. However, Personnel are discouraged from making any disclosures anonymously, as this can limit the investigation process.

Following an internal investigation, EcoWorld Ballymore may decide to alert the police.


We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith any suspicion they might have. If any Personnel consider that they have suffered any such treatment, then they should refer to the Reporting Concerns section of the Code of Conduct and Business Ethics, available on EcoWorld Ballymore’s website.

Communication and awareness of this policy

EcoWorld Ballymore recognises its statutory obligations in connection with the Act and is taking appropriate steps to ensure that modern slavery does not take place within our business and our supply chains. However, we recognise that we do not control the conduct of individuals and organisations in our supply chains. We will take the following measures to ensure compliance, so far as we are reasonably able, to prevent modern slavery from occurring:

  • We will communicate this policy to all our Personnel focusing on the risk EcoWorld Ballymore‘s business faces from modern slavery in its supply chains.
  • We will make known EcoWorld Ballymore’s zero-tolerance approach to modern slavery and this policy to all contractors, sub-contractors, consultants, suppliers, service providers, joint venture partners and any other agents, third-party representatives and business partners at the outset of our business relationship with them and as appropriate thereafter.
  • We will introduce contractual provisions for all our suppliers to confirm their adherence to this policy and accept our right to audit their activities and (where practicable) relationships, both routinely and at times of reasonable suspicion.
  • We will include in the directors’ report accompanying our annual financial statements a reference to the Company’s Modern Slavery and Human Trafficking Statement, which can be found here.
  • As part of our commitment to this issue we are engaged in a process of ongoing due diligence which involves reviewing all existing and novated contracts to ensure that all contractual terms are drafted and if necessary amended to ensure compliance with company policy.
  • We will review this policy annually and update it where necessary.

Breaches of this Policy

Any Personnel found to be in breach of this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

Any claims or allegations which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

We may terminate our relationship with other individuals and organisations working on our behalf if they are found to be in breach of this policy.

Supply Chain and Third Party Compliance with this Policy

Those who are accessing this policy because they are either seeking to have or already have a business relationship with EcoWorld Ballymore are advised to familiarise themselves with this policy and should refer any questions or comments by email to or by phone on +44 1534 676 006 or and by phone on +44 (0)20 7510 9103.

Responsibility for this Policy

The board of directors of Eco World-Ballymore Holding Company Limited has overall responsibility for seeking to ensure that this policy complies with EcoWorld Ballymore’s legal and ethical obligations, and that all those with whom we work  comply with it.  Management at all levels within our business are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

Comments on this Policy

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to: or

A full copy of this policy is available on the EcoWorld Ballymore website. A copy of the Act may be obtained by clicking here.

For further information regarding Modern Slavery in the construction industry, please see the briefing fact sheet published by the UK Government which can be accessed here.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the slavery and human trafficking statement for the financial year ending 31 October 2018.

Eco World-Ballymore Holding Company Limited
Date:  March 2019