Modern Slavery Act 2015
Europe Legal and Compliance

Approver’s name and title:
Mark Packer, General Counsel, EuropeDirector

Effective date:
November 2016

Review date:
December 2017

Next review date:
December 2018

PURPOSE
Lendlease Europe Holdings Limited(‘Lendlease’) has taken and continues to takesteps to improve our practices to combat slavery and human trafficking both within our own business and that of our supply chains. The aim for the company is to inform and encourage staff members to be more vigilant to the issues around slavery and human trafficking and to provide them with an opportunity to raise any concerns.

POLICY
Organisation’s Structure
Lendlease is a multidiscipline company providing Consultancy, Asset & Property Management, Infrastructure, Development, Investment Management and Construction Services within the Construction and Real Estate industry. We have circa 1300 employeesacross the business and have a multi-disciplined supply chain to support us through the different aspects and provisions of our business. We are part of the Lendlease Group and our ultimate parent company is Lendlease Corporation Limited whichhas its head office in Sydney, Australia.

Our Policies
We operate a number of internal policies to ensure that we are acting ethically and with integrity in all our business relationships and implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chain.

We are committed to building a workplace in which all individuals are supported, respected and connected and this forms part of our Diversity and Inclusion policy which can be found on our company website here.

Lendlease is also a signatory to the United Nations Global Compact (UNGC) and as part of our commitment to the UNGC we produce an annual “Communication on Progress” against the UNGC 10 universal principles and broader UN development goals which can be found here.

Due Diligence Processes
As part of our initiative to identify and mitigate risk, we have in place or will be putting in place systems to (but not limited to):

  1. Accredit its supply chain using the AchillesBuilding Confidence audited accreditation scheme. This has included for a number of years, audited pre-qualification checks on ethical procurement, child and forced labour, anti-bribery and corruption, sustainable products, living wage and working hours. We have recently updated the scheme to include an additional section on Modern Slavery and our supply chains adherence to the Act.
  2. Monitor other potential risk areas such as;
    • Materials sourced from overseas
    • Sub-sub supply chain
  3. Use of temporary labour agencies
  4. Encourage the reporting of concerns and the protection of whistle blowers (Whistleblowing Policy)

Supplier Adherence to our Values
We have zero tolerance to slavery and human trafficking. In addition to the accreditation checks, to ensure all those in our supply chain and contractors comply with our values we have in place requirements to comply with Lendlease Core Values and Global Minimum Requirement’swhich can be viewed on our company website here.

Our Effectiveness in Combating Slavery and Human Trafficking
We use the following key performance indicators (KPI’s) 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:

  1. Additional actions taken to strengthen supply chain auditing and verification.
  2. Requiring our supply chain members to update their information on a regular basis and Lendlease auditing the supply chain members on their updated information once a year at their premises.
  3. Audit and review of current business practices with regards to recruitment and treatment of employees.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. The statement has been approved by the Board of Directors who will review and update it as necessary on an annual basis. Lendlease Europe Holdings Limited