MODERN SLAVERY STATEMENT

The Student Shed Ltd is committed to ensuring that all its staff, subcontractors and suppliers are not subject to behaviour which may amount to modern slavery, human trafficking, forced labour or human rights abuse. This statement sets out our current procedure in assessing and understanding the risk of modern slavery within the business and intended actions to further improve the prevention of the risk of human rights violations.

Modern slavery is a crime and a violation of fundamental human rights. It takes 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. TSS (The Student Shed) has 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 and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
Although the business operates under the threshold for the Modern Slavery self-assessment legal requirement, we are 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 Modern Slavery Act 2015.

We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. This statement applies to all persons working for TSS Ltd or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

THE ORGANISATION
The Companies within the shared directorship of TSS, including Ametros Facilities Management and Inspired Projects, specialise in providing soft facilities services, property refurbishment projects and consumables within the private student accommodation sector within the UK and Republic of Ireland. 
The seasonal nature of our industry attracts many supply chains involving temporary workers and subcontractors, many of which are not UK based. We acknowledge the risk involved in utilising international recruitment and manufacturing processes, and therefore have management systems in place to protect individuals working with the Company against discriminatory practices and human rights violations.

RESPONSIBILITY
The Directors have overall responsibility for ensuring this statement complies with our legal and ethical obligations, and that all those under our control comply with it. The management team has primary and day-to-day responsibility for implementing this statement, monitoring its use and effectiveness, dealing with any queries, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

COMPLIANCE
Employees must ensure they read, understand, and comply with this statement. The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this statement. Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If an employee believes or suspects a breach of this statement has occurred or that it may occur, they must notify their manager or report it as soon as possible. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this statement, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.

COMMUNICATION
Our zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

PROCESSES FOR MANAGING RISK
To assess and manage the risk of modern slavery and human trafficking within the business we apply some of the following practices:

• Assessment of new suppliers at regular intervals.
• Working with sister companies to assess subcontractors prior to involvement in installation projects and review at regular intervals for best practices and adherence to our agreed policies.
• Educating Supervisory and Managerial staff regarding exploitation.
• Assessment of applicants, checking of legal documents and right to work status.
• Providing HR materials and training in multiple languages to ensure full clarity of agreements, and avenues to facilitate whistleblowing are supported by bilingual staff.
• Through receiving multiple quotations and developing supplier relationships, we can ensure all quotations are provided in a way that demonstrates the full labour costs are factored and there is no reliance on bonded or unpaid labour. 

TRAINING AND IMPROVEMENT
It is our aim to maintain awareness and increase our understanding of the risks of modern slavery and human trafficking within our business. We are looking to further expand our training programme for Head Office staff to include more about detection of exploitation within the workforce, how to remain alert to such behaviour, and how to report it immediately. As a business we will also seek to formalise a strategy of internal investigation and response in the wake of any allegations and incorporate this within our procurement process.