Slavery and Human Trafficking Statement

Introduction from the Company Director, on behalf of the Vita Group Board

The Modern Slavery Act 2015 (“the Act”) requires commercial organisations of a certain size, operating in the UK and supplying goods and services from or to the UK, to publish a slavery and human trafficking statement each financial year, setting out the steps which they have taken to ensure that there is no slavery or human trafficking in their business or supply chains.

Vita Group and all its UK subsidiaries (the ‘Group’) are committed to combatting slavery and human trafficking in all its forms in our own business and in our supply chain. Vita Group adopt a zero – tolerance approach to any criminal offence. This statement is made pursuant to section 54(6) of the Act and constitutes our slavery and human trafficking statement for the financial year 2023. This statement relates to all companies within the Vita Group Holdings Limited group of companies.

Organisational Structure

We are a developer, operator and promoter of market-leading residential property brands headquartered in the UK but operating through branch offices globally. The ultimate parent company is Vita Group Holdings Limited. The Group has over 500 employees.

Organisational Structure

Our business is organised primarily into the following six operating brands, across a range of business units from design and development, marketing and letting, building operations, and finance and accounts:

Vita Student and House of Social provide purpose-built student accommodation;
Vita Living and Affinity Living are brands which operate in the build-to-rent sector;
CitySuites delivers Aparthotel serviced apartments; and
Union operates co-living residential communities.

Given the nature of our business, we consider that there is a low risk of modern slavery and human trafficking having a connection with our operating brands. However, we have taken the steps detailed below to ensure compliance of the Act.

Our supply chains

Our supply chains include design and engineering consultants, construction contractors, suppliers of furniture, fixtures and equipment, building maintenance/service contractors, professional service providers (such as lawyers and accountants), IT software and service providers, marketing and design agencies and recruitment agencies.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Modern Slavery and Human Trafficking Policy.

Our Modern Slavery Policy demonstrates our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

This can be found at VG-Modern Slavery Policy-001

Due diligence processes for slavery and human trafficking internal employees

Employees are required to familiarise themselves with all policies and procedures to assist in the identification and prevention of such criminal acts.

Due diligence processes for slavery and human trafficking internal employees

We fully expect that our direct supply chain members meet both legal and ethical standards in their daily operations, while ensuring that compliance is managed appropriately across their own supply chain partners.

We have recently upgraded our supplier onboarding through our Supplier Take-On Process and have hired additional staff to assist with supply chain engagement and monitoring.

We have mechanisms in place to protect whistle-blowers.

Furthermore, we are working to have increased awareness around the following:

Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.

Supplier adherence to our values

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values we intend to review our agreements and dealings with suppliers and contractors to ensure compliance with anti-slavery measures.

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide guidance and training to our staff in Modern Slavery at enrolment, and also require them to undertake refresher training annually.

We will also encourage our business partners to provide training to their staff and suppliers.

Our effectiveness in combating slavery and human trafficking

To make sure that we monitor our compliance with policy, we will use a number of key measures across our group of companies, including specifically Completion of all statutory requirements to
ensure right to work within the UK.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ending December 2023.