Modern Slavery Act

Modern Slavery and Human Trafficking Statement 2021

Capital & Counties Properties PLC (together with its subsidiary companies, “Capco”) is one of the largest listed property companies in central London. Our key asset is the landmark Covent Garden estate. We create and grow value through a combination of creative asset management and strategic investments. Capco’s assets were valued at £2.4 billion as at 31 December 2021 (Group share) and Capco employed around 70 people, all of whom are based in the UK.

Our purpose is to invest in and create world-class places, focusing on central London. Using our vision, long-term approach and responsible stewardship, we deliver economic and social value and generate benefits for our stakeholders.

Capco remains committed to combatting modern slavery, servitude, forced or compulsory labour and human trafficking in every part of its business and supply chains. This statement sets out Capco’s approach by describing the policy framework, due diligence and monitoring implemented to prevent all forms of modern slavery.

Our Approach

In line with Capco’s values, our Business Code of Practice (akin to a code of conduct) states our strong and long-term commitment to embedding high ethical standards throughout the business and to operating, as a minimum, in accordance with all applicable laws and regulations. We apply these high standards to our engagement with stakeholders, our approach to managing our environmental impact and commitment to become net zero carbon by 2030, the quality of services and facilities we supply, our employment practices, procurement and corporate reporting. As outlined in our Financial Crime Policy, which is available on our website, we take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings. We expect those who work with or for Capco to comply with their tax obligations.

Capco employees are expected to deliver their roles with integrity, following ethical business practices in line with Capco’s approach to high standards of personal and professional ethics. This includes awareness of the risk of breaches of human rights, including modern slavery, forced labour and human trafficking. A range of HR policies and procedures support the recruitment and management of employees in a fair and positive manner. We operate a Whistleblowing Policy and independent Whistleblowing hotline to encourage staff, and those affiliated with the business, to report any suspected wrongdoing, in the knowledge that their concerns will be taken seriously and investigated in confidence. We have not received any modern slavery related complaints or allegations of serious labour abuse during the financial year ended 31 December 2021.

Capco does not have a stand-alone human rights policy, as the standards we expect to be adhered to are integrated within a number of our policies and procedures, which relate to both our own employees and those of our supply chain. Capco’s Environment, Sustainability and Community (“ESC”) Strategy is aligned with the UN Sustainable Development Goals (“SDGs”). The ESC Strategy and the relevant SDGs can be found in Capco’s 2021 Annual Report, which can be accessed on our corporate website.

Our Employees

We have policies and procedures in place to protect our directly employed employees and their labour rights. We have ensured that applicable policies and procedures remained effective and appropriate during 2021. All Capco employees are paid above the London Living wage.  We also ensure that the providers of managed services to our offices and estates pay the London Living Wage to those working with Capco. We believe that as we are a UK employer that is subject to UK employment legislation and as we have well developed internal controls within our business there continues to be a minimal risk of modern slavery incidences relating to the recruitment and management of Capco’s directly employed employees.

Capco’s Anti-Harassment and Bullying Policy and Equal Opportunities Policy are published on our corporate website. The former ensures our employees are treated with dignity and respect, free from harassment and bullying.

Our Supply Chain

As a property company that purchases, manages and develops assets, we procure a wide range of goods, services and works to support the delivery of our business strategy. Capco considers that the highest potential risk areas in relation to modern slavery are in its supply chain. To mitigate the risks that could be associated with our business and our supply chain, Capco has put in place policies, procedures and processes to avoid incidences of modern slavery and human trafficking. A large part of our supply chain spend comprises professional services from suppliers based in the United Kingdom, which we have assessed to be of low potential risk area in relation to modern slavery.

Capco has a Procurement Policy and procedure to support employees in achieving best value and minimising risk when procuring goods, services and works. A working group continually monitors the effectiveness of the Procurement Policy. Capco’s Supply Chain Policy (which is available to view on our corporate website) sets out the ethical standards we require our suppliers to uphold and specifically addresses modern slavery and human trafficking. Should we believe that a supplier is not undertaking adequate action to prevent modern slavery or human trafficking, or is practising in breach of Capco’s policies or legislation, then the relationship with the supplier would be terminated.

Capco is also a Client Partner of the Considerate Constructors Scheme (“the CCS”). The CCS requires Client Partners to adhere to its guidance on modern slavery and human trafficking awareness and ethical sourcing. We encourage the contractors we engage to be registered with the CCS and we expect compliance with all aspects of the CCS Code on our registered sites, including the CCS guidance on modern slavery.


On joining Capco all permanent and fixed term contract employees are made aware of modern slavery and human trafficking as part of the formal induction process. All employees are made aware of the Group’s policies and procedures including those on financial crime, whistleblowing, diversity and inclusion, health and safety and anti-bullying and harassment and are required to review and confirm their understanding of company policies on an annual basis. Bespoke training on modern slavery and human trafficking will continue to be provided to relevant employees and included as part of the formal induction process for new employees.

Activities To Date

Capco remains committed to being transparent with suppliers, to operating in a collaborative manner and to improving our suppliers’ understanding of ethical and responsible business in a sustainable manner.

During the year ended 31 December 2021 the following activities were undertaken to raise awareness of the risk of modern slavery and human trafficking:

  • Capco promoted its ESC Strategy amongst its stakeholders. The ESC Strategy is underpinned by four pillars, which were designed with reference to the UN SDGs. The goals are a call for action by countries, in a global partnership. They recognise that ending poverty and other deprivations must go hand-in-hand with strategies that improve health and education, reduce inequality and spur economic growth.
  • Capco published an updated Sustainable Development Framework for Projects and Development. The Framework details the standards we expect to be achieved by our appointed supply chain on new construction and major refurbishment projects. The Framework reflects the evolving standards for responsible development that is environmentally and socially considerate.
  • Continued to ensure that best practice advice from the Gangmasters Labour Abuse Authority (“GLAA”) Construction Protocol was provided to our suppliers where relevant, with our direction that this be provided to the wider supply chain.
  • Capco remains an active member of the Construction Clients Leadership Group (“CCLG”) and participates in a working group to raise industry awareness of the risk of modern slavery in the construction sector and drive best practice.
  • Delivered bespoke training to our employees on inclusive behaviour and respect at work to ensure the continued awareness of the importance of diversity and inclusion amongst our people.
  • Consideration of prospective suppliers’ approach to combatting modern slavery continued to be integral to the Capco Procurement Policy and tender review process.
  • Further information on our expectations relating to modern slavery continued to be provided to suppliers via our wider suite of corporate policies with which key suppliers are required to confirm acceptance on an annual basis.
  • We continued to deliver bespoke training on modern slavery and human trafficking to relevant employees, and continued to include training on the statement and Capco’s Procurement Policy in our induction process for new employees.
  • Continued to raise awareness of the issue of modern slavery and human trafficking with those responsible for procurement within the business to ensure that they are able identify and report any suspected instances.  This included providing further guidance on matters to be considered when procuring goods or services from higher-risk sectors.
  • Continued to proactively monitor our supply chain and ensure any potential high-risk suppliers complete a Modern Slavery Act questionnaires.

To date, Capco has identified no occurrences of modern slavery or human trafficking in our supply chains.

Future Activities

Capco recognises that tackling modern slavery and human trafficking requires constant monitoring and vigilance. During the year ahead we aim to continue to build on the work to date. Capco will continue its work as an active member of the CCLG Working Group to drive engagement between the industry and government on the key issues of regulation, enforcement and prevention during 2022 and beyond.

We will build upon the diversity and inclusion training delivered to our employees during 2021, with a specific emphasis on the prevention of harassment and sexual harassment within the workplace.

We intend to further our ongoing engagement with our applicable suppliers on modern slavery by encouraging them to train their own suppliers on the relevant policies they have in place and raise awareness of modern slavery and human trafficking throughout the supply chain.

Evaluating Performance

Whilst we believe that the risk of modern slavery within our direct operations is low, we recognise the need to set best practice standards for our supply chain and to regularly monitor and evaluate their performance. We remain committed to demonstrating strong environmental, social and governance practices, in conjunction with our ESC Strategy.  In the year ahead we will continue to raise the awareness of modern slavery to our employees, engage with and review supplier performance.


This statement is Capco’s sixth statement made pursuant to section 54 of the UK Modern Slavery Act 2015 ‘Transparency in Supply Chains’ (the “Act”) and constitutes Capco’s modern slavery and human trafficking statement for the financial year ended 31 December 2021. This statement covers the activities of Capco, and all its subsidiary entities and specifically those subsidiary and joint venture entities referenced below. This Statement was approved by the Board of Capital & Counties Properties PLC on 22 February 2022.

Ian Hawksworth

Chief Executive

Capital & Counties Properties PLC

There is a link to this statement, and Capco’s previous statements, on the Capco website and copies are available upon written request.

Capital & Counties CGP

Covent Garden Group Holdings Limited

Lillie Square LP (*equity account joint venture entity)

A copy of the 2021 Modern Slavery and Human Trafficking Statement can be downloaded here.

Copies of the 2020, 2019, 20182017 and 2016 Modern Slavery and Human Trafficking Statements can be downloaded here.