Modern Slavery Act Policy 

Procedures to Identify and Manage the Risk of Modern Slavery and Labour Exploitation

MAS Lettings and Management limited

Effective Date: 30th November 2022

Reviewed: 13th October 2025

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1. Purpose

This document outlines the procedures used by MAS Lettings and Management limited to identify, assess, prevent, and respond to risks of modern slavery, child labour, and other forms of labour exploitation in our operations and supply chains. These procedures support our compliance with relevant legislation (e.g., the Modern Slavery Act) and our broader corporate social responsibility (CSR) commitments.

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2. Scope

These procedures apply to:

All employees of MAS Lettings and Management limited

• All landlords, contractors and service providers

• All tenants and suppliers operating within the properties we manage

 

 

3. Risk Identification

A. Risk Mapping of Operations and Supply Chain

We will identify high-risk areas by assessing:

• Industries with a known high risk of labour exploitation (e.g., cleaning, construction, security)

• Geographical locations (e.g., countries or regions with weaker labour protections)

• Use of subcontracted or temporary labour

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B. Supplier and Contractor Risk Assessment

Before onboarding any third party, we will:

• Require them to complete a Modern Slavery Risk Questionnaire

• Collect information on recruitment practices, working conditions, and employment terms

• Prioritise suppliers with clear policies and training on labour rights​

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4. Risk Management Procedures

​A. Due Diligence

• Conduct background checks on suppliers and contractors

• Include anti-slavery and ethical labour clauses in all contracts

• Require ongoing compliance certifications from high-risk vendors​

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B. Auditing and Monitoring

• Schedule annual reviews of suppliers, focusing on labour conditions and practices

• Use spot audits or third-party social audits where risk is high

• Monitor subcontractor chains (not just direct vendors​

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C. Employee and Contractor Training

• Provide mandatory training on identifying signs of modern slavery and exploitation

• Train property managers and site supervisors to identify red flags such as:

  • Workers showing signs of coercion, fear, or control

  • Unexplained injuries or reluctance to speak freely

  • Workers who appear to be minors or unsure of their rights

 

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5. Reporting and Escalation

​Establish and communicate a confidential reporting channel (e.g., email or telephone) for concerns related to labour exploitation

A. Allow anonymous reports without fear of retaliation

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B. Incident Response Protocol

If modern slavery or labour exploitation is suspected:

​The issue will be escalated immediately to senior management and legal advisors

​An internal investigation will be launched

​If confirmed, relationships with non-compliant suppliers may be suspended or terminated

​Authorities and relevant NGOs may be contacted depending on the severity​

Remediation and Support

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If victims of exploitation are identified:

• Provide access to support services (e.g., shelter, legal aid, or NGOs specialising in victim support)

• Ensure any impacted individuals are removed from harmful environments

• Engage in dialogue with suppliers to implement corrective action plans

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6. Continuous Improvement​​

       We are committed to ongoing improvement by:

• Reviewing these procedures annually

• Staying informed of changes in legislation and best practices

• Participating in industry initiatives to improve supply chain transparency and labour conditions

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7. Accountability and Governance

• A designated Modern Slavery Compliance Officer or senior manager is responsible for overseeing these procedures

• A summary of actions taken will be included in our annual CSR or Modern Slavery Statement