Introduction
The Super Prime (“TSP”, “we”, “our”, “us”) strongly opposes modern slavery in all its forms, including slavery, human trafficking, forced labour, and exploitation. Although TSP does not currently meet the turnover threshold requiring a formal Modern Slavery Statement under the UK Modern Slavery Act 2015, we proactively commit to maintaining high ethical standards and preventing modern slavery in our business and supply chains.
Our Commitment
TSP is dedicated to ensuring no form of slavery or human trafficking exists within our business operations or our supply chains. We operate with integrity and require the same from our suppliers and partners.
Our Business and Supply Chains
TSP operates in the luxury real estate and lifestyle sector, primarily through our digital platforms offering property listings and luxury content. Our business engages suppliers and partners for technology, digital advertising, marketing, and professional services, as well as property maintenance and related services, which constitute our primary areas of risk.
Risk Assessment and Management
We recognize that while the risk of modern slavery within our direct business operations is minimal, certain supply chains such as property maintenance, cleaning, security, and facility services pose a greater potential risk. To manage and mitigate this risk, TSP undertakes careful due diligence processes and only partners with suppliers who clearly share our ethical standards.
Policies and Procedures
We have implemented several internal policies aimed at ensuring our operations and supply chains are free from modern slavery. These include:
- Ethical Procurement Policy
- Whistleblowing Policy
- Anti-Bribery and Anti-Corruption Policy
All suppliers and business partners must adhere to these policies and standards.
Supplier Due Diligence
As part of our procurement and contracting process, TSP undertakes careful selection and evaluation of suppliers:
- Suppliers must demonstrate compliance with our Ethical Procurement Policy.
- We conduct background checks to ensure suppliers align with our anti-slavery standards.
- Contracts clearly state supplier obligations regarding adherence to applicable anti-slavery laws.
Staff Training and Awareness
We are committed to ensuring awareness among our employees regarding the signs and risks of modern slavery and encourage vigilance and reporting of any concerns via our confidential whistleblowing channels.
Reporting Concerns
Employees, suppliers, and other stakeholders are encouraged to report any concerns or violations confidentially to:
- Email: compliance@thesuperprime.com
- Address: 45 Albemarle Street, Mayfair, London, W1S 4JL
Continuous Improvement
We recognize that combating modern slavery is an ongoing effort. Our future commitments include:
- Regularly reviewing and improving our risk assessment practices.
- Continuous enhancement of our procurement processes to include thorough compliance checks.
- Ongoing training and awareness initiatives for employees and stakeholders.
Approval
This statement reflects the commitment and proactive stance of TSP towards eliminating modern slavery and was formally approved by the senior management team.