Modern Slavery Statement

Made pursuant to section 54 of the Modern Slavery Act 2015 for the Financial Year ended 05 April 2026

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps taken by Seville Developments Ltd (“Seville”) during the Financial Year ended 05 April 2026 to help prevent modern slavery and human trafficking in our business and supply chains.

Seville is committed to acting ethically and with integrity in all business dealings and relationships. We are committed to improving our practices to help prevent slavery, servitude, forced or compulsory labour and human trafficking in our own operations and in our supply chains.

1. Our organisation, business and supply chains

Seville Developments Ltd is a construction and property maintenance services contractor operating in England.

During the reporting period, our principal business activities included residential development, building maintenance, and refurbishment and decoration works for public sector and commercial clients. Seville’s work is delivered across a varied portfolio of occupied and unoccupied properties and includes both directly delivered services and specialist subcontracted packages where additional expertise or capacity is required.

Our supply chain includes subcontractors and suppliers engaged in specialist trades and peak demand support, typically within the following categories:

1. General building, structural and enabling works
2. Building fabric, roofing and external envelope
3. Internal finishes and fit-out
4. Mechanical, electrical and specialist building services
5. External works, access and infrastructure, and
6. Specialist support and compliance services.

We recognise that modern slavery risks can arise both in labour-based services and in product supply chains, particularly where there are multiple tiers of suppliers or reduced visibility beyond direct suppliers.

2. Our policies in relation to modern slavery

During the reporting period, Seville’s approach to modern slavery was supported by the following policies, procedures and controls:

• Modern Slavery and Human Trafficking Policy
• Whistleblowing Policy
• Subcontractor Pre-Qualification and Approval Procedure, and
• Equal Opportunities Policy.

These documents support lawful recruitment, fair treatment of workers, safe reporting of concerns and ethical business conduct. We expect our employees, subcontractors and suppliers to comply with applicable law and with Seville’s standards when working for, or on behalf of, the company.

3. Due diligence processes

During the reporting period, Seville applied due diligence measures intended to reduce the risk of modern slavery within its operations and supply chains. These included, where applicable:

• review of right to work and labour engagement arrangements
• review of insurance, business credentials and compliance information
• onboarding checks before approval of new suppliers or subcontractors, and
• periodic review of approved suppliers and subcontractors.

Where new suppliers or subcontractors were engaged, they were required to undergo Seville’s onboarding and approval process before appointment.

4. Assessing and managing risks

Seville recognises that modern slavery risks are more likely to arise in sectors and supply chains involving temporary labour, lower-skilled work, outsourced services, complex subcontracting or limited supply chain visibility.

In our business, the areas considered most relevant to modern slavery risk during the reporting period were:

• subcontracted specialist trades and peak-demand support, where additional labour is introduced outside Seville’s direct workforce
• any proposed second-tier subcontracting, where visibility of labour sources and working practices could be reduced
• labour-intensive work packages delivered through specialist subcontractors, and
• supply chain relationships where compliance information, reporting standards or transparency are weaker than Seville’s required standards.

To manage these risks, Seville took the following steps during the reporting period:

• applied a structured subcontractor pre-qualification and approval process covering competence, experience, capacity, financial standing, insurance, health and safety compliance and digital capability
• limited subcontracting to approved specialist trades or peak demand support within a predominantly direct-labour delivery model
• did not permit uncontrolled second-tier subcontracting, with any further subcontracting
  required to be declared in advance and approved by Seville management, and
• required subcontractors to operate within Seville’s works management and reporting arrangements, with ongoing monitoring, review and removal from the approved supply chain where standards were not met.

Where indicators of possible modern slavery are identified, the matter is escalated internally for review. Depending on the circumstances, appropriate action may include further investigation, corrective action, suspension of engagement and referral to the appropriate authorities. Seville recognises the importance of responding in a way that protects potentially affected workers and does not worsen their position.

5. Monitoring and evaluating effectiveness

Seville is continuing to strengthen its approach to monitoring and evaluating the effectiveness of its anti-slavery measures.
In line with the company’s subcontractor management controls, oversight during the reporting period was supported by the following indicators and controls:

• use of a formal subcontractor pre-qualification and approval process before appointment
• monitoring of subcontractor performance through routine quality checks, spot inspections and regular supply chain review meetings
• control of further subcontracting, with any second-tier subcontracting required to be declared and approved in advance, and
• implementation of corrective actions, including removal from the approved supply chain where subcontractor standards were not met.

These controls are not treated as a standalone compliance exercise. They form part of Seville’s wider approach to supply chain oversight and are intended to improve visibility, strengthen control over subcontracted labour and support continuous improvement in identifying and managing modern slavery risk. Current UK guidance places increasing emphasis on practical action, monitoring and evidence of implementation rather than policy-only reporting, and Seville intends to continue improving its approach on that basis.

6. Training and awareness

During the reporting period, Seville delivered modern slavery awareness briefings and toolbox talks to staff in order to raise awareness of this issue in the construction and property maintenance sectors, how to recognise warning signs, and what to do if concerns arise.

In addition, Seville included modern slavery awareness within company induction and site induction processes so that those commencing work for Seville understood their related responsibilities and reporting routes.

7. Looking ahead

In the Financial Year 2026/27, Seville intends to continue improving its approach by:

1. developing processes to spot potential discrepancies in personal information provided during induction stage, for example, duplicate home addresses, bank account details, etc. that may suggest possible modern-slavery occurrences.
2. additional awareness-raising methods across our sites and business, including refresher training on the key issues surrounding the Modern Slavery Act and how to raise a concern internally and externally.

 

Nathan Crook – Director
14 May 2026