Modern Slavery

Modern Slavery and Human Trafficking Statement

Madison Brook (Group) Limited (“Madison Brook”)
For the financial year ending 31 December 2024
Pursuant to section 54(1) of the Modern Slavery Act 2015

Introduction

At Madison Brook, we are committed to conducting business responsibly, ethically, and transparently. We take seriously our obligations under the Modern Slavery Act 2015 and remain committed to identifying and mitigating the risk of modern slavery and human trafficking in our operations and across our supply chain.

This statement outlines the steps we have taken during the financial year ending 31 December 2024 to prevent modern slavery and human trafficking from taking place within our organisation or those we work with.

Group Structure and Operations

Madison Brook (Group) Limited (“the Group”) is a multi-disciplinary property services group headquartered in London, operating across Greater London and the Home Counties.

The Group comprises the following principal subsidiaries:

• Madison Brook (Agency) Limited – residential sales, lettings, and property management services
• Madison Brook (Construction) Limited – design, refurbishment and build services
• Madison Brook (Living Markets) Limited – affordable housing, investment acquisition, and compliance-led portfolio management

The Group employs approximately 100 individuals across multiple office locations and site operations. From time to time, the Group may acquire or establish new companies in related sectors.

Supply Chains

Our supply chains support both internal operations and external service delivery, and include:

• Building contractors, trades, and maintenance providers
• Professional service providers (legal, IT, accountancy, software, and consultancy)
• Marketing, media and creative suppliers
• Recruitment partners
• Utility companies, telecoms providers and office services
• Local authorities, housing partners and specialist consultants

We recognise that construction and maintenance sectors, in particular, can carry elevated risks in relation to modern slavery. As such, our approach to supplier due diligence and ongoing relationship management reflects this.

Policies and Approach

We are committed to upholding human rights and ethical labour practices across all areas of our business. Our policies and governance frameworks include:

• A Group Code of Conduct, which outlines the ethical standards expected from all employees and contractors
• A robust Supplier Onboarding and Vetting Process, requiring all key suppliers to confirm compliance with modern slavery legislation and our values
• A commitment to only engaging contractors and employees with the legal right to work in the UK
• Standard working practices that favour direct employment relationships, rather than indirect or agency-sourced arrangements
• We aim to foster an inclusive and respectful workplace culture, with a clear expectation that our people and partners uphold high standards of integrity, fairness, and accountability.

Training and Awareness

We are working to ensure that all relevant staff, particularly those involved in procurement, site management, lettings, and property management, are trained to identify the signs of modern slavery or exploitation – whether in supply chains or within properties under our management.

Our Anti-Money Laundering and Tenant Risk Awareness training includes modules on identifying potential indicators of trafficking, illegal subletting, or exploitative arrangements within the private rented sector.

Where wrongdoing is suspected, we are committed to working closely with the relevant authorities to safeguard victims and pursue accountability.

Whistleblowing and Reporting

The Group facilitates a confidential whistleblowing mechanism that enables employees to raise concerns about unethical or unlawful conduct, including suspected slavery or trafficking, without fear of retaliation.

All reported concerns are reviewed independently and handled in line with our internal investigations protocol.

Ongoing Action and Commitment

While we have not identified any instances of modern slavery or human trafficking within our business or supply chain during 2024, we recognise this is an ongoing risk requiring vigilance.

In 2025, we are committed to:

• Continuing to review and strengthen our supplier vetting processes
• Expanding training for relevant staff across all business units
• Regularly reviewing our policies to ensure they remain fit for purpose
• Proactively collaborating with ethical supply chain partners

Approval

This statement has been approved by the Board of Directors of Madison Brook (Group) Limited and its principal subsidiaries.

Signed:

John Lipper
Chief Executive Officer
Madison Brook (Group) Limited

Date: 01 April 2025