MODERN SLAVERY STATEMENT 

This statement applies to all companies within and associated to Rauniar Investments (referred to in this  statement as ‘The Company’). The information included in the statement refers to the financial year 2020.

ORGANISATIONAL STRUCTURE 

Rauniar Investments and its group of companies operate a property development business. The business  operates from one office from which all employees work. Rauniar Investments acts a parent company to  many subsidiaries and is controlled by its two directors and co-founders, Shiro Rauniar and Shaunak  Rauniar. The directors welcome the Modern Slavery Act as an important piece of legislation that will not  only help achieve greater transparency in supply chains, but which will also protect those who are  vulnerable. Rauniar Investments operates from once office located in Hale, Cheshire, United Kingdom.  The Company covers various areas of business including consulting, operations, project management,  development, procurement, financing, marketing, sales and lettings. Business is conducted throughout the  year and is not dependent on seasons.

The labour supplied to Rauniar Investments in pursuance of its operation is carried out in the United  Kingdom, specifically the North West of England.

DEFINITIONS 

Rauniar Investments considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse; • Being dehumanised, treated as a commodity or being bought or sold as property; • Being physically constrained or to have restriction placed on freedom of movement.

COMMITMENT 

The Company acknowledges its responsibilities in relation to tackling modern slavery and commits to  complying with the provisions in the Modern Slavery Act 2015. Rauniar Investments understands that this  requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its  supply chains.

Rauniar Investments does not enter into business with any other organisation, in the United Kingdom or  abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or  compulsory labour.

No labour provided to The Company in the pursuance of the provision of its own services is obtained by  means of slavery or human trafficking. The Company strictly adheres to the minimum standards required  in relation to its responsibilities under relevant employment legislation in the United Kingdom.

SUPPLY CHAINS 

In order to fulfil its activities, Rauniar Investments main supply chains include those related to the  engagement of subcontractors and subconsultants to undertake services and works on our construction  sites including sourcing materials and manufactured products. We take an active role in development of  our suppliers and use a variety of methods to clearly convey our requirements. We have strong relationships  with our subcontractors, subconsultants and suppliers and outline our expectations of ethical business  conduct. Anyone, including workers, subcontractor, subconsultants, and vendors, is encouraged to disclose  any complaints or concerns regarding alleged or possible ethics, human rights, legal, or regulatory violations,  including illegal or immoral business practises, in good faith. In accordance with the Modern Slavery Act  2015, we expect our supply chain to have appropriate anti-slavery and human trafficking policies and

processes. Our expectation is that each organisation in the supply chain to conduct due diligence on the  next link in the chain and assume responsibility for ensuring compliance. It is not viable for Rauniar  Investments (or any other individual in the chain) to have direct contact with all supply chain connections.

POTENTIAL EXPOSURE 

The Company considers its main exposure to the risk of slavery and human trafficking to exist in its  construction sector, specifically subcontractor supply chains because they involve the provisions of a manual labour workforce.

In general, Rauniar Investments considers its exposure to slavery/human trafficking to be negligible. Nonetheless, we have taken steps to ensure that such practices do not take place in our business nor the  business of any organisation that supplies goods and/or services to us.

IMPACT OF COVID-19 

During the reporting period covered by this statement, the COVID-19 pandemic had taken hold. For  several months, the UK was placed into lockdown to stem the spread of COVID-19. This created several  challenges for The Company, as it did for others across the nation.

The Company welcomes the UK Government’s decision, as confirmed in April 2020, to allow for a delay  of up to 6 months in the publication of modern slavery statements without the risk of facing penalty. Despite the permitted, delay, The Company remains in a position to publish its statement in line with the  original publishing requirements.

The Company concludes that the COVID-19 pandemic did not adjust the risk of modern slavery to a  level above that which existed before the pandemic, which is as set out under ‘POTENTIAL  EXPOSURE’ above. Accordingly, The Company’s use of suppliers dropped due to the fact that  homeworking was swiftly implemented in March 2020 which meant that its premises, from which it  usually conducts day to day business, were temporarily closed.

During the pandemic, the Group’s employees still had access to the grievance procedure to raise any  concerns that they may have had. In line with emergency legislation passed by the Government, Group  employees have been paid Statutory Sick Pay during periods of self-isolation where it has not been  possible to agree a temporary period of homeworking.

STEPS 

The Company has not, to its knowledge, conducted any business with another organisation which has been  found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, The Company has taken the following  steps to ensure that modern slavery is not taking place:

• Measures in place to identify and assess the potential risks in its supply chains; • Action plans to address risk to modern slavery;

POLICIES 

The Company is committed to acting ethically and with honesty in all of our business relationships, as well  as implementing and enforcing effective processes and controls to ensure that slavery and human trafficking  do not occur anywhere in the company or our supply chain, to the extent possible. We follow all legislation,  to ensure that no one works illegally.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed  for each financial year.

For and on behalf of Rauniar Investments Ltd