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Modern slavery statement


Modern Slavery Act 2015

Opening statement from senior management

Churchill Living Ltd ("Churchill") is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain and imposes the same high standards on its suppliers. We have a zero-tolerance approach to modern slavery and human trafficking, and we are committed to acting ethically, transparently and with high integrity in all our business dealings and relationships. We aim to achieve this commitment by implementing and enforcing effective systems designed to ensure modern slavery is not taking place anywhere within our business, our partners or in any of our supply chains and by adhering to our obligations under the Act.

Structure of the Organisation

Churchill is a retirement property developer based solely in the UK. It is a wholly owned subsidiary company of Churchill Living Plc, which employs circa 700 people in the UK, operating from 5 regional offices and various construction and sales sites.

The Churchill group has a consolidated annual turnover of £175m. To find out more about the nature of our business, please click We provide quality retirement homes for independent living and have over 30 years' experience in this field.

In order to build, develop and sell retirement homes, we work with a range of suppliers and subcontractors on a national and regional basis, many of whom have grown alongside us and have become trusted partners.


As part of our commitment to combating modern slavery, we have implemented the following policies:

  • Procurement (Buying) Policy
  • Speak-Up Policy
  • Recruitment of site agency labour policy

These policies are published on our group intranet site and are available to all employees.

We also make sure our suppliers are aware of our policies and adhere to the same high standards.

These policies have been developed by our in-house legal department in conjunction with our Group Risk & Assurance team. and are implemented via our Group HR and Group Commercial Construction functions.

Due diligence

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains, we have adopted a number of due diligence procedures including internal audits and checks. We have recently required all our key subcontractors to be members of the Safety Management Advisory Services (SMAS) Workface scheme who are national leaders in providing full form SSIP (Safety Schemes in Procurement) and promotes adherence to Anti Modern Slavery policies.

Our procedures are designed to:

  • establish and assess areas of potential risk in our business and supply chains
  • monitor potential risk areas in our business and supply chains
  • reduce the risk of slavery and human trafficking occurring in our business and supply chains
  • provide adequate protection for whistle-blowers

Risk and compliance

Churchill regularly evaluates the nature and extent of its exposure to the risk of modern slavery occurring in its supply chain by periodical audits.

We consider that we operate in a fairly high-risk sector because the construction sector is renowned for its complex supply chains and although we do not operate outside of the UK, some of our suppliers and subcontractors may source labour and products from global supply chains.

We ensure all our suppliers are aware of and adhere to our Modern Slavery & Human Trafficking Statement. We operate a strict code of compliance and do not tolerate slavery and human trafficking within our supply chains. For example, if we find evidence of a failure to comply with our policies, we will immediately seek to terminate our relationship with the relevant supplier or Subcontractor.


We are seeking to invest in educating our construction staff, in particular, to recognise the real risks of modern slavery and human trafficking in our business and supply chains and all employees are encouraged to identify and report any potential breaches of our anti-slavery and human trafficking policy through our Speak-up Policy line.

Further actions and sign-off

Following our review of our actions this financial year to prevent slavery or human trafficking from occurring in our business or supply chains, we intend to take the following further steps to tackle slavery and human trafficking:

  • develop and roll out training for all site-managers to be made better aware of the risks of Modern Slavery and to report it, if they have any concerns.
  • introduce a new specific anti-slavery and human trafficking policy and publish this on our intranet detailing new procedures and lines of managerial responsibility.
  • audit all key suppliers annually to ensure compliance with our Modern Slavery & Human Trafficking Statement and Policy.
  • This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes Churchill Living Ltd.'s slavery and human trafficking statement for the financial year commencing 1 July 2024 and ending 30 June 2025.

This statement was approved by the Board in April 2024.

Clinton McCarthy
Managing Director – Churchill Living Limited
21st May 2024