Policy · Supply relationships
Modern slavery and human trafficking statement.
Our approach to identifying and reducing exploitation risk in business, contractor and supply relationships connected with land and estate ownership.
Policy information · reviewed September 2026
Our position.
Grupo Gosen does not accept forced labour, servitude, trafficking or other forms of modern slavery in its own operations or in relationships with contractors and suppliers. Land and estate ownership can involve construction, maintenance, landscaping, cleaning, agricultural, security and other labour-intensive services, so responsible procurement requires attention to how work is actually delivered.
This page describes the group’s public approach to modern-slavery risk. Publication of this page should not by itself be taken as a representation that Gosen Group Limited falls within any particular statutory turnover threshold or reporting requirement. The applicability of formal reporting duties is reviewed by reference to the law and the group’s circumstances.
The objective is practical: use proportionate due diligence, maintain transparent contracting and create a route for concerns to be raised where exploitation may be present.
Risk management
Areas of focus.
Contractor labour
Pay attention to labour-intensive estate and property services, especially where work is subcontracted through several layers.
Supplier selection
Use proportionate checks on counterparties and avoid relationships where ownership, labour practices or payment arrangements cannot be explained satisfactorily.
Clear contracting
Set legitimate scopes, rates and responsibilities and avoid opaque arrangements that make it difficult to understand who is carrying out work.
Warning signs
Take concerns seriously where there are indications of coercion, withheld identity documents, restriction of movement, debt bondage, unusual deductions or controlled communication.
Respectful treatment
People working on or around estate assets should be treated lawfully and with dignity regardless of employment status or contracting chain.
Escalation
Where a credible concern arises, pause ordinary assumptions, gather appropriate facts and seek specialist or authority involvement where necessary.
Due diligence
Proportionate checks depend on the relationship.
A low-value local professional service and a labour-intensive multi-tier contractor present different risks. Due diligence can consider the nature of the work, subcontracting, recruitment model, country risk, payment arrangements, workforce visibility and any credible concerns raised by workers or third parties.
A contractual statement alone is not a complete control. Estate teams and project advisers should remain alert to conditions observed on site and inconsistencies between the stated supply chain and the people actually performing the work.
Where concerns are substantiated, available responses can include requiring corrective action, changing suppliers, suspending work, ending a relationship where contractually and legally appropriate, or referring a matter to competent authorities.
Concern about exploitation or a supply relationship?
Use the central contact form and identify the issue as a modern-slavery or responsible-sourcing concern. Do not include unnecessary sensitive personal information in an initial submission.
Raise a concernProperty supply chains
Estate ownership creates supply-chain relationships that require proportionate oversight.
Land and estate management can involve construction, maintenance, landscaping, agriculture, cleaning, security, waste, utilities, professional services and temporary labour. The nature of those activities means labour standards and subcontracting practices can be relevant even where Grupo Gosen itself has a relatively small direct workforce.
The group takes a risk-based approach. Higher-risk work can warrant closer review of the supplier’s identity, employment model, use of subcontractors, geographic exposure, labour sourcing and ability to explain how workers are recruited and paid.
A low-value contract is not automatically low risk. Labour-intensive services, opaque subcontracting and cash-based arrangements can require particular attention.
Supplier expectations
Suppliers are expected to operate lawfully and respect fundamental labour standards.
Freely chosen work
Workers should not be subjected to forced labour, threats, debt bondage, retention of identity documents or other coercive practices.
Clear employment terms
Workers should receive lawful and understandable terms, pay and working arrangements appropriate to the jurisdiction and role.
Safe working conditions
Suppliers should comply with applicable health-and-safety and welfare requirements and manage risks appropriate to their work.
Responsible subcontracting
Material subcontracting should not be used to obscure labour conditions or avoid legal responsibilities.
Right to investigate
Grupo Gosen may request information, investigate credible concerns and take contractual action where serious non-compliance is identified.
Escalation
Serious concerns can lead to suspension, remediation requirements, termination or referral to appropriate authorities.
Governance and review
The policy is reviewed in proportion to the group’s activities and legal obligations.
The legal requirement to publish a slavery and human-trafficking statement under section 54 of the Modern Slavery Act 2015 depends on statutory criteria, including turnover and business activity. Publication of this page does not state that Grupo Gosen falls within the mandatory reporting threshold unless that position is separately established.
Irrespective of mandatory threshold status, the group considers modern-slavery risk relevant to responsible procurement and estate management and may update supplier expectations, contractual controls and review procedures as its activities develop.
Concerns relating to a Grupo Gosen supplier, contractor or property can be raised through the contact form. Reports should contain enough factual information to permit responsible review.