Peterborough Prison Management (Holdings) Limited & Peterborough Prison Management Limited  (together “Peterborough Group”)

Modern Slavery Statement & Human Trafficking Statement
for the financial year to 31st March 2018
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Peterborough Group has taken and is continuing to take, using all reasonable endeavours, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour.  Peterborough Group has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
Company Overview
Peterborough Group was formed as Private Finance Initiative special purpose vehicles, whose purpose was to design, construct, finance and provide management services to a prison, HMP Peterborough, following the entry into a 25 years’ contract (“the PFI Contract”) with the Secretary of State for Justice (the “Authority”) for such services.   
The Company operates a number of policies to ensure that it is conducting business in an ethical and transparent manner, including anti-bribery, Health & Safety, and Data Protection. The policies explain the manner in which we behave as an organisation and how we expect our suppliers to act. 
The Company has no direct employees; however, it does have in place two Management Services Agreements.  The first agreement is with Albany SPC Services Limited (“Albany”), which provides the services of a Finance Officer, Company Secretary and other management staff.  The second is with Sodexo Limited (“Sodexo”), which provides the services of the General Manager and again, other management staff.  Both Albany and Sodexo operate robust recruitment policies including eligibility to work in the UK, checks for all employees to safeguard against human trafficking or individuals being forced to work against their will, and whistle-blowing.
Supply Chain
The Company works with key supply chain partners.
Under the PFI Contract, construction and long-term facilities management subcontracts were put in place at the time when the PFI Contract was signed.  Due diligence was undertaken into the financial status, operating policies and practices (including ethical) of the subcontractors prior to the subcontracts being signed.  The principal subcontractors were pre-approved by both the Peterborough Group and the Authority to ensure they held any required accreditations or appropriate qualifications for the services that they would deliver. 
Under the PFI Contract, the principal supplier of construction services was Interserve Construction Limited (“ICL”) who built the prison. Sodexo is the provider of facilities management services to the prison for the life of the concession.  
The Peterborough Group recognises that there is a risk of slavery and human trafficking in the construction and facilities management sectors, and therefore expects both ICL and Sodexo to adhere to a policy of zero tolerance to slavery and human trafficking both within their own organisations and in any of their own supply chain partners who may provide services on their behalf to the prison or for the PFI Contract. The Board of the Peterborough Group has sought and received assurances and evidence of their policies and operational practices in this respect.
In addition, the Peterborough Group has an agreement in place with Lenders to provide credit facilities; the Board believes this area of activity is very low risk in relation to slavery and human trafficking.
The Peterborough Group intends to provide this statement to its key supply chain partners and to monitor their policies.
This statement will be reviewed on an annual basis.
This statement was approved by the Board of Directors on    25 March  2019.
This statement was signed on behalf of Peterborough Prison Management Holdings Limited & Peterborough Prison Management Limited on 25 March 2019 by Chris Field, Director