Modern Slavery and Human Trafficking Statement

We have zero tolerance for slavery, servitude, forced or compulsory labour, human trafficking, debt bondage, exploitation or the abuse of vulnerable workers.

Statement published 25 August 2026. Approved by the Board 25 August 2026. Signed by Davinder Singh, Director. Review date 25 August 2027.

Sable and Stone Real Estate Ltd, company number 16748179. Registered office and principal office: 124 City Road, London, England, EC1V 2NX.

1. Commitment and reporting status

Sable and Stone Real Estate Ltd ("Sable and Stone", "we", "us" or "our") is committed to identifying, preventing, mitigating and responding to the risks of modern slavery and human trafficking within our operations and business relationships.

Sable and Stone is a newly established residential property business operating in England and Wales. Our activities include residential sales, lettings, property management, marketing, client onboarding, digital property enquiries and relationships with professional partners, contractors and suppliers.

A voluntary statement

For the financial year covered by this statement, Sable and Stone Real Estate Ltd's total annual turnover was below £36 million. Sable and Stone is therefore not currently required to publish a statement under section 54 of the Modern Slavery Act 2015.

We nevertheless publish this voluntary statement because we consider responsible employment, ethical supplier engagement, worker welfare and transparency to be integral to the way we conduct our business. The UK Government encourages organisations below the statutory threshold to consider publishing voluntary statements as part of a transparent and proportionate approach to modern-slavery risk.

2. Our business, structure and supply network

Sable and Stone Real Estate Ltd is a private company incorporated in England and Wales. The Company is governed by its directors, who retain ultimate responsibility for this statement and for the adequacy of the Company's approach to modern slavery and human trafficking.

Our direct operations principally comprise professional property-agency services. Although we do not manufacture goods or operate a large physical supply chain, we rely on a network of employees, contractors, professional service providers and suppliers.

Direct workforce

Employees, workers, agency personnel, consultants, interns and authorised representatives.

Property services

Self-employed negotiators, inventory clerks, photographers, EPC providers, surveyors, cleaners, maintenance contractors, tradespeople, concierge and security providers, removal services and waste providers.

Professional and referral network

Solicitors, mortgage and insurance providers, brokers, property professionals, introducers, marketing affiliates, sourcing partners and other service partners.

Digital and business services

Website and hosting providers, CRM, IT, communications, data, marketing, screening, payment, document-signing, office and facilities suppliers.

Recruitment and labour supply

Recruitment agencies, employment businesses, specialist contractors and subcontractors.

We recognise that modern-slavery risks can arise in both primary service delivery and supporting activities, including recruitment, labour supply, cleaning, construction and maintenance, security, property services and outsourced administration.

3. Policies and governance

Sable and Stone's approach to modern slavery is supported by the following policies, procedures and contractual controls, to the extent that each has been formally approved and implemented:

• Staff handbook: standards for workplace conduct, equality, dignity, anti-harassment, whistleblowing, health and safety and operational conduct.
• Employment and contractor agreement suite: lawful engagement requirements, eligibility, insurance and relevant employment and operational standards.
• Partner and affiliate agreement: partner conduct, due diligence, compliance, data-sharing and cooperation requirements.
• AML verification policy and client onboarding checklists: risk assessment, verification, escalation, recordkeeping and governance controls.
• Privacy and data security policies: protection of personal data and controls for information security and reporting.
• Equality, dignity-at-work, grievance and whistleblowing procedures: appropriate routes for raising concerns without retaliation.
• Supplier and contractor due-diligence process: proportionate screening, insurance, compliance evidence and risk-based approval.

The Board is accountable for this statement. Day-to-day responsibility for supplier and contractor controls, and for workforce policy, training and whistleblowing, rests with the Director or designated responsible person. The Board will review the Company's modern-slavery approach at least annually and following any material incident or change in business activities.

4. Risk assessment and management

Sable and Stone takes a proportionate, risk-based approach to modern slavery. Modern-slavery risk can arise from a range of factors, including worker vulnerability; recruitment practices; use of labour intermediaries; subcontracting; employment status; payment practices; excessive control; restricted movement; retention of identity documents; recruitment fees; debt; threats or coercion; lack of transparency; and inadequate reporting mechanisms.

Self-employed agents, consultants and outsourced labour

Intermediaries or unclear employment arrangements may reduce visibility over worker conditions. We verify identity and engagement route, use written agreements and require appropriate insurance and eligibility evidence.

Cleaning, maintenance and facilities

Labour-intensive services may involve temporary, migrant or subcontracted labour. We use proportionate supplier checks and consider subcontracting and labour risks.

Recruitment and labour supply

Workers may be vulnerable to unlawful recruitment fees, debt, deception or coercion. We use reputable recruitment providers and require lawful recruitment practices.

Security, concierge and removals

Short-notice or outsourced labour may reduce oversight. We apply proportionate supplier checks and clear contractual requirements.

Referral and partner network

Third parties may engage people or services outside our direct oversight. We apply appropriate partner due diligence and contractual requirements.

International digital and service providers

International supply chains may reduce visibility over labour conditions. We maintain supplier records and apply proportionate risk-based due diligence.

Client properties and occupancy

Property activity can potentially expose staff to safeguarding or exploitation indicators. We train relevant personnel to recognise and escalate concerns appropriately.

Our risk assessment will be reviewed annually and following material changes, including a new service, new geography, higher-risk supplier, credible concern or significant change in our workforce model.

5. Due diligence

Sable and Stone will apply proportionate due diligence before and, where appropriate, during relevant supplier, contractor and partner relationships. Depending on the relationship and level of risk, we may:

• verify the legal identity and ownership of the counterparty;
• confirm the nature and scope of services;
• assess labour and subcontracting arrangements;
• consider recruitment methods and geographical exposure where appropriate;
• obtain relevant insurance, registration and compliance evidence;
• require compliance with applicable employment, human-rights, health-and-safety and anti-slavery laws;
• require notification of material modern-slavery allegations or concerns;
• maintain proportionate due-diligence records; and
• require remediation, suspend an engagement or terminate a relationship where serious risks are identified and cannot appropriately be addressed.

6. Contractual expectations

Where appropriate, relevant supplier, contractor and partner agreements will include expectations covering:

• Legal compliance: compliance with applicable laws prohibiting slavery, servitude, forced labour and human trafficking.
• Worker treatment: lawful, fair and safe treatment of workers.
• Recruitment: lawful recruitment practices and no unlawful recruitment fees.
• Subcontracting: disclosure of material subcontracting where required.
• Reporting: prompt notification of credible modern-slavery concerns.
• Cooperation: cooperation with reasonable due diligence and information requests.
• Remediation: appropriate remedial action where concerns are identified.
• Termination: suspension or termination where serious or unremedied breaches warrant such action.

7. Employment, worker welfare and speaking up

We aim to maintain recruitment and employment practices that reduce vulnerability to exploitation. These include, where applicable, written employment and contractor terms; lawful right-to-work checks; fair and non-discriminatory recruitment; role-specific induction; accessible workplace policies; secure payment arrangements; anti-harassment controls; and appropriate reporting routes.

Employees, contractors and business partners are encouraged to raise concerns about poor working conditions; coercion; exploitative recruitment; worker mistreatment; document retention; recruitment-related debt; threats or intimidation; suspicious occupancy arrangements; or other potential indicators of modern slavery.

Concerns may be raised with a manager or Director, or by email to enquiries@sableandstonerealestate.com.

8. Training and awareness

As Sable and Stone is a newly established business, we are establishing our formal modern-slavery training baseline. During the first reporting period, no training will be described as completed unless it has actually been delivered and recorded.

Our planned training programme will provide role-appropriate awareness to directors, managers, client-facing personnel, finance personnel, property-management personnel and individuals involved in supplier engagement. Training will cover modern slavery and human trafficking; indicators of exploitation; worker vulnerability; responsible recruitment; fair treatment and anti-retaliation; supplier and contractor due diligence; escalation procedures; safeguarding; health and safety; AML and fraud intersections; confidentiality and data protection; and internal and external reporting routes.

Training will be refreshed periodically and following material legal, operational or risk changes.

9. Reporting, response and remediation

Immediate danger

Where there is an immediate threat to life or safety, contact 999 where appropriate and safe to do so and notify a Director as soon as practicable.

Worker, supplier or partner concern

Report the concern promptly to a Director and preserve factual information without conducting an unauthorised investigation.

Property-related concern

Where there is an immediate safety concern, leave or pause the situation where necessary and notify a Director or other appropriate responsible person.

Financial crime or identity concern

Follow the Company's applicable AML and fraud procedures. Do not make unsupported accusations or disclose information where doing so could prejudice an investigation.

Sable and Stone will assess credible concerns promptly and seek specialist advice where necessary. Our response will be victim-centred and safety-led. Depending on the circumstances, action may include safeguarding individuals, obtaining specialist advice, preserving evidence, reporting concerns to appropriate authorities, engaging with suppliers or partners, suspending work, requiring remediation or terminating a relationship where necessary and proportionate.

10. Measuring effectiveness

Sable and Stone will use proportionate measures to assess the effectiveness of its modern-slavery controls. As a newly established business, the first reporting period will focus on establishing a credible baseline.

• Supplier due diligence: percentage of relevant active counterparties subject to completed risk-based checks.
• Contractual controls: percentage of relevant new agreements containing appropriate modern-slavery provisions.
• Training: percentage of relevant personnel completing required awareness training.
• Risk reviews: completion of annual and event-driven risk reviews.
• Concerns: number and type of credible concerns and actions taken.
• Remediation: number of material remediation actions, suspensions or terminations.
• Governance: Board review of the statement and annual improvement plan.

11. Priorities for the next reporting period

During the next reporting period, Sable and Stone intends to:

• implement a risk-based supplier, contractor and partner due-diligence questionnaire;
• establish and maintain a central supplier and contractor register;
• ensure relevant agreements contain appropriate modern-slavery provisions;
• deliver and record role-specific modern-slavery awareness training;
• review higher-risk property-service relationships;
• test the Company's internal reporting and escalation process;
• improve guidance for property-facing personnel;
• monitor and review identified risks; and
• report progress to the Board annually.

These measures represent planned improvements and will be reported as completed actions only once they have actually been implemented.

12. Board approval and director sign-off

This statement is published voluntarily by Sable and Stone Real Estate Ltd as part of its commitment to responsible business practices and transparency. It was approved by the Board of Sable and Stone Real Estate Ltd on 25 August 2026.

Signed on behalf of the Company by Davinder Singh, Director, Sable and Stone Real Estate Ltd. Signed electronically, 25 August 2026.

Legal and regulatory note