Slavery and Human Trafficking Statement

We have chosen to publish this statement regardless, because the Group is being established to operate in a sector — the provision of supported and exempt accommodation — where the people we support are, by definition, among the more vulnerable members of society, and because the trades we expect to engage to renovate and maintain our properties operate in an industry where labour exploitation is a recognised risk. We believe transparency on this issue is a basic part of operating responsibly, and we intend for our practice to meet or exceed the standard expected of much larger organisations as we grow.

1. Organisation Structure and Business

Northstar Investment Partners Limited (company number 17356274) is the capital and governance holding company for the Group. Northstar is being established to provide capital and governance for supported and exempt housing accommodation in England, delivered operationally through one or more subsidiary entities currently in the process of being established.

Northstar expects to work alongside independent delivery partners, including specialist community interest companies, who will provide frontline support work, youth engagement, and life-skills programmes to residents. These partners are not, and are not expected to become, subsidiaries of Northstar, and are separately responsible for their own compliance with the Act; we address our approach to working with them under “Our Supply Chains” below.

At the date of this statement the Group employs a small number of directors directly. We expect the size and structure of the Group to change materially over the coming months and years as our operating subsidiary is established and as we scale from our current base to a larger, multi-region operation, and we will review and update this statement to reflect that growth.

2. Our Supply Chains

Given our sector, we expect our most significant third-party relationships, and where we consider our modern slavery risk exposure will principally arise, to be:

• Building and refurbishment contractors: tradespeople and contracting firms engaged to renovate, convert, and maintain properties before and during occupation, including general building, electrical, plumbing, and decorating work.
• Property-related suppliers: furnishing, white goods, and materials suppliers used to fit out properties to a habitable standard.
• Facilities and maintenance services: cleaning, gardening, and reactive maintenance contractors servicing occupied properties.
• Recruitment: any agencies or platforms used to source directly employed staff or contracted labour.
• Delivery partners: independent organisations providing support-work and life-skills services to residents under contract or partnership arrangement.

We recognise that the construction and refurbishment trades are widely identified, including by the Home Office and the Gangmasters and Labour Abuse Authority, as a higher-risk sector for labour exploitation, including within subcontracted and casual labour arrangements. We treat this as our primary area of continuing attention rather than a box-ticking exercise.

3. Our Policies on Slavery and Human Trafficking

We are committed to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to guard against modern slavery taking place anywhere in our own operations or supply chains. As the Group grows, we are embedding this commitment through:

• A Group anti-slavery and human trafficking policy, setting expectations for staff and for any contractor or supplier engaged by the Group.
• A whistleblowing route enabling staff, contractors, and residents to raise concerns confidentially, without fear of reprisal.
• Contract terms with building, refurbishment, and facilities contractors that require compliance with UK employment and immigration law, including right-to-work checks on any workers they engage.
• A recruitment and right-to-work verification process for all directly employed and directly contracted staff.

4. Due Diligence

Before engaging a new building, refurbishment, or facilities contractor, we take steps proportionate to the size of the engagement, including confirming the contractor's registered business status, seeking references or evidence of prior work, and, for larger or ongoing engagements, asking contractors to confirm their own compliance with the Modern Slavery Act where they meet the statutory threshold, or to confirm their labour practices where they do not.

Where we engage delivery partners to provide support work to residents, we satisfy ourselves as to their own safeguarding, HR, and compliance practices as part of onboarding them as a partner, given the vulnerability of the people they will be working with.

5. Risk Assessment and Management

We assess our most significant modern slavery risk as sitting in subcontracted and casual labour within the building and refurbishment trades, reflecting well-documented sector-wide risk rather than any specific concern about a current contractor. A secondary area of attention is the vulnerability of the residents we support, which is why our due diligence on delivery partners focuses on safeguarding as well as on employment practice.

We have not identified any incidents of modern slavery or human trafficking within our own operations or supply chains during the period covered by this statement.

6. Training

Directors and staff involved in engaging contractors, suppliers, or delivery partners are made aware of the indicators of modern slavery and labour exploitation relevant to our sector, and of the whistleblowing route available if they have concerns.

7. Looking Ahead

This statement reflects the size and stage of the Group as at the date of publication. As Northstar's operating subsidiary is established and the Group grows, we intend for our modern slavery practice to keep pace with that growth, and we will review this statement at least annually.