THE LANGHAM ESTATE

MODERN SLAVERY ACT 2015 (“MSA”) STATEMENT

FYE 31 March 2025

• Overview

This statement is published by STL UK Group Holdings Limited (“STL“) on behalf it and its subsidiaries, including (but not limited to): Mount Eden Land Limited (“MEL“) (which itself meets the qualification threshold for reporting under section 54 of the MSA) and Langham Estate Management Limited (which provides property management services to MEL and the rest of the Langham Estate). For the purposes of this MSA statement, STL and its subsidiaries are referred to collectively as the “Langham Estate“.

The Langham Estate recognises the importance of ensuring that our business is conducted responsibly. We welcome the MSA and the transparency it encourages and take a zero-tolerance approach to modern slavery occurring in our business or supply chains.

The Langham Estate is committed to ensuring that no one in its own organisation, or our external contractors and suppliers are involved in or profit from modern slavery or human trafficking in any way.

• Business structure

The Langham Estate’s primary business in the UK is focused on the letting of commercial property and consists of the management of a number of commercial property interests in London. In addition to the primary business of letting commercial property, the Langham Estate also operates a boutique hotel and serviced office business.

While our business is not considered to be particularly high risk from an MSA perspective and our supply chains are relatively straightforward and our direct supplier relationships are mainly focused in the UK, the Langham Estate works with a number of different third parties as part of our operations, including our tenants, and is required from time to time to undertake refurbishments, redecorations, and occasional repairs across our portfolio. In doing so, we engage with external contractors and suppliers to carry out the work on our behalf.

• Supply chain and due diligence

The Langham Estate’s upstream and downstream supply chains includes suppliers and contractors in the following sectors:

We have implemented a due diligence process that is designed to limit the risk of modern slavery or human trafficking from arising in in our supply chains. As part of this due diligence process, we review supplier’s responses as part of our procurement and supplier onboarding process, which considers specific country, sector, transaction, and business partnership risks and compliance related policies and procedures (including modern slavery, anti-bribery and health and safety).

Where possible, we build long-standing relationships with our key suppliers and ensure that expectations of business behaviour are clear and consistent. Some contractors and suppliers are appointed to the Langham Estate’s approved list of contractors following additional due diligence carried out by the Langham Estate’s main external property consultant.

Our Supplier Code of Conduct clearly outlines the standards we expect of our suppliers when conducting business. We expect our suppliers to operate fair and ethical workplaces as set out in our ‘Supplier Code of Conduct’.

• Policies and procedures

The Langham Estate maintains and adheres to a dedicated Modern Slavery policy (the “Policy“) which reaffirms our commitment to a zero-tolerance approach to modern slavery occurring in our business or supply chains.

• Implementation

[STL’s board of directors (the “Board“)] take overall responsibility for implementing the objectives considered in this MSA statement.

The Chief Executive Offices (CEO) will monitor progress of our efforts in this area and issues (should they arise) and report back to our Board directly.

• Training

Training is currently provided to employees on a regular basis through a dedicated e-learning module.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Langham Estate’s slavery and human trafficking statement for the financial year ending 31 March 2024.

This statement was adopted by the board of STL in September 2024 The statement was also approved by the board of MEL in September 2024.

Signed on behalf of STL:

Philip Hardie
Chairman
September 2024