This Statement is prepared on behalf of Whistler UK Bidco Limited (“Wildstone”)and subsidiaries (known as the “Wildstone Group”) in accordance with Section 54, Part 6 of the Modern Slavery Act2015 (the Act).
At Wildstone, we are committed to upholding ethical and responsible business practices. As part of Wildstone’s commitment to human rights and social responsibility, a Modern Slavery Policy was adopted in November 2023, to eliminate any form of modern slavery or human trafficking from our operations and supply chains. We believe in promoting transparency, fairness, and dignity for all individuals involved in our business, including employees, suppliers, contractors and partners.
We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our contractors, suppliers and other business partners will hold their own suppliers to the same high standards.
Please send any written requests for information on this Statement to office@wildstone.co.uk and your request shall be responded to within the timeframes set out in the applicable law.
The United Kingdom Modern Slavery Act came into effect in October 2015. This Act requires commercial organisations doing business in the UK that supply goods or services and have an annual turnover exceeding £36 million to publish an annual statement addressing the measures taken to mitigate the risk of modern slavery.
Environmental, Social and Governance matters, including human rights policies and procedures, are overseen by Wildstone’s Board of Directors. Risk, including in relation to ESG matters, is overseen by Wildstone’s Senior Management Team.
Wildstone adopted its Modern Slavery Policy on the 10th of November 2023.
Wildstone Group is an outdoor media infrastructure business that acquires and rents property assets for outdoor advertising in Australia, Germany, Ireland, the Netherlands, Spain and the United Kingdom.
Wildstone procures goods and services from a limited supply chain in each of the countries it operates in, which can be summarised as follows:
- Professional services (i.e. lawyers, accountants, planning consultants etc);
- Principal contractors to install and maintain traditional and digital outdoor media infrastructure, install power and associated works (e.g. hard and soft landscaping); and
- Suppliers of outdoor media infrastructure (i.e. digital screens and ancillary infrastructure and traditional outdoor infrastructure such as paper and paste and backlight panels)
Wildstone seeks to ensure that legal agreements with third parties require them to comply with applicable human rights, modern slavery and labour laws and we do not knowingly contract with suppliers engaged in any practice of child labour or human trafficking.
Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.
Our supply chains are limited due to the size of the operations in each country and the nature of our operations. We procure goods and services from a restricted range of Australian, UK and EU based corporate suppliers. The only suppliers we use outside of Australia, UK and EU are our digital screen suppliers in China.
We have introduced a Pre-Qualification Questionnaire (PQQ) which all principal contractors for maintenance and installation contracts need to complete before they can be added to Wildstone’s contractor frameworks. The Pre-Qualification Questionnaire incorporates questions on modern slavery.
Wildstone introduced training to raise awareness and ensure that all staff have a basic level of understanding of modern slavery and what to look for in their respective roles. For all existing staff, Wildstone rolled out basic training in 2024 and a requirement that all new staff complete the training as part of their inductions. It is intended to update training for key staff involved in procurement and dealing with our supply chain on an annual basis.
In 2023 we introduced an independent whistleblowing service provided by WhistleB. The whistleblowing service can be used anonymously to alert us about serious risks of wrongdoing affecting people and our organisation. The service can be used by internal and external parties to alert Wildstone to risks including human rights abuses.
Wildstone has assessed the risk of modern slavery from our supply chain in Australia, UK and EU to below given the highly regulated nature of the locations in which the Group companies operate.Nonetheless, Wildstone has instigated a supplier questionnaire (the ‘Supplier Questionnaire’) to understand the companies we are contracting with and the workers within our supply chain in order to assess risk at a company level.
Our only major supplier not based in Australia, UK or EU is our digital screen supplier who is a private owned company based in Shenzhen, People’s Republic of China. China has a vulnerability score of 46(out of 100) based on the Walk Free global slavery index and the UN has identified widespread evidence of state-sanctioned modern slavery in Tibet and Xinjiang, China, homeland of the Tibetans and Uyghurs.
Prior to entering into a manufacturing and supply agreement with this party, Wildstone undertook inspections of its manufacturing and workers facilities. Wildstone undertook inspections of the manufacturing facility in November 2024 and employed the Freeman Consultancy (a specialist screen procurement consultancy) to undertake a review of its processes and supply chain.
The due diligence steps undertaken by Wildstone did not identify any indications of modern slavery or forced labour in our supply chain. Should Wildstone seek to procure screens from other suppliers, we would undertake similar due diligence exercises.
Wildstone has adopted the following policies relevant to this statement:
- Modern Slavery Policy
- Whistleblowing Policy
We will continue to monitor working conditions in our supply chain through the following:
- Providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking;
- Requiring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK;
- Ensuring that consideration of modern slavery risks and prevention are added to Wildstone’s policy review process as an employer and procurer of goods and services;
- Continuing to take action to embed a zero-tolerance policy towards modern slavery; and
- Requiring staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices.
Wildstone’s Board requires all its portfolio companies to report on ESG related KPIs in addition to financial KPIs.
- This includes a requirement to report any material ESG incidents involving the company’s key suppliers or contractors (e.g. environmental pollution incidents, labour right violations, corporate scandals, etc.)