This statement is published in accordance with the Modern Slavery Act 2015. It refers to the risks of slavery in our business and supply chain and how we mitigate those risks through effective management, policies and procedures.
As consultants, specialising in public-private partnerships, placemaking and economic regeneration, establishing and managing Business Improvement Districts (BIDs), Community Improvement Districts (CIDs), Community Interest Companies (CICs) and similar structures, the inherent risk of slavery is low.
Primera Corporation Limited (Primera) has seen significant growth in recent years, and our spend with suppliers has increased proportionately, notwithstanding the majority is through separately registered not-for-profit companies that are managed by Primera rather than direct procurement.
In 2024, our total spend with third parties, direct and through the portfolio of managed companies, was in the region of £15m. This spend was with contractors providing a broad range of event services, membership organisations, professional advisors, consultants and agencies, all of whom may support Primera’s consulting business and the delivery of activities overseen by Primera across the portfolio of managed companies.
The highest risk of modern slavery within our supply chain is with companies providing services including cleaning and street cleansing and waste management services. The higher risk is due to the nature of work which can attract workers who might be more susceptible to mistreatment. Risk is mitigated through diligent procurement practices and contract management and working with suppliers that are aligned with Primera in terms of policy and ethical standards.
We work with contractors on a range of projects, installations and activations where we occasionally rely on them to source and purchase materials through their own supply chains. Some of these materials may be sourced from countries with less stringent labour practices and employment laws than the UK. Risk is mitigated through procurement, policy enforcement and promotion of ethical standards.
For Primera, the two Shareholders are ultimately accountable. For the portfolio of not-for-profit companies managed by Primera, including; Culture Mile, Fleet Street Quarter, EC BID, The Aldgate Partnership, Cheapside Business Alliance, Hatton Garden BID, Central District Alliance, Harley Street BID, Long Acre, Old Street and City Riverside Partnerships, Primera is partly accountable as defined in obligations set out in management agreements, however, the Board of Directors for each company is ultimately responsible for sustainability, including procurement, supply chain management, modern slavery and compliance in general.
Primera’s Group Chief Operating Officer (Group COO) is responsible for drafting and implementing our strategy and any related procedures, policies or statements, this is done with the support of the Shareholders. The aim is to ensure that we identify, prioritise and manage our risks, and for dissemination or information to the staff and other stakeholders. Primera employees assigned to each not-for-profit company, i.e. those operating a BID, Partnership or similar vehicle, are responsible for following procedures, delivering actions as directed, and for operating each BID company in accordance with standards set and for highlighting any issues or concerns to the Group COO.
Over the course of the next 12-months, we intend to fully embed our standardised procurement guides and tender processes, moving more procurement activity to a central place (with stakeholder agreement), which may reduce the number of suppliers used, drive efficiency and cost savings and facilitate closer scrutiny of prospective and current partners and their respective supply chains.
This policy applies to all company activities which Primera can directly control. Where we have influence rather than control, we will encourage the uptake and adoption of this policy and related policies and practices.
This policy will be reviewed annually and made available to stakeholders. It is supported by a number of supplementary policies and procedures.
The Group Chief Operating Officer is responsible for the operation of this policy.