Companies Policies

Data Collection and Purpose

Our organization collects personal data from customers, employees, and contractors for the purposes of providing and managing our Passenger Chauffeur Service, Logistics Transport Service, Personnel Parcel Delivery Service, and Property Facilities Clearance Service. This data may include names, addresses, contact details, vehicle information, delivery locations, payment information, and employee/contractor details such as qualifications and background checks (where legally required and with consent). We process this information to fulfill service requests, manage bookings, optimize routes, ensure secure deliveries, process payments, maintain accurate records, comply with legal obligations, and communicate service updates. We may also use anonymized and aggregated data for statistical analysis and service improvement.

Data Sharing and Disclosure

We may share personal data with third-party service providers who assist us in delivering our services, such as payment processors, mapping and navigation services, and IT support providers. We ensure that these third parties have appropriate data protection measures in place and are contractually obligated to process data only for the purposes we specify. We will not sell or rent personal data to third parties for marketing purposes. We may disclose personal data if required by law, court order, or other legal process, or to protect our legitimate interests, such as in the event of a legal claim. For our Personnel Parcel Delivery Service and Property Facilities Clearance Service, specific data may be shared with recipients or relevant property owners as necessary for service completion.

Data Security and Retention

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, use, alteration, or disclosure. These measures include encryption, access controls, regular security assessments, and staff training on data protection best practices. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, taking into account legal and regulatory requirements. Data retention periods are regularly reviewed and updated. For employee and contractor data, retention will comply with UK employment law. After the retention period expires, data is securely deleted or anonymized.

Data Subject Rights

Individuals have the right to access, rectify, erase, restrict processing, and object to the processing of their personal data.

They also have the right to data portability, allowing them to obtain a copy of their data in a structured, commonly used, and machine-readable format. Requests to exercise these rights should be submitted in writing to our Data Protection Officer, whose contact details are available upon request. We will respond to requests within one month. Individuals also have the right to lodge a complaint with the Information Commissioner's Office (ICO) if they believe their data rights have been violated.

Modern Slavery Act 2015

JILIT Limited Statement 2025/26

This statement sets out the steps that JILIT Limited has taken to provide assurance that slavery and human trafficking are not taking place within its supply chains and its own business.

As the government’s housing and regeneration agency, we believe that affordable, quality homes in well-designed places are key to improving people’s lives. Together with our partners, we are accelerating the pace of house building and regeneration across the country, as we seek to deliver homes and places people are proud to live in – for generations to come.

Our Investment and Development models support housing and economic growth using delivery partners, including registered providers of social housing, house builders and developers in both the public and private sector; and direct intervention by providing loans to builders and developers, including small and medium-sized enterprises (SMEs).

JILIT Limited occasionally undertakes activities by partnering with local authorities and developers within a special purpose entity or joint venture partnership organisation and often, where appropriate, we will undertake direct development using delivery partners or construction companies procured for that purpose.

JILIT Limited aims to provide a rewarding working environment in which people are valued and respected. We have a strong commitment to diversity, equity and inclusion and look after the wellbeing of our people, ensuring that they are safe and cared for appropriately. Good corporate citizenship and corporate responsibility are important parts of our identity, as a public body, and employer. We set out the ethical standards we expect of our colleagues to demonstrate, outlined in various policies, including our Declarations of Interest Policy published on our digital platform, Net Consent. Our policies and procedures aim to ensure that we create a safe and inclusive working environment for our colleagues. Our Net-Consent content contains policies and procedures including:

• Whistleblowing Policy.
• Dignity and Respect at Work Policy;
• Diversity, Equality, and Inclusion Strategy

JILIT Limited maintain several professional services and development framework agreements, with our framework partners and these are made available to the wider public sector. We also maintain many other frameworks for exclusive use including site security and legal services. The scope of our procurement activities is summarised at Appendix A.

Our Earlier Statements concentrated on the risk associated with third party procurement activities, including land sales to large house builders or developers. As each large company is required to comply with the Modern Slavery Act (the Act) JILIT Limited has historically placed significant reliance on their own supply chain risk assessments and activity monitoring.

Over the past 7 years, JILIT Limited’s business activities have significantly expanded, along with our understanding of modern slavery risk across the construction sector. Our assessments have determined that:

• Our primary risk is through a delivery partner, framework participant or investment recipient, regardless of size, with an ambiguous or non-compliant supply chain; and
• Where we provide loans to SMEs, our assessment has identified a specific risk in certain foreign supply chains, as noted below.

Our analysis has reconfirmed that our primary risk is an association with a delivery partner, framework participant or company with an ambiguous or non-compliant supply chain. Continued assessment of our risk environment indicates that our primary risks remain constant and our controls to mitigate against these risks whilst mature and should be agile to respond and always evolving.

Evaluation of information provided by His Majesty’s Government (HMG), Non-Governmental Organisations (NGOs), Gangmasters and Labour Abuse Authority (GLAA) and law enforcement agencies, together with open-source material, continues to allow us to further focus our response to modern slavery - by concentrating resources on our sites in those geographical hot spots where it is considered most prevalent.

JILIT Limited approach has been to widen our risk assessment across business lines, benchmarking our activities and policy statement with other organisations with similar supply / reputation risk issues and engage with leading anti-slavery organisations.

JILIT Limited has conducted a review of its Modern Slavery Policy (published April 2023) and current statement against our activities. Our intention is to establish whether our approach follows emerging best practice, by assessing and interpreting recent and/or emerging case law and best practice, including a review of the Transparency in Supply Chains provision in the Act, and Cabinet Office procurement directives.

Our approach ensures we have a clearer understanding of the supply chain risks across our business lines:

• Established that SME participants are at a higher risk in certain component supply chains. To support investment decisions, applicants are required to provide a Project Delivery Plan, which enables us to discuss and clarify supply chain anomalies.
• Re-affirmed compliance requirements with the Act in our tender and procurement documentation.
• Reviewed existing compliance conditions in existing contracts and agreements, including termination clauses.
• Identified how we can continue to use our framework panel of compliance and monitoring surveyors to provide escalation and notification of suspicious activity or welfare concerns.
• Engaged with multi-industry leads on modern slavery and will continue this engagement to keep up to date with current trends, evolving risks and to share best practice. We will:
  • Continue to be vigilant when assessing areas of potential risk within our supply chain, and that our delivery partners, framework participants, investment and grant recipients act with comparable zeal.
  • Increase awareness with third parties we engage with, by promoting and signposting industry led on-line guidance and compliance tool kits to them - as supplied by the Chartered Institute of Building (CIOB) the Royal Institute of Chartered Surveyors (RICS) and others.
  • Continue to provide training and raise awareness - both internally and externally - and help in the identification of new areas of risk arising from our wider business activities.
  • Increase our understanding of risk within the sector; and, specifically, SME and equity participation risk. To succeed, we will examine all available information provided by law enforcement agencies and NGO partners; and
  • Work collaboratively with other organisations across the sector, to identify additional methods to promote and support the government’s aim to eradicate the injustice and brutality of modern slavery and human trafficking. Ongoing monitoring will enable us to identify our sites and SMEs that are of a higher risk of modern slavery and to tailor our activities and support those risk hotspots. Homes England’s contractual arrangements, require monitoring surveyors and portfolio managers to function as the Agency’s ‘eyes and ears’ when checking development progress; and the Anti Economic Crime team (AEC) provides guidance and clarity on how to report suspicious activity or welfare concerns.

The potential risk of Modern Slavery arises from the following key scenarios:

• The risk that we procure goods or services for our own consumption where there is an unethical supply chain.
• The risk that we partner alongside organisations with an unethical supply chain, or we engage, invest, lend, or sell land to organisations with an unethical supply chain. We mitigate these risks by:
  • Using monitored framework panels/suppliers demonstrating compliance with the requirements of the Act.
  • Up-front compliance requirement in our tender and procurement documentation, enforced at delivery by contractual conditions and agreements; and including appropriate termination clauses. This is supported by pre-procurement dialogue and monitoring throughout the duration of the contract.
  • Customer due diligence research to identify organisations and individuals with criminal convictions or a higher potential risk of non-compliance.
  • Requiring applicants to provide details of their development scheme; this provides us with an opportunity to identify potential supply chain risks within the development specifications.
  • Introducing and continually assessing procurement processes and procedures and supplier due diligence - including Homes England’s contractual arrangements, with the inclusion of a mandatory undertaking from our contractors that they will comply with the provisions of the Act.
  • Confirmation of the applicability and enforceability of clauses and conditions included in our legal agreements and contracts.
  • Requesting management information from our panel firms in relation to the training they provide both internally, to their staff, and externally, to their contractors. This information has provided Homes England with assurance that we are able to measure the compliance of our contractors against our procurement controls.

For those companies with whom we engage but who do not produce an annual modern slavery statement, due to their turnover being below £36 million, we request that they produce a statement detailing that they have considered their obligations regarding the suitability of their workforce and supply chains, and the risk of Modern Slavery and exploitation in their supply chains. This is consistent with the recommendations contained in the independent review of the Act.

We recognise that Modern Slavery is a crime and a violation of fundamental human rights. We are aware that Modern Slavery takes various forms, including slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.

JILIT Limited continues to adopt a zero tolerance to modern slavery, human trafficking, all forms of servitude and forced and compulsory labour. Modern Slavery is the term used within the UK and is defined within the Act. The Act categorises offences of Slavery, Servitude and Forced or Compulsory Labour and Human Trafficking (the latter of which comes from the United Nations’s Palermo Protocol).

JILIT Limited fully supports the government’s objectives to eradicate all forms of modern slavery and human trafficking, and we will continue to set high standards of impartiality, integrity, transparency, and objectivity. We will ensure that our activities and those of our contractors operate to the highest ethical standards, operating under sound governance arrangements. Our annual statement provides details of our activities, supply chains and actions we continue to take to support government in its aim to eliminate modern slavery.

We require all organisations we engage with to ensure their goods, materials, and labour- related supply chains:

• Fully comply with the Act; and
• Are clear, transparent, accountable, and auditable.

We call upon all organisations we engage with to influence their global supply chains by improving transparency, accountability, and training, so that together, we can help the government and our society to eradicate the injustice and brutality of modern slavery and human trafficking.