1. Purpose
This policy sets out the Group's approach to owning, acquiring, leasing, letting, occupying, managing, altering and exiting commercial property and business premises in the United Kingdom.
The purpose is to reduce legal, financial, tax, health and safety, fire, energy, environmental, planning, landlord, tenant, insurance, fraud, sanctions and operational risk connected with UK commercial premises.
This policy does not replace transaction-specific legal, tax, surveyor, fire, environmental, planning, insurance or health and safety advice. Property commitments must be assessed on their facts.
2. Scope
This policy applies to Murzo Group Ltd and all subsidiaries, controlled entities, divisions, brands, branches, projects, premises, assets and operations in the United Kingdom.
It applies to freehold, leasehold, licence, serviced office, coworking, storage, farm, warehouse, shop, showroom, studio, workshop, laboratory, yard, office, food premises, collection storage, mixed-use, short-term occupation, subletting, assignment and facilities arrangements.
It applies where the Group is buyer, seller, owner, landlord, tenant, occupier, licensee, licensor, managing party, subtenant, guarantor, funder, agent, facilities manager or party with control over any part of a premises.
3. UK Jurisdiction Differences
Property law, land registration, transaction taxes, business rates, fire safety, building safety, landlord duties, energy rules and enforcement routes can differ across England, Wales, Scotland and Northern Ireland.
References to UK property in this policy must therefore be applied with local advice where the premises, land, lease, transaction, tax or enforcement authority sits outside England or Wales.
4. No Property Commitment Without Authority
No person may buy, sell, lease, surrender, assign, sublet, licence, occupy, mortgage, charge, guarantee, alter, fit out, insure, store goods in, let to others, or commit the Group to a property arrangement without written approval from authorised representatives.
Heads of terms, exclusivity agreements, deposits, option agreements, letters of intent, early access letters, fit-out commitments, side letters, rent-free periods, break clauses and service charge arrangements may create legal or financial risk and must be reviewed before commitment.
5. Acquisition and Lease Due Diligence
Before acquiring, leasing or occupying a UK commercial property, the responsible person should consider the property title, lease terms, boundaries, easements, covenants, restrictions, mortgages, charges, rights of way, access, services, utilities, drainage, planning status, lawful use, building condition, environmental condition, flood risk, contamination risk, heritage restrictions, insurance, tax, rates, VAT, service charges, landlord controls and exit rights.
Due diligence should be proportionate to value, use, duration, public access, staff exposure, stock value, operational importance, safety risk, environmental risk and whether the site will hold food, chemicals, insects, animals, cultural objects, high-value goods, confidential data, vehicles or controlled items.
6. Title, Registration and Ownership
Freehold and registrable leasehold interests in England and Wales must be assessed through HM Land Registry processes. Equivalent local registers and procedures apply in Scotland and Northern Ireland.
The Group must check whether ownership, transfer, mortgage, charge, lease, easement, restriction, rentcharge, overage, option, pre-emption, beneficial ownership or security arrangement requires registration, consent, notice, filing or lender approval.
Longer leases may require registration. Shorter leases may still need review, noting or protection depending on the structure and risk.
7. Lease, Licence and Occupation Controls
Every lease, licence or occupation arrangement should clearly allocate rent, service charge, insurance, repairs, decoration, maintenance, rates, utilities, VAT, deposits, guarantees, permitted use, access, security, assignment, subletting, alterations, signage, fit-out, reinstatement, break rights, rent review, renewal rights and exit obligations.
The Group must understand whether a business tenancy has statutory security of tenure or has been validly contracted out, and whether any side letter, concession or informal occupation could change the legal position.
Informal occupation, key handover, storage, early access, shared space use or verbal licence arrangements must not be treated as low risk merely because no formal lease has been signed.
8. Landlord Responsibilities
Where the Group is landlord, licensor, superior tenant, managing party or party controlling common areas, it must understand its responsibilities for the premises, common parts, services, fire safety, health hazards, statutory notices, repairs, insurance, energy performance, access, safety information, service charge administration and tenant communications.
The lease and local law will usually decide who is responsible for specific repair and safety matters, but the Group must not ignore a serious hazard merely because a tenant, contractor, managing agent or insurer is also involved.
Residential or mixed-use property may trigger additional landlord, housing, tenancy deposit, right to rent, fire, licensing, service charge and building safety duties and must be reviewed separately.
9. Tenant and Occupier Responsibilities
Where the Group is tenant, licensee or occupier, it must identify the duties it controls. These may include workplace risk assessment, fire safety, electrical equipment safety, gas equipment maintenance, asbestos management, safe plant and equipment, toilets and washing facilities, drinking water, lighting, ventilation, reasonable temperature, cleaning, waste, access control and staff welfare.
The Group must take reasonable steps to make sure the landlord, managing agent or building owner fulfils responsibilities allocated to them, especially for common areas, shared fire systems, access routes, structural matters, asbestos information, lifts, utilities and landlord-controlled services.
10. Fire Safety and Responsible Persons
In business and other non-domestic premises, responsibility for fire safety may sit with an employer, owner, landlord, occupier, facilities manager, managing agent or another person with control of the premises.
Where more than one responsible person exists, they must cooperate and coordinate. Common or shared areas may involve the landlord, freeholder or managing agent, while the Group may control its own demise, staff, stock, equipment, visitors and work activity.
Fire controls should include a suitable fire risk assessment, emergency plan, clear escape routes, alarms, detection, extinguishers, signage, lighting, staff information, instruction and training, and review after changes or incidents.
11. Building Safety and Higher-Risk Buildings
Before acquiring, leasing, occupying or managing premises in or connected with a higher-risk building, multi-occupied building, mixed-use building or building with residential parts, the Group must identify any building safety, accountable person, responsible person, fire safety, resident information, golden thread, safety case, remediation, cladding, evacuation, access or regulator obligations.
Fit-outs, refurbishment, structural works, fire-door changes, service penetrations, compartmentation changes, alarm changes and occupation changes must not compromise building safety, fire stopping, evacuation or statutory compliance.
12. Asbestos Management
Where asbestos may be present in commercial premises, the Group must identify who has the duty to manage asbestos under the lease, contract or control arrangements.
Controls may include an asbestos survey, asbestos register, management plan, risk assessment, condition monitoring, contractor information, restricted access, safe removal or encapsulation, and emergency response where asbestos-containing material is damaged or disturbed.
No work may disturb suspected asbestos unless competent advice has confirmed a lawful and safe method.
13. Energy Performance, EPC and MEES
Before selling, letting, acquiring or renewing a lease of non-domestic premises, the Group must check whether an Energy Performance Certificate is required and whether minimum energy efficiency standards apply.
For non-domestic private rented property in England and Wales, landlords generally must not let, renew or continue to let relevant property below EPC band E unless a valid exemption is registered or the property is outside scope.
EPC ratings, exemption status, improvement obligations and lease wording should be reviewed before acquisition, letting, renewal, assignment, subletting, fit-out or change of use.
14. Planning, Building Control and Lawful Use
Planning permission or other local authority approval may be required for new buildings, major alterations, extensions, change of use, signage, external plant, extraction, food preparation, agricultural use, storage, public access, events, listed buildings, conservation areas, highways access, waste areas or environmental controls.
Work must not proceed on the assumption that a previous use, landlord consent, estate agent description, business rates listing, insurance quote or online listing confirms lawful planning use.
If enforcement action is threatened or served, the matter must be escalated promptly and work or occupation may need to stop, change or be regularised.
15. Business Rates, Property Taxes and VAT
Commercial premises may attract business rates, transaction taxes, capital allowances questions, VAT, option-to-tax issues, capital gains or corporation tax issues, service charge VAT, insurance premium tax, utilities charges, landlord charges and local authority fees.
In England and Wales, the Valuation Office sets rateable values used by local councils to calculate business rates. The 2026 revaluation took effect on 1 April 2026 and should be considered for budgeting and challenge decisions.
SDLT generally applies in England and Northern Ireland above relevant thresholds, while Wales and Scotland have separate land transaction tax regimes. Specialist tax advice should be taken before material acquisitions, leases, linked transactions, premiums, assignments, surrenders, rent changes or property disposals.
16. Repairs, Maintenance and Dilapidations
Repairing obligations must be understood before signing a lease or taking occupation. Full repairing and insuring leases, schedules of condition, service charge clauses, landlord works, tenant works, reinstatement clauses and dilapidations risk can create significant liabilities.
The Group should consider surveys, photographs, schedules of condition, planned maintenance, landlord approvals, contractor competence, warranties, defects, utilities, roof, structure, drainage, plant, lifts, fire systems, asbestos, damp, pests and contamination before commitment.
17. Health, Safety, Welfare and Accessibility
Premises must be suitable for the intended work and the people who may use them. This includes safe access, workplace welfare, lighting, ventilation, temperature, toilets, washing facilities, drinking water, safe equipment, manual handling, slips and trips, emergency arrangements, first aid, lone working and security.
Where customers, visitors, candidates, tenants or the public access premises, accessibility and equality duties must be considered, including reasonable adjustments where legally required and practical.
18. Food, Farming, Chemicals and Specialist Premises
Food handling, kitchens, storage, farming, live insects, animals, plants, soil, compost, chemicals, cleaning products, waste, laboratories, workshops, vehicle storage, machinery and security-sensitive activity may require enhanced premises review.
Relevant controls may include food business registration, hygiene, pest control, drainage, ventilation, extraction, temperature control, COSHH, environmental permits, waste controls, biosecurity, fire loading, insurer approval, product segregation and local authority inspection.
19. Environmental, Utilities and Waste Controls
Property decisions should consider contamination, flood risk, drainage, trade effluent, water hygiene, legionella risk, waste storage, hazardous waste, pest control, noise, odour, emissions, energy use, refrigerants, fuel storage, batteries, electric vehicle charging, landlord utilities, metering and environmental permits.
The Group must not accept premises where environmental risk, unsafe utilities, unlawful discharge, contamination, hazardous waste or insurance exclusions cannot be understood and controlled.
20. Contractors, Fit-Out and Works
Contractors, designers, builders, maintenance providers, facilities managers, surveyors and consultants must be competent for the work and must follow site rules, health and safety requirements, fire controls, permit-to-work controls, insurance requirements, landlord consents and building control requirements.
Construction, refurbishment, demolition, maintenance or fit-out works may trigger CDM and other duty-holder obligations. The Group must define who is client, principal designer, principal contractor, contractor and site controller where those roles apply.
21. Security, CCTV and Sensitive Assets
Premises used for high-value goods, cultural objects, confidential documents, IT equipment, drones, cameras, servers, fashion stock, food, chemicals, controlled items, vehicles, tools or customer property require proportionate security controls.
Controls may include access control, key management, alarms, CCTV, visitor logs, secure storage, inventory checks, insurance approval, cybersecurity for building systems and prompt removal of access when roles change.
22. Subletting, Assignment and Third-Party Occupation
The Group must not assign, sublet, share occupation, grant a licence, allow storage, permit pop-up trading, host third-party events or allow another business to operate from premises unless the lease, title, insurance, planning, fire, health and safety, sanctions, AML, tax and landlord consent position has been checked.
Where the Group remains tenant or guarantor, it may remain liable to the landlord even if the subtenant, assignee, licensee or occupier fails to pay, damages the premises, breaches planning rules, creates a safety risk or trades unlawfully.
23. Fraud, AML, Sanctions and Property Payments
Property transactions create risk of fraud, bribery, AML, sanctions, identity misuse, false ownership, fake bank details, forged documents, hidden beneficial ownership, inflated valuations, undisclosed commissions, nominee structures and property-related tax evasion.
Counterparties, landlords, tenants, agents, beneficial owners, lenders, buyers, sellers and payees must be checked where risk requires. Bank details and completion monies must be verified through trusted routes before funds move.
24. Notices, Enforcement and Regulator Contact
Legal notices, break notices, rent review notices, forfeiture notices, dilapidations claims, planning notices, fire safety notices, improvement notices, environmental notices, business rates notices, insurer conditions, landlord notices and authority enquiries must be escalated promptly.
Only authorised people may admit liability, settle a claim, agree works, accept a notice, serve a notice, surrender a lease, instruct litigation, speak to authorities on formal matters or make public statements about a property incident.
25. Exit, Surrender and Disposal
Exit planning must consider notice dates, break conditions, rent, service charge, insurance, dilapidations, reinstatement, removal of goods, confidential information, waste disposal, utilities, keys, access credentials, signage, customer notices, employees, subtenants, rates, tax, licences and continuing guarantees.
Returned, abandoned, contaminated, unsafe, unsellable, confidential or regulated items must be removed, destroyed, donated, sold or disposed of lawfully and in line with relevant Group policy.
26. Evidence and Legal Hold
Property evidence should be limited to what is reasonably needed for legal compliance, transaction management, finance, tax, insurance, safety, maintenance, dispute handling, notices, audits or legal hold.
Evidence may include approvals, heads of terms, leases, title documents, searches, surveys, planning documents, EPCs, asbestos information, fire risk assessments, service charge information, insurance, rates, tax advice, contractor evidence, maintenance records, photographs, notices and exit files where relevant.
27. Accountability
Failure to comply with this policy may result in withdrawal of authority, refusal of reimbursement, contract remedies, disciplinary action, insurer notification, regulator notification, law enforcement referral, recovery action or other lawful action.
Deliberate concealment of property defects, unauthorised occupation, unauthorised subletting, false property documents, unsafe premises use, unlawful works, bribery, sanctions evasion, unauthorised notices or misuse of Group premises may be treated as serious misconduct or contractual breach.
28. Relationship With Other Policies
This policy should be read with the Real Estate Acquisition, Leasing and Facilities Management Policy, Building Safety, Fire Safety and Occupied Premises Policy, Health, Safety and Wellbeing Policy, Records Retention and Legal Hold Policy, Tax Governance and Compliance Policy, Contract Approval, Signing Authority and Delegations Policy, Supplier Approval, Procurement and Due Diligence Policy, Anti-Bribery and Corruption Policy, Fraud Prevention and Economic Crime Policy, High-Value Goods, Anti-Money Laundering and Source of Funds Policy, Export Controls and Sanctions Compliance Policy, Environmental policies, Food Safety policies, COSHH / Chemical Safety Policy, CCTV, Surveillance and Body-Worn Camera Policy, Cybersecurity and Data Breach Policy, and Insurance and Liability Disclosure Statement.
