We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We act ethically and with integrity in all our business relationships and undertake appropriate due diligence to identify and assess potential risk areas and mitigate the risk of slavery and human trafficking occurring.

What is modern slavery? 

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking; all of which have in common the deprivation of a person’s liberty by another or others to exploit them for personal or commercial gain.

Our approach

We exist to provide affordable homes for those in housing need, deliver related support services to vulnerable people and deliver maintenance services. We have charitable status and do not have shareholders, which means that all surpluses generated go back into the delivery of great services, supporting our customers and building new homes. 

Our ethos is reflected in our Equality Policy, which sets out our commitment to equality, diversity, and inclusion in all our dealings as an employer, and provider of housing, support services, community services, and procurement partner. 

Our Board of Directors ensures compliance with the Modern Slavery Act 2015, while all colleagues are responsible for upholding its requirements. 

Here is a round up the steps we take to do this. You can view our statement and action plan in full here.

 

Man with hand tied behind back

Colleague awareness and training

  • Policies and procedures in place to identify and report any safeguarding concerns 
  • E-learning modules on modern slavery and human trafficking are mandatory for all colleagues
  • Dedicated safeguarding panel 
  • Resources are available on our internal intranet and awareness is raised through our internal newsletter and by promotion of Anti-Slavery Day (October 18).

Our supply chains

Last financial year we spent around £30 million on contracts and services with around 700 contractors who are predominantly based in the UK. We work with a number of consortia and frameworks and have procurement processes that are UK-compliant and a contractor code of conduct. 

  • Procurement questionnaire requires new suppliers to declare that they are not and have not been involved in slavery or human trafficking
  • Provisions in our template contract documents require suppliers to take appropriate steps to ensure that there is no slavery or human trafficking in their supply chains
  • Assess any evidence of non-compliance and take appropriate remedial action.

Human resource (HR) practices

  • Strict 'Right to Work in the UK' checks for all employees
  • Policies reviewed every three years and communicated by colleague briefing
  • Consult with our colleague forum which includes representatives from across the business
  • Temporary workers sourced from reputable agencies that comply with anti-slavery requirements 
  • National Living Wage paid to all employees except those completing apprenticeships
  • Health and safety group ensures compliance within business and supply chain. 

Principal risks, mitigations, and actions

We consider our principal risks as:

  • smaller contractors or work which is sub-contracted in our supply chain
  • customers impacted by modern slavery and human trafficking

These risks are mitigated by our action plan and existing procedures and policies.

If you think someone is at risk through modern slavery, we encourage you to:

  • Call 999 if it’s an emergency
  • Call 0800 0121 700 for help and advice any time (free from landlines and most mobiles) 
  • File a report at: modernslaveryhelpline.org/report - you can do this anonymously if you are scared to give your name

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