Slavery & Human Trafficking

This statement reflects our commitment to be accountable, act vigilant, and with integrity in relation to s54 of the Modern Slavery Act 2015. As an organisation, we take a zero tolerance approach to slavery and human trafficking in our supply chain or in any other part of our organisation.

A risk based approach has been adopted assessing the potential risk for slavery and human trafficking within the organisation and our supply chain. This has resulted in three main areas being identified:

1. Procurement and supply chain
2. Human resources and recruitment
3. Housing management – letting of properties and their utilisation.

We will not enter into any business or associate with any organisation knowingly involved in any form of modern slavery or human trafficking.

We have established a Slavery and Human Trafficking Policy. This policy is aimed at preventing slavery and human trafficking from existing within the organisation and its supply chain and ensures we will:

• Work collaboratively with our supply chain to eradicate slavery and human trafficking
• Identify and manage any key vulnerabilities that could support slavery and human trafficking
• Strengthen our due diligence processes to further enhance the detection of slavery and human trafficking within our supply chain.

The policy complements a number of other policies and procedures in our organisation, including our Whistleblowing Policy, Safeguarding Adults Policy, ‘Something’s Not Right’ Initiative, and the Procurement Code of Practice. Taken together we believe they ensure we have a robust approach to the prevention of slavery and human trafficking.

All of our customers go through the following checks prior to being granted a tenancy:

• Right to residency
• Work/economic status
• Tenancy reference checks and three years housing history.

In addition, subletting is not permitted under the tenancy agreement and all new customers are visited in the first four weeks of any new tenancy.

We have key partnerships in place with agencies, such as the police and local authorities and strive to work together to share intelligence and where necessary take appropriate action to tackle slavery and human trafficking.

Our HR policies and procedures are well established and help prevent unethical employment practices in our organisation. We promote and foster a healthy work life- balance, with wellbeing and employee satisfaction viewed as key priorities. We are also committed to ensuring our employees receive fair remuneration for the job they do, with the support of a job evaluation process and system.

During the recruitment process various checks are completed, including:

• Proof of eligibility to work in the UK
• Disclosure and barring service for appropriate roles.

We require a commitment to the prevention of slavery and human trafficking from all of our suppliers. If a supplier does not have an appropriate policy we ask them to adopt our own. Failure to do so may lead to a supplier not being approved. This approach forms part of our supplier selection process.

Our procurement activities and our contractors and suppliers are predominantly UK based. We expect our suppliers to share our values on modern slavery and also carry out their own due diligence on their supply chains to limit the risk of modern slavery taking place.

We have taken the following steps in relation to our supply chain:

• We regularly update our supplier records in line with our supplier approval process to confirm their business arrangements in terms of modern slavery
• We asked all new suppliers to complete an application which asks them to establish their business arrangements in terms of modern slavery
• We intend to include in our standard terms and conditions a clause relating to the Modern Slavery Act 2015.

We have shared our statement with our suppliers and ask that they abide by the principles of the Modern Slavery Act 2015 and commit to ensuring modern slavery is not taking place in their own supply chains.

To ensure a general understanding of modern slavery and human trafficking across the organisation, we have launched an awareness campaign. The campaign utilises the Home Office’s marketing material and research. This has included messages on computer screens, posters displayed in offices and articles to staff in our weekly briefings.