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Modern slavery statement 2019/20
Modern Slavery is the term used within the UK and is defined within the Modern Slavery Act 2015. The Act categorises offences of slavery, servitude and forced or compulsory labour and human trafficking. Crimes associated with these offences include holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon after (National Crime Agency).
We have identified three potential risk areas relating to modern slavery to our business as follows:
Who we employ – preventing exploitation within our ownorganisation.
Who we house – are our homes being used as intended?
Who we work with – preventing slavery with our supplychains.
We are working to reduce the risk within our business by:
Paying all our employees (including agency colleagues) at least the living wage.
Employing all our employees directly or through a reputable agency.
Vetting all employees prior to their employment. All new employees must provide right to work documentation and their National Insurance Number before their employment starts.
Having a recruitment and selection policy to ensure fair and transparent recruitment processes.
Requiring all those seeking rehousing to formally apply for a home with us or be nominated for re-housing by the relevant local authority.
Vetting customers for their ‘right to rent’ - to ensure they have the right documentation to live in one of our homes.
Conducting tenancy reviews - to check that our homes are being used in line with our contractual arrangements
Acting against customers who abuse their tenancy with us e.g. illegally sub-let their home; use their home for criminal activities.
Liaising with our local partners, including the Police, to understand and prevent criminal behaviour.
Having a Safeguarding Policy to protect our customers and we train our colleagues in this.
People we Work With
We will prohibit the use of any vendors that have any Directors or employees who have been convicted of an offence or are under investigation for an alleged offence in connection with human slavery or trafficking.
All vendors must ensure that sub-contractors implement their own due diligence procedures to ensure that no organisation in their supply chain is involved in human slavery or trafficking.
We will use Construction Line to vet most of our vendors and maintain due diligence procedures.
We will maintain our own due diligence procedures for those vendors not registered with Construction Line.
We will review this statement at least annually and update in line with any legislative changes or good practice.
Awareness and Communication
All relevant colleagues will be made aware of this statement through our Safeguarding Policy and Procedures and relevant Safeguarding Training to ensure that they are aware of signs of slavery and what to do if they suspect this may be happening.