Modern slavery statement
The Modern Slavery Act 2015 (the Act) requires organisations supplying goods or services with a turnover of above £36 million to prepare and publish an annual Modern Slavery Statement.
The Statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its business or supply chain. Your Housing Group (YHG) is publishing this statement setting out what it has done to recognise and prevent potential incidences of modern slavery in the Financial Year 2018-19.
YHG structure and vision
YHG prides itself on providing homes which help people live independently and enables them to get on and off the property ladder at different stages of their lives. With more than 27,000 homes across the North West, Yorkshire and Midlands, the business has a large and diverse portfolio. We operate across the whole of the property chain from initial procurement of sites, through planning to the delivery and management of high quality communities across a range of tenure types and housing solutions.
We deliver services to a range of stakeholders including tenants, landlords, house buyers and local authorities.
YHG is committed, as both an employer and as a landlord, to running our business responsibly. By creating more places to thrive, we will protect and enhance the communities we work for and with.
Our policies and procedures
We continue to review our existing policies and procedures in light of the Act each year. We are confident that our policies promote good behaviour among our colleagues at work and within our supply chain. Our policies and procedures are kept under review to make sure that they reflect the Group’s evolution and our regulatory and statutory obligations. We have a number of policies and procedures in place that contribute to ensuring modern slavery does not occur in our business or supply chain which include:
- Employee Code of Conduct;
- Anti-Social Behaviour and Hate Crime Policy
- Probity Policy;
- Harassment and Bullying Procedure;
- Equality, Diversity and Inclusion Policy;
- Anti -Fraud & Bribery Policy;
- Health & Safety Policies
- Recruitment Policy;
- Right to Work Policy;
- Whistleblowing Policy;
- Domestic Abuse and Safeguarding Policies;
- Financial Standing Orders;
- Supply Chain Due Diligence Policy.
We have successfully introduced a Procurement Policy, Procurement Regulations and Contract Management Procedures to further enhance our governance around tendering and supplier selection which embeds due diligence on the supply chain in relation to Modern Slavery into our processes and procedures. This is currently being completed by all areas of the business with the support of Procurement and will continue to be embedded through this year.
YHG’s Strategic Safeguarding Group and Safeguarding Operational Group regularly meet to discuss our duties under the Modern Slavery Act and concerns or incidents which could fall under the act. Modern Slavery now also forms a standing item on the agenda for YHG’s Equality and Diversity Steering Group.
Any concerns or issues in relation to Modern Slavery are recorded and monitored on the our risk management system and any issues are escalated as appropriate.
We have discussed the Act at our Risk and Compliance Group to understand our duties and our Board has reviewed the annual statement and provided oversight to our approach.
At our Strategic Safeguarding Group and Safeguarding Operational Group we have discussed our duties under the Modern Slavery Act and explained what modern slavery is to staff.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business, we have provided training to relevant members of staff, typically “front line” staff working in our communities through our tiered Safeguarding Training Courses. The training was reviewed and updated during 2018-19 to ensure that it remains relevant and reflects existing best practice. Online safeguarding training is also mandatory for all employees. YHG Procurement staff have all completed the CPP accredited Modern Slavery Certificate during 2018-19 to further increase awareness of Modern Slavery Issues.
YHG online training is in the process of being reviewed and specific modern slavery units are being developed as part of this.
The Safeguarding Operational Group have benefitted from training from Greater Manchester Police on the County Lines programme and a “Safeguarding Bulletin” was shared with staff about the County Lines programme to raise awareness of Modern Slavery and related issues.
Our approach to recruitment and selection contains relevant requirements in terms of checking of eligibility to work in the UK and carrying out the necessary checks such as DBS (Disclosure and Barring Service).
For every successful application, we check proof of eligibility to work in the UK; this initially is by way of a question upon application and then verification of relevant documentation before/after interview. This is by production of a valid passport, or via other means such as a full birth certificate.
For roles that require DBS clearance; each relevant role clearly states the requirement for DBS and the level of DBS associated with that role and the relevant DBS is undertaken for all offered candidates where it is a role requirement.
References are also taken for every potential new starter covering two years full career history and a minimum of two references – if there are any gaps in employment greater than three weeks we will seek a character reference. All references are viewed by the hiring manager and where required the People Business partner also and are then signed off (or rejected) prior to an employee starting.
YHG has just over 1000 suppliers across a wide range of goods, works and services primarily corporate, construction and property related, but also some more specialist requirements.
Our internally delivered procurement service is now embedded, giving us greater controls on our supply chain management and the service assess the actual and potential risks within our supply chains. A Due Diligence Policy for all suppliers includes a standard selection or eligibility questionnaire which asks all bidders to demonstrate that they comply with the Act. In addition, the members of the procurement service are designated to key categories of spend enabling them to be specialists in each market as they better understand where the potential risks may occur.
Our procurement templates, contracts and questionnaires have all been subject to a legal review completed by our legal advisors in 2018 to ensure our standards were fully compliant with all relevant legislation including Modern Slavery.
All our standard contracts contain clauses and contractual requirements that our suppliers do not engage in any activity that is contrary to the Act. Where a contract has been renewed during the year or any new contract has been entered into, that contract term has been applied. Over time, we will achieve the inclusion of the contractual requirement in all supplier relationships. The Procurement Team maintain a register of all contracts and approve all new suppliers to the business ensuring that they meet our eligibility criteria including Modern Slavery. During 2018-19 a new process and checklist has been established for use with suppliers and at contractor site visits as part of evidence process
Our suppliers have been mapped to identify those who carry the greatest risk to our business including in relation to modern slavery. We will continue to enhance the assurances we seek from supply chain members as to their avoidance of modern slavery and human trafficking.
Our on-going commitment to the Modern Slavery Act 2015
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our commitment is to act ethically and with integrity in all our business relationships and to implement effective systems and controls to ensure slavery and human trafficking is not taking place. We are further committed to making sure that our properties are not used to accommodate the work of human traffickers or detain others for servitude.
In support of this, a Modern Slavery Action Plan, based on the Guidance issued by the Home Office in 2018, has been reviewed and approved to include actions further aimed at combatting Modern Slavery in any part of our business or in our supply chain. This includes plans for the implementation of a new procurement system, proposed audits of the supply chain and the development and roll out of a new Learning Management System.
Oversight of the Modern Slavery agenda will be monitored through the Equality and Diversity and Risk and Compliance Groups and any issues escalated to the Group Board.
This statement has been approved by the Group Board of Directors and is made pursuant to section 54(1) of the Modern Slavery Act 2015.