Modern slavery statement
MODERN SLAVERY STATEMENT 2019-20
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 2019-20.
YHG STRUCTURE & VISION
YHG prides itself on providing homes that 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 the 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 & PROCEDURES
We continue to review our existing policies and procedures in light of the Act in accordance with a review programme. We are confident that our policies promote good behaviour among our colleagues both 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, all of which have been updated in 2019 and 2020, that contribute to ensuring modern slavery does not occur in our business or supply chain which includes:
- Employee Code of Conduct;
- Anti-Social Behaviour and Hate Crime Policy;
- Probity Policy;
- Equality, Diversity and Inclusion Policy;
- Anti -Fraud & Bribery Policy;
- Health & Safety Policies;
- Whistleblowing Policy;
- Domestic Abuse and Safeguarding Policies;
- Operational Standing Orders;
- YHG Procurement Procedures;
- Disciplinary Procedure;
- Recruitment and Selection Procedure
- Grievance Procedure.
In 2019, a YHG Procurement Procedure, Procurement Team Guidance and Contract Management Procedures were introduced to further enhance our governance around tendering and supplier selection. This embeds due diligence in the supply chain in relation to Modern Slavery into our processes and procedures. The Guidance and any associated procedures are updated regularly, with the most recent update taking place during May 2020.
YHG’s Strategic Safeguarding Group and Safeguarding Operational Group meet to discuss our duties under the Modern Slavery Act and concerns or incidents of safeguarding, some of which could fall under the act and any issues are escalated if required. Modern Slavery forms a standing item on the agenda for YHG’s Equality and Diversity Steering Group. The group meets on a quarterly basis.
Any concerns or issues in relation to Modern Slavery are recorded and monitored on the 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 2019/20 to ensure that it remains relevant and reflects existing best practice. Level 1 online safeguarding training is also mandatory for all employees. YHG Procurement staff have all completed the CIPS accredited Modern Slavery Certificate during 2019 to further increase awareness of Modern Slavery Issues and will refresh this training on an annual basis.
YHG online training has been reviewed and a new system introduced. Our modern slavery training has been reviewed and a new course developed and made available. This will become mandatory for all frontline staff who receive Level 2 safeguarding training, as well as for other staff whose work may have an impact on helping to tackle and prevent modern slavery such as those working in procurement, finance and governance.
Due to Covid-19 and the inability to deliver face to face training, we have designed a full Level 2 safeguarding package. This package consists of 8 detailed Safeguarding modules (Domestic Abuse; County Lines; Prevent; ASB; Intro to Hoarding; Suicide Awareness; Modern Slavery and Hate and Mate Crime). This package has been assigned to all relevant roles across YHG and Fix360.
The Safeguarding Operational Group has benefitted from training from Greater Manchester Police on the County Lines programme.
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 the interview. This is by the 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 one month we will investigate and clarify the gap and where possible, seek a character reference.
For YHG staff references are obtained by the HR team and then reviewed by the hiring manager and where escalation is required, the HR Business Partner. They are then either signed off as satisfactory or if unsatisfactory, the conditional offer is withdrawn prior to an employee starting.
For fix360 operatives, references need to be received and signed off as satisfactory before the end of the first month of employment. Trade Operatives and Supervisors are also required to have a basic DBS check completed for them. All other pre-employment checks including the Right to Work in UK, qualification checks, interview notes, evidence of recruitment and budget approval have to be received and signed off prior to an employment start date being agreed.
YHG reviews its suppliers each year and currently has 771 suppliers, compared to c1000 in 2018/19, who are used to deliver a range of goods, works and services across the Group.
YHG has its own Procurement Team, consisting of 5 full time members of staff, which takes a category management approach to procurement and management of its supply chains following the Procurement Team Procedures that are embedded across YHG.
The Procurement Team has set procedures for the assessment and due diligence of suppliers which includes standard selection or eligibility questions including specific questions on Modern Slavery which asks all bidders to demonstrate that they comply with the Act.
Our standards are all fully compliant with all legislation relating to public procurement, including those around 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. As contracts are renewed or retendered, the Procurement Team ensure that any relevant terms and conditions are included within any new agreements. 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. YHG has also developed its own modern slavery checklist for the Procurement Team to use with suppliers at site visits as part of the evidence process.
Our suppliers have been mapped to identify those who carry the greatest risk to our business which incorporates modern slavery as a risk. The goods, works and services that YHG typically purchases tend to be from industries that are highly regulated such as law, asset safety, compliance and are therefore of a lower risk for modern slavery. However, YHG continues to enhance the assurances we seek from supply chain members as to their avoidance of modern slavery and human trafficking. For those suppliers YHG uses in higher risk supply chains, such as construction and supply of materials, YHG conducts additional checks such as site visits using our checklist.
COVID-19 AND MODERN SLAVERY
Measures announced in early 2020 to tackle coronavirus (COVID-19) have seen people’s day-to-day life be drastically altered. Whilst these changes are essential to beat coronavirus and protect the NHS, modern slavery is a harmful and hidden crime and its victims may be especially isolated and hidden from view during the coronavirus outbreak. YHG remain committed to tackling the issues of modern slavery during this time and are ensuring that we remain vigilant to the risks.
We have implemented a series of additional welfare calls and checks to customers, particularly those most vulnerable. This will enable us to continue to monitor issues of safeguarding and modern slavery during these unusual circumstances. Training has been provided to staff undertaking calls to ensure they are aware of the need to report any safeguarding issues or concerns. We also conduct welfare calls with employees to ensure that they can work safely and address any wellbeing concerns.
During the COVID-19 pandemic we have made a number of adjustments to the recruitment process. Following a brief freeze on all recruitment we have now tightened the approval processes for any requests for additional or replacement resource. Where we have been unable to see documents first hand due to stringent social distancing measures, we have ensured that these have been viewed via video link. We have also facilitated skype and zoom interviewing techniques to limit face to face contact. We continue to adopt these practices and will closely monitor all recruitment activities.
Learning and development have adapted induction and training sessions to convert these to online sessions to limit face to face contact and have added a number of e-learning courses for essential health and safety training and COVID-19 training. As part of the induction process all staff undergo training in safeguarding issues. Essential health and safety training sessions are planned, and facilities have been risk assessed.
Emerging developments are monitored, and additional health and safety forums established to discuss the changing picture and undertake risk and impact assessments for Covid-19, this includes information in relation to safeguarding staff and customers. Information is cascaded to staff and customers using a range of communication methods.
We have taken additional measures to protect our supply chain and businesses from risks associated with Covid-19 which could lead to an increased risk around Modern Slavery. We are speaking regularly to our suppliers and get credit check alerts about their financial status, their ability to keep working for us to ensure that they are able work safely both now and after any return from furlough. We are following government guidance and making extra payments or reviewing payment terms where necessary to ease operating pressures and safeguard incomes and jobs. For example, we have been working closely with our workwear and PPE supplier to ensure supply and that our high standards are still upheld. We are also reviewing all our contracts and suppliers to ensure we are managing these effectively and are ensuring that staff are aware that they should be extra-vigilant at this time of crisis to pick up on any fraud, financial issues or other concerns that may increase the risks associated with suppliers.
OUR ON-GOING COMMITMENT TO THE MODERN SLAVERY ACT 2015:
We are committed to ensuring as far as possible 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 and work with a range of agencies, including the police and local authorities to ensure that information is shared, and action is taken if necessary.
In support of this, a Modern Slavery Action Plan, based on Guidance issued by the Home Office , 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. The plan is on track with actions achieved and progress reported to the appropriate body. Further actions for 2020/21 are also planned to enhance our commitment as well as continuing to embed current activity to ensure that addressing issues of modern slavery is business as usual.
This includes further development of the training on offer and ensuring all staff have access to it, using real life examples as case studies within the training we offer to staff to ensure they know the signs to look out for, undertaking monitoring questionnaires with our suppliers and continuing to adapt our activities taking into account the changes caused by Covid-19.
Public procurement is highly regulated and YHG is subject to the rules and due diligence around this. All suppliers been through rigorous process and we follow up on this through monitoring and using market intelligence. All our procurement activity is governed by these regulations.
Oversight of the Modern Slavery agenda is monitored through the Equality and Diversity and Risk and Compliance Groups and any issues escalated to the Group Board. Risk and Compliance Group and Group Board are also responsible for approving the action plan and annual Statement.
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.