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 2017-18.
YHG STRUCTURE & 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 28,000 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 & 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;
- Probity Policy;
- Dignity at Work Policy;
- Equality & Diversity Policy;
- Anti Fraud & Bribery Policy;
- Health & Safety Policies
- Recruitment Policy;
- Right to Work Policy;
- Wellbeing Framework;
- Whistleblowing Policy;
- Domestic Abuse and Safeguarding Policies;
- Financial Standing Orders; and
- Supply Chain Due Diligence Policy.
This year we are also introducing 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.
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.
We have discussed the Act at our Senior Leadership Team 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. Level 1 Safeguarding Training is mandatory for all employees.
In the last year, Modern Slavery training has been made a mandatory unit for all staff available on our online training portal, Skillbuilder.
This year 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 continues to contain 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. More often than not, this is by production of a valid passport but could be other means (e.g. full birth certificate).
For roles that require DBS; 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 People Business partner and are signed off (or rejected) by the People Business Partner prior to an employee starting.
YHG has just over 900 suppliers across a wide range of goods, works and services primarily corporate, construction and property related, but also some more specialist requirements.
Last year we established our internally delivered procurement service giving us greater controls on our supply chain management and who assess the actual and potential risks within our supply chains. We put in place a Due Diligence Policy for all suppliers which includes the 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.
We had a full documentation review of our procurement templates, contracts and questionnaires completed by Trowers & Hamlins in January 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.
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.
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.