Modern Slavery Statement

As a housing organisation, our key risks lie in our supply chains, such as construction and supply of materials, and in the potential vulnerability of people living in our homes. We have described these in more detail below.

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 in line with YHG’s risk management framework.

Risks of a safeguarding nature are reviewed by  YHG’s Safeguarding and Domestic Abuse Operational Group which meets to discuss our approach to safeguarding including our duties under the Modern Slavery Act. Concerns or incidents of safeguarding, some of which could fall under the Act, are managed by the relevant frontline team and escalated to managers and the designated Safeguarding Officer if required.

We consider risks to the organisation and its supply chain, including modern slavery, across a number of channels in YHG and will escalate any concerns to the monthly Risk and Compliance Group, which has representation across the business including members of the Leadership Team. The Risk and Compliance Group will also review the modern slavery action plan. Modern Slavery also falls under the agenda of YHG’s Balance for Better Group (EDI group).

Although the Group has not identified a specific Modern Slavery risk, we assign appropriate actions addressing any risks connected to modern slavery against our risks relating to compliance with procurement legislation and inconsistent contract management, which we believe is appropriate to the size and scale of our operations. 

We aim to ensure that our supplier due diligence procedures are appropriate to our modern slavery risk and the level of influence the Group has.

An important element of these are the Procurement Procedure, Procurement Team Guidance and Contract Management Procedures, as previously mentioned. These were updated in April 2025 to take into account the changes brought in from the Procurement Act 2023 in February 2025.

We use the Procurement Specific Questionnaire for supplier due diligence including questions on compliance with the Modern Slavery Act, and review of suppliers’ modern slavery statements or policies/procedures as appropriate to the contract or commodity being procured. We tailor these questions where appropriate to the commodity being purchased based on its risk level.

In 2024-25, the Procurement Team have reviewed the guidance from PPN 009: Tackling modern slavery in government supply chains and use the guidance when assessing risks of modern slavery associated with different contracts and procurement activity. In line with the guidance in the PPN YHG’s Procurement Team have produced an on-site checklist for our contract managers to use, ensuring all staff are vigilant for signs of modern slavery on sites or when dealing with suppliers.

During Safeguarding September, we delivered specifically developed safeguarding training which raises awareness about modern slavery.   

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 Safeguarding and Domestic Abuse Operational Group we have discussed our duties under the Modern Slavery Act and explained the definition of modern slavery to staff.

We believe training is crucial to address the risk of modern slavery and human trafficking occurring in our properties, and supply chains and to ensure a high level of understanding of the risks, we have provided training through our tiered Safeguarding Training Courses.  Level 1 online safeguarding training is mandatory for all employees and further levels are undertaken by relevant members of staff, typically “front line” staff working in our communities.

YHG has its own Procurement Team, consisting of five full time members of staff who provide procurement, sourcing and supply chain expertise to the business following the Procurement Team Procedures that are embedded across YHG.

YHG reviews its suppliers annually and during 2024/2025 had 786 suppliers, who are used to deliver a range of goods, works and services across the Group.

The Procurement Team has set procedures for the assessment and due diligence of suppliers to address the supply chain risk.  This includes use of the Procurement Specific Questionnaire or eligibility questions including specific questions on Modern Slavery which asks all bidders to demonstrate that they comply with the Act. These questions are tailored to the risk level of the commodity being purchased with enhanced checks for those suppliers in higher risk sectors such as construction. 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 all staff 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, where the supply chain may be longer and include the use of temporary or agency workers, YHG conducts additional checks such as site visits using our checklist or at tender stage. 

We are not exposed to a high risk of recruiting staff who may have been subject to human trafficking, however our recruitment and selection process 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 with proof also of National Insurance Number.  
 
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 discuss with the candidate and for a safer recruitment role we will investigate, clarify the gap and seek a character reference.

All 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.

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 some actions continuing, to enhance our commitment and embed current activity as part of our focus on continuous improvement.  Progress is reported to the appropriate body.   

This includes working towards attaining the Domestic Abuse Housing Alliance Accreditation, and continuing to raise awareness of modern slavery and safeguarding across the business. 

Public procurement is highly regulated and YHG is subject to the rules and due diligence around this. All suppliers have been through a rigorous process, and we follow up on this through monitoring and using market intelligence. All our procurement activity is governed by these regulations which includes the introduction of the Procurement Act 2023.  

Oversight of the Modern Slavery agenda is monitored through the Risk and Compliance Group 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.