Anti-Modern Slavery & Human Trafficking Policy

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We are committed to preventing and identifying slavery and human trafficking in all our business activities and supply chains. Section 54 of the Modern Slavery Act 2015 emphasises our responsibility to ensure transparency and accountability in our supply chains.

This policy applies to all colleagues and volunteers, outlining our approach to recognising and minimising the risk of modern slavery and human trafficking within our workforce, communities, and supply chains. Modern slavery, which includes sexual exploitation, domestic servitude, forced labour, criminal exploitation, and organ harvesting, is the illegal exploitation of people for personal or commercial gain. More details can be found in Appendix A of this policy.

Modern slavery occurs globally and can involve cross-border trafficking as well as local exploitation, often in plain sight. Victims can be of any age, gender, nationality, or ethnicity.

We have a zero-tolerance approach to modern slavery and human trafficking within our association. We will never knowingly support or deal with any business whose operations involve slavery or human trafficking in any way.

Our Safeguarding Adults Policy, and Safeguarding Children Policy should be followed.

if anyone becomes suspicious, or aware of potential slavery or human trafficking. The incident should be recorded on our Housing Management Platform and reported to the Modern Slavery Helpline on 0800 0121 700 or online at: File a Report (modernslaveryhelpline.org).

We regularly review our recruitment process controls to ensure they are robust enough to minimise the risk of modern slavery within our workforce. This includes verifying that potential colleagues are legally entitled to work in the UK and ensuring all colleagues have written employment contracts.

We have suitable process for reporting concerns, and we offer multiple options for colleagues to voice any concerns and seek help.

All colleagues will receive specific training on anti-modern slavery and human trafficking. Those working in areas where modern slavery is more likely to occur, such as supply chain management, procurement, and housebuilding activities, will receive more in-depth training.

We will:

• Ask suppliers/bidders to confirm their agreement to follow our Anti-Modern Slavery and Human Trafficking policy
• Make use of standard terms and conditions so suppliers must comply with all applicable laws and regulations including the Modern Slavery Act 2015. This refers to their own and their subcontractors’ supply chains
• Make use of procurement frameworks, where suppliers have to set out their response to anti-modern slavery to participate.

Colleagues managing contracts and supply chains should regularly ensure compliance with the Modern Slavery Act. They should also take practical steps to verify that our suppliers and contractors are minimising the risk of modern slavery within their supply chains and business activities. When entering into contracts, they will consider risks and mitigations, which will vary depending on the nature of the contract.

Colleagues should evaluate any practical opportunities to identify or prevent modern slavery within their business area and take steps to mitigate the risk.

We will publish our Anti-Modern Slavery Statement on an annual basis, in line with Section 54 of the Modern Slavery Act 2015 (or any relevant updated legislation) and approved by the necessary operational panel and our Boards.

All suppliers and contractors must confirm compliance with this policy by either submitting a compliant response to a tender or accepting the terms and conditions outlined in a purchase order.

Compliance with mandatory training requirements is to be monitored annually.

The effectiveness of this policy will be monitored as part of the internal controls audit, and its implementation will be reviewed annually by the Development & Asset Committee (DAC).

This policy will be reviewed every three years unless business need, regulation or legislation prompts an early review.