Modern Slavery and Human Trafficking Statement 2022/23
Introduction
The Modern Slavery Act 2015 (the Act) requires organisations supplying goods or services with a turnover of above £40m to prepare and publish an annual Modern Slavery and Human Trafficking Statement.
Our Commitment
Estuary Housing Association Ltd (EHA/We/Our) recognises the detrimental effect modern slavery has on global society and we are committed to acting ethically and with integrity within our business and with others to combat this. We take care to ensure modern slavery and human trafficking is not taking place in our business or supply chains through implementing and enforcing effective systems and controls. As a housing association registered with the Regulator of Social Housing, we recognise our duty to combat modern slavery and human trafficking. This statement sets out how we deliver our commitment to improving our practices to combat modern slavery and human trafficking in our corporate activities and supply chains. EHA will not knowingly deal with any business involved in modern slavery. If any is found, we will work with them, in the first instance, to resolve the issues and prevent further occurrences. We will terminate our dealings with any business where we are not assured, they are taking adequate steps to eliminate modern slavery.
Our organisational structure and purpose
Our Organisational Structure and Purpose The Group’s principal activities are the development, management and maintenance of good quality social, affordable and market rent housing, and the provision of supported living services. We were founded in the 1970s and have two subsidiaries (Accession Homes Limited and Estuary Homes Design Limited) to which this statement equally applies. We are a Registered Society under the Co-Operative and Community Benefit Society Act 2014, with charitable rules and status and regulated by the Regulator of Social Housing, Care Quality Commission and the Financial Conduct Authority. We have over 4,704 homes in 18 local authority areas predominately in Essex but also in Suffolk and the London boroughs of Redbridge, Havering, and Barking & Dagenham. Our core purpose remains the same as it did when we were established which was to provide homes to those in greatest need. However, we also build and Page 2 of 4 develop open market housing to help subsidise the development of even more affordable homes. We are transparent in reinvesting our surpluses to fulfil this social purpose. Our approach to combatting modern slavery and human trafficking is in keeping with our social business purpose, our desire to demonstrate ethical business practices that are aligned with our ethos, and to meet our legal and regulatory duties.
Risk assessment
Our Business: Although we think the risk of modern slavery/ human trafficking within our operations is low, we will be vigilant and ensure any instances of modern slavey or human trafficking identified are appropriately dealt with and reported, so that lessons may be learnt and future incidents avoided.
Supply Chains: EHA’s supply chains are drawn mainly from the construction, property maintenance and adult social care market. EHA operates in England and had an annual turnover of circa £40 million in 2022/23. EHA has assessed the risks of modern slavery and human trafficking in its operations as follows:
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High risk |
None |
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Medium risk |
Supply chain linked to house building and property maintenance |
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Low risk |
Supply chains in the provision of agency staff in adult social care |
Due Diligence Processes for Slavery and Human Trafficking
Policies
We have a robust framework of policies, procedures and contractual arrangements in place which contributes towards the prevention of slavery or human trafficking within our organisation and our supply chains. These include, but are not limited to, areas such as housing management, risk management, safeguarding, health and safety, recruitment, whistleblowing, equality, diversity and inclusion, procurement, terms and conditions of employment, and codes of conduct for Board members, staff, suppliers and contractors, as well as due diligence and checks when recruiting staff or Page 3 of 4 engaging suppliers or contractors. We will work with our contractors and suppliers to understand any supply chain pressures so as to deliver the most efficient, best value service for our customers and our business as a whole.
Staff and Workforce
The average number of people we employed during 2022/23 was 238 and we are committed to treating those who work for us fairly. We are committed to paying the Living Wage to all our directly employed staff. We regularly review our terms of employment to ensure that they comply with all relevant legislation. We only use specified, reputable employment agencies to source labour and always verify the practices of any new agency we use before accepting workers from that agency. We expect all employees to adhere to the Association’s Staff Code of Conduct. We ensure that we have systems in place with an overarching policy statement as well as a whistleblowing policy to encourage the reporting of concerns and the protection of whistleblowers. All employees are required to undertake mandatory training on safeguarding, health and safety, anti-bribery and fraud awareness. These courses are monitored for completion monthly. Compliance for all mandatory courses is reported to the Executive Team for assurance on a monthly basis.
Corporate Procurement Policy
EHA is committed to ensuring that its suppliers adhere to the highest standards of ethics. We recognise that modern slavery is a complex supply chain issue and suppliers are required to demonstrate that they provide safe working conditions where necessary, treating workers with dignity and respect, and acting ethically and within the law in their use of labour. Our procurement activities take place in England and our contractors and suppliers are predominantly UK-based. We follow The Public Contracts Regulations 2015, which govern good practice in procurement. We work with suppliers to verify that they meet the standards of the policy and as such are required to complete a Standard Selection Questionnaire (SQ) as part of the initial tender process. Our Procurement team is taking an active role in contracts tendered by EHA and will not support or deal with any business knowingly involved in slavery or Page 4 of 4 human trafficking in any part of its operations. We continue to improve and update our procurement documentation, which includes our terms and conditions for the provision of goods and services, ensuring they are up to date and contain the necessary clauses regarding Modern Slavery and Human Trafficking. These updates continue to be made to emphasise our zero-tolerance approach and to ensure our suppliers do not engage in any activity that is contrary to the Act.
Performance this year
This year we have reviewed and implemented new Codes of Conduct for our Board and Employees. We will continue to update our internal staff policies relating to fair and safe working conditions. We will also continue to increase the monitoring of key suppliers in ‘at risk’ business industries and start to review construction contracts and the supply chain where the potential risk of modern slavery and human trafficking increases.
OUR ON-GOING COMMITMENT TO THE MODERN SLAVERY ACT 2015:
As a social business, committed to improving lives, we are determined to ensure 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 was approved by EHA’s Board of Management on 25th September 2023 and applies to all companies within the group. It will continue to be reviewed and updated as necessary or, as a minimum, on an annual basis. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Modern Slavery and Human Trafficking statement for the financial year ending 31st March 2022.