Modern Slavery and Human Trafficking Statement
Review date: August 2021
The Modern Slavery Act 2015 (the Act) requires organisations supplying goods or services with a turnover of above £36m to prepare and publish an annual Modern Slavery Statement.
This statement sets out Estuary Housing Association’s (EHA) commitment and actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and supply chains.
As a Registered Provider, EHA recognises its duty to combat modern slavery and human trafficking. This statement is an expression of our commitment to improving our practices to combat modern slavery and human trafficking in our corporate activities and supply chains. As a business for social purpose EHA does not wish to support or deal with any business involved in slavery or human trafficking in any part of its operations.
EHA’s organisational structure and supply chains
This statement covers the activities of EHA and its subsidiary companies. The Group’s principal activities are the development, management and maintenance of good quality social, affordable and market rent housing, and the provision of care.
Estuary Housing Association Limited was founded in the 1970s and registered with the Housing Corporation in 1984. It is a Registered Society under the Co-Operative and Community Benefit Society Act 2014, with charitable rules and status. It is regulated by the Regulator of Social Housing, Care Quality Commission and Ofsted. It provides over 4600 homes in 14 local authority areas across Essex, three in Suffolk and three bordering London boroughs of Redbridge; Havering; and Barking & Dagenham. The largest concentration of this provision, 1,626 units are in the town of Southend-on-Sea. The Association provides additional services in Southend, including a Nursery and Housing Office. Our remaining stock is dispersed throughout Essex and Suffolk, in both urban and rural areas.
The Association’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 £42.2 million in 2019/20. EHA has assessed the risks of modern slavery and human trafficking as follows;
High risk activities
EHA does not believe there to be any high-risk operations within the work of the company and its supply chain with regards to modern slavery and human trafficking.
Medium risk activities
Supply chains linked to house building and property maintenance, as a result of the organisation’s reliance upon external contractors to undertake a high percentage of building and maintenance work.
Low risk activities
Supply chains in the provision of agency staff predominantly in adult social care.
Responsibility for EHA's anti-slavery approach is as follows:
Policies – We have an extensive and robust framework of policies in place which should already contribute 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, safeguarding, health and safety, recruitment, whistleblowing, procurement, terms and conditions and codes of conduct for staff, suppliers and contractors, as well as stringent and extensive due diligence and checks when recruiting staff or engaging suppliers or contractors.
We continue to review all relevant policies periodically in light of the Act. 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 Association’s commitment and our regulatory and statutory obligations.
EHA has the following policies and strategies that describe its approach to the identification of modern slavery risks and the steps to be taken to prevent modern slavery and human trafficking in its operations:
Confidential Reporting (Whistleblowing) Policy – EHA encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of the Association. This includes any circumstances that may give rise to an enhanced risk of modern slavery or human trafficking. EHA's Confidential Reporting (Whistleblowing) procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Recruitment Policy – EHA operates a comprehensive and transparent recruitment policy which is adhered to by our People & Change department and subject to periodic internal audit. Our approach to recruitment and selection continues to contain relevant requirements in terms of checking of eligibility to work in the UK which is carried out for every successful application as well as reference checks for every new starter.
Employee and Board and Committee Members’ Code of Conduct – EHA’s code makes clear to employees and Board Members the actions and behaviours expected of them when representing the Association. EHA strives to maintain the highest standards of employee and Board Member conduct and ethical behaviour including a mandatory annual declaration of interest from every Board and independent committee member or employee.
Probity Policy – EHA requires all Board and committee members and employees to ensure that good probity is maintained at all times and that our conduct is transparent, effective and beyond reproach. The policy requires EHA to maintain a register of declarations of interest as well as a register of gifts and hospitality.
Procurement Policy and Contract Procedure Rules:
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.
EHA works with suppliers to ensure 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. Questions within the SQ help identify and mitigate any potential risks in the supply chain in relation to child labour and other forms of trafficking and an organisations compliance to Section 54 where applicable.
EHA Procurement is involved in all contracts tendered by the association and does not wish to support or deal with any business knowingly involved in slavery or 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.
Over time, we will achieve the inclusion of the contractual requirements in all supplier relationships.
Contract management is also being developed to ensure improved governance around supplier selection and performance. Modern Slavery will form part of regular contract reviews to ensure compliance to EHA policies and the Modern Slavery Act.
A register of all current contracts is maintained by Procurement using our eSourcing portal.
Recruitment of Agency workers – EHA works with Procurement for Housing (PfH) Frameworks and uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Agency workers supplement the use of our internal staff bank.
Safeguarding Policy – EHA’s Corporate Safeguarding Policy identifies Modern Slavery as a form of abuse and details clear referral methods for staff to follow if and where abuse is suspected.
Risk assessments – Key Corporate Risk monitoring and management is undertaken as a standing item by the Audit and Risk Committee, with all risks, controls and assurances being signed off by the Committee on an annual basis. The Board of Management also receive the Key Corporate Risk matrix on a bi-annual basis. All Senior Leadership Team Members are responsible for assessing the risks associated with modern slavery and human trafficking.
Investigations/due diligence – Any suspected incident of slavery or human trafficking should be immediately reported to the Chief Financial Officer in the first instance. Individual members of the Senior Leadership Team, with assistance from the People & Change Team, are responsible for investigating any suspected instances of modern slavery and human trafficking.
Training – EHA’s Director of People & Change is responsible for sourcing and making training available on modern slavery and human trafficking to staff. All staff are required to undertake mandatory e-learning courses covering the topics of Anti-Bribery & Corruption and Safeguarding on a 2-yearly basis, which outline how concerns around criminal and safeguarding matters should be raised and addressed.
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 was approved by EHA’s Senior Leadership Team on behalf of EHA Board of Management and applies to all organisations 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 slavery and human trafficking statement for the financial year ending 31st March 2020.
Chief Executive: Ian Martin
Modern Slavery Helpline - call 08000 121 700 to get help, report a suspicion or seek advice. More information can be found on https://www.unseenuk.org/
The Safe Car Wash - The Safe Car Wash app is a new smartphone app created and launched by the Church of England’s anti-slavery campaign ‘The Clewer Initiative’ and the Catholic Church’s Santa Marta Group to help members of the public alert police to potential incidents of modern-day slavery at hand car washes. You can download the free app onto your smartphone. When you are using a hand car wash, simply open the app and complete a short survey about the working conditions of the car wash. https://www.theclewerinitiative.org/safecarwash