Modern Slavery and Human Trafficking Statement

Review date: February 2019


This statement sets out Estuary Housing Association’s (EHA) 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 our 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. 

EHA’s organisational structure and supply chains 

This statement covers the activities of EHA and its subsidiary companies. 
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 provides 4,300 homes in 18 local authority areas across Essex and three bordering London boroughs of Redbridge; Havering; and Barking & Dagenham. The largest concentration of this provision, 1,429 units, is 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, 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 has an annual turnover of £39 million. 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: 


All policies are reviewed by Senior Management and signed off by Committee, where appropriate under a delegated authority from the Board of Management, or by the Board of Management. All policies are reviewed on a rolling basis in response to longevity, audit, statutory or regulatory change and customer and partner feedback. 

Risk assessments:

Key Corporate Risk monitoring and management is undertaken by the Investment, 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 an annual basis.  All Senior Management are responsible for assessing the risks associated with modern slavery and human trafficking with the Head of Governance and Central Services assuming specific responsibility for those activities assessed as medium risk. 

Investigations/due diligence:

Individual members of the Senior Management Team, with assistance from the Human Resources Team, are responsible for investigating any suspected instances of modern slavery and human trafficking. 


EHA’s Director of Human Resources and Organisational Development is responsible for sourcing and making training available on modern slavery and human trafficking to staff. 

Relevant Documents: 

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: 

Whistle Blowing 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 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 subject to the oversight of the Human Resources team and periodic internal audit. 

Employee code of conduct: 

EHA’s code makes clear to employees the actions and behaviours expected of them when representing the Association. EHA strives to maintain the highest standards of employee conduct and ethical behaviour. 

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, treat workers with dignity and respect, and act ethically and within the law in their use of labour. EHA works with suppliers to ensure that they meet the standards of the policy. Serious violations of EHA's procurement policy will lead to the termination of the business relationship. 

Recruitment/Agency workers:

EHA 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 and Strategy: 

EHA’s Safeguarding Policy.pdf 420KB identifies Modern Slavery as a form of abuse and details clear procedures for staff to follow if and where abuse is suspected.

More information can be found on our Safeguarding page and in our Safeguarding Strategy.pdf [pdf] 322KB

Our effectiveness in combating slavery and human trafficking 

Any suspected incident of slavery or human trafficking should be immediately reported to the Executive Director of Finance and Corporate Resources in the first instance. 


Further Action:

All contractors and suppliers will be requested to send us a copy of their Modern Slavery and Human Trafficking Statement, whereby their turnover exceeds £36m p.a.


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 2019. Under this review, we have found we are continuing to adhere to the principles.  


Chief Executive: Ian Martin as of June 2019