Modern Slavery and Human Trafficking Statement 2020/21


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 and Human Trafficking Statement.

Our Commitment

Estuary Housing Association (EHA) 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 Registered Provider, EHA recognises its 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 for the financial year 2020/21. 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.


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 care.

Estuary Housing Association Limited was founded in the 1970s and includes two subsidiaries (Accession Homes Limited and Estuary Homes Design Limited) to which this statement equally applies. 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 4,600 homes in 14 local authority areas across Essex, three in Suffolk and three bordering 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 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

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 £39.8 million in 2020/21. EHA has assessed the risks of modern slavery and human trafficking in its operations as follows:

Modern Slavery Risk Assessment Results

High risk


Medium risk

Supply chain linked to house building and property maintenance

Low risk

Supply chains in the provision of agency staff in adult social care


Due Diligence Processes for Slavery and Human Trafficking


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, 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 engaging suppliers or contractors.


Staff and Workforce

The average number of people we employed during the year was 329 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 whistle blowers.

All employees are required to undertake mandatory training on safeguarding, anti-bribery and fraud awareness. These courses are monitored for completion monthly. Compliance for all mandatory courses is reported to the Senior Leadership 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.

EHA works 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. 

EHA Procurement is taking an active role in contracts tendered by EHA and will not support or deal with any business knowingly involved in slavery or human trafficking in any part of its operations. This activity is in its early stages.

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

Whilst 2020/21 has been impacted by Covid-19, we have continued to strengthen key areas relevant to Modern Slavery and Human Trafficking. We have:

  • Appointed a Head of Procurement and Contract Management
  • Appointed additional governance resources to improve our business assurance and risk management processes
  • Reviewed our Procurement Policy.


Future Actions 2021/22

We will continue to further develop our processes and practices during 2021/22 including reviewing relevant policies such as Corporate Safeguarding, Codes of Conduct for Staff and Board members, probity and confidential reporting (whistleblowing).

We will also 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 Ongoing 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 Board of Management on 20th September 2021 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 2021.


Chief Executive:  Ian Martin

September 2021

Modern_Slavery_Statement.pdf[pdf] 121KB

Modern Slavery Helpline - call 08000 121 700 to get help, report a suspicion or seek advice. More information can be found on

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.