Introduction

In accordance with the Modern Slavery Act 2015 we set out the Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.

It has been reviewed and updated to reflect changes and positive developments over the past year and our intentions for the coming year.

The organisation is committed to preventing slavery and human trafficking in all its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

We will look forward to the coming year with a commitment to continue our activity to meet and exceed our legal and moral obligations under this legislation.

Our Vision and Values

Our shared vision is to have a positive impact on people and communities by providing high quality homes, supporting independence and creating opportunities.

Values we have that support this are that we are people-focused and we are genuine.  People are at the heart of our business.  We look to treat everyone fairly and understand their diverse needs.  We are open and honest, with a friendly, enthusiastic and energetic way of working that is true to what we stand for.

Reflecting this in both our vision and values, we are pleased to be publishing our annual Modern Slavery and Human Trafficking Statement for this financial year.

Organisational structure

This statement covers the activities of the Group who own and manage over 10,000 homes. The Group operates mainly in Lancashire but provides Supported Living homes predominantly for people with a learning disability or mental health need nationwide, as well as keyworker accommodation in Lincolnshire. We also manage two women's refuges and three supported housing schemes for people who are homelessness.  The Group also provides technology enabled care and support services through Progress Lifeline to over 40,000 customers.

Our range of housing includes general needs, supported living, supported housing, independent living, shared ownership, and keyworker accommodation.

Our Group structure at March 2019 is as follows:

 Group Structure

 

Our Supply Chain

The Group’s principal services are providing and developing social housing.  Our Procurement Policy fully reflects what we do and what we require of our business partners (including assessment and procurement routes for development) to ensure full compliance with the Modern Slavery Act requirements.  We ensure that any supplier or sub-contractor we work with goes through a comprehensive assessment process.  We ask bidders as part of the procurement process what they do to ensure their own business and supply chain is free from modern slavery.  Where this cannot be evidenced to the satisfaction of the Group, we would actively exclude from further involvement in a tender process.

Responsibility

The Executive Director, Finance and Corporate Services has strategic responsibility for the development and implementation of the Group’s anti-slavery initiatives and on-going review of our approaches. 

Relevant Policies

The Group operates the following policies:

Code of Conduct – we strive to maintain the highest standards of employee conduct and ethical behaviour in delivering our services and managing our supply chain and the Group’s Code of Conduct clearly defines what is expected of our staff when representing the Group.

Recruitment and Employment – The Group will undertake all relevant pre-employment checks prior to staff being employed. Throughout the whole recruitment process and into the employment relationship, we pride ourselves on providing a safe environment, free from inequalities, where employees’ wellbeing is supported by responsible and inclusive employment practices.

We require our recruitment agencies to commit to the principles of fair and transparent recruitment processes in the provision of agency staff. We principally operate within an established framework agreement for the provision of recruitment services. Agency workers appointed are subject to a range of checks as a requirement of the framework. When we appoint agency workers outside of the framework agreement, the providers are subject to the established due diligence required of all suppliers. In addition, we will carry out our own audits through our employment agency checklist, intended to identify, amongst other things, any Modern Slavery practices or gaps in right to work checks,

As an example of our commitment to fair employee treatment, the Group is committed to the Voluntary Living Wage promoted by the Living Wage Foundation.

Safeguarding & Training – The Group will raise and maintain staff awareness of the risks of slavery and human trafficking through cyclical mandatory safeguarding training and briefing. 

We remain committed to the highest standards of quality, probity, openness and accountability and as part of this commitment provide a confidential reporting process for employees to report serious concerns about any aspect of our work which includes abuse or neglect of vulnerable people.

The Group is a member of the Lancashire Safeguarding Board through which a number of related training courses have been made available to staff throughout 2018/19.  We also have access to the pan Lancashire tool kit for anti-slavery.

Due Diligence

The Group has implemented, the following actions to mitigate the risk of slavery or human trafficking in the delivery of its services and supply chain:

  • All suppliers and contractors must be compliant with the legislation as a condition of business with the Group.
  • Where appropriate, we include reference to the Modern Slavery Act 2015 in our policies and procedures and ensure our Safeguarding and Modern Slavery training to our staff gives guidance to staff on the identification and reporting of modern slavery or human trafficking. 

Future Plans

The Group is currently reviewing our mandatory e-learning Safeguarding courses with a view to incorporating a Modern Slavery and Human Trafficking module. 

To ensure an understanding of the potential risks of modern slavery and human trafficking in delivering our services and managing our supply chain, we plan to provide training to relevant members of staff involved in contract management.

We also plan to supplement training to staff providing active links and news items on our internal ‘Intranet’ staff pages to raise collective awareness.  The collective aim of these is to highlight:

  • the basic principles of the Modern Slavery Act 2015;
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
  • what external help is available, for example through the Modern Slavery Helpline.

Statement Approval

This statement has been approved by the Board of Progress Housing Group Limited who will ensure it is reviewed and updated annually.