Annual statement to demonstrate compliance with the Modern Slavery and Human Trafficking Act 2015/16
This statement sets out Progress Housing Group’s (PHG) 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 2015 to 31 March 2016.
The organisation is committed to preventing slavery and human trafficking in 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 our legal and moral obligations under this legislation.
This statement covers the activities of PHG who own and manage approximately 11,000 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 accommodation for keyworkers in Lincolnshire. We also manage two women's refuges and three supported schemes for people facing homelessness. PHG also provides social alarm services.
Our range of housing includes general needs rented housing, supported living, supported housing, housing for older people, shared ownership, key worker accommodation and market rented accommodation.
Our subsidiaries are New Progress Housing Association Limited, Progress Care Housing Association Limited, New Fylde Housing Limited and Key Unlocking Futures Limited. We are a registered provider of social housing regulated by the Homes and Communities Agency (HCA).
Our Supply Chain
The Group’s principal services are providing and developing social housing. The Group’s Procurement Policy has been updated and details how we manage our supply chain and how all go through approval processes to ensure compliance.
The Executive Director for Finance and Resources has responsibility for the development and implementation of the Group’s anti-slavery initiatives and on-going review of our approaches.
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 PHG Code of Conduct clearly defines what is expected of our staff when representing the Group.
Recruitment – The Group will undertake all relevant pre-employment checks prior to staff being employed. We will carry out fair and transparent recruitment processes and we require our recruitment agencies to commit to the principles of fair and transparent recruitment processes in the provision of agency staff. 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 – The Group will raise and maintain staff awareness of the risks of slavery and human trafficking through cyclical 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 has implemented the following actions to mitigate the risk of slavery or human trafficking in the delivery of its services and supply chain:
- We have notified all our existing supplier base of their requirements under this legislation. Any new suppliers will be asked to confirm they are compliant with the legislation and principles of the Act.
- To ensure an understanding of the potential risks of modern slavery and human trafficking in delivering our services and managing our supply chain, we are providing training to relevant members of staff.
- Where appropriate, we will include reference to the Modern Slavery and Human Trafficking Act 2015 in our policies and procedures and ensure our Safeguarding training gives guidance to staff on the identification and reporting of modern slavery or human trafficking.
This statement has been approved by the Board of Progress Housing Group who will ensure it is reviewed and updated annually.