Annual statement to demonstrate compliance with the Modern Slavery and Human Trafficking Act 2016/17
This statement sets 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 2016 to 31 March 2017
It has been thoroughly 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 understanding 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.
This statement covers the activities of the Group 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. The Group also through Progress Lifeline provides telecare and technology enabled care and support services to over 16,000 telecare customers and supporting over 27,000 customers continues to deliver “platinum standard” (the highest level possible) for all services provided under the Telecare Services Association’s code of practice.
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. We recognise working with external business partners presents risks and seek to ensure they fully comply with their requirements under the Act. We mitigate against the risk of non-compliance of third party organisations through our Procurement Policy which fully reflects our approach 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 qualifying 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 will actively exclude from further involvement in a tender process.
Every supplier or sub-contractor we work with is required to state whether they qualify as ‘commercial organisations’ under the terms of the Act. Those that do not qualify by law and therefore need not put in place measures to combat slavery or human trafficking we do not exclude for reasons of fairness, but our own checks and balances we have in place as detailed in this statement add protection in this regard.
The Executive Director for Finance and Resources has strategic responsibility for the development and implementation of the Group’s anti-slavery initiatives and on-going review of our approaches. The Group supports the Executive Director in our operational responses.
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 are moving to an established framework agreement for the provision of recruitment services. Agency workers appointed are subject to a range of due diligence checks as part of the framework. In addition, we will carry out our own audits 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 – 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 (or will be implementing during this year), the following actions to mitigate the risk of slavery or human trafficking in the delivery of its services and supply chain. Whilst we do not have bespoke performance indicators, these due diligence measures taken are compulsory and/or non-negotiable. We at present provide compulsory classroom training for certain groups of staff which is measured and this is to be supplemented further by compulsory online training, which will again be monitored and measured:
- All qualifying suppliers and contractors must be compliant with the legislation as a condition of business with the Group. This is managed through our procurement process from the very start where qualifying businesses are required to evidence their compliance with the legislation before the Group will work with them.
- 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 through classroom-based training. Our aim this year is to also introduce bespoke compulsory online training on Modern Slavery and Human Trafficking for key frontline staff to complete.
- We will supplement training to staff providing active links and news items on our internal ‘Intranet’ staff pages, posters around the Group’s premises and all-staff emails 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.
- Where appropriate, we will include reference to the Modern Slavery and Human Trafficking 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. Compliance in this regard is monitored through policy review as appropriate through Board.
This statement has been approved by the Board of Progress Housing Group Limited who will ensure it is reviewed and updated annually.