Modern slavery and Human Trafficking Statement

The following statement gives a concise overview of the steps Housing Solutions has taken to ensure that slavery and trafficking is not part of its business practices or those of its contractors and suppliers. This statement confirms the actions and activities which Housing Solutions undertakes to ensure compliance with the requirements of the Modern Slavery Act 2015.

Organisational structure & supply chains

Housing Solutions is a housing association operating predominantly within the
Berkshire and Buckinghamshire area. We are a leading provider of affordable homes,
for rent, sheltered, care and support, leasehold and shared ownership. We own,
maintain and manage around 7,300 homes, employ around 160 people and have an
annual turnover in excess of £45m.

Housing Solutions is regulated by the Regulator of Social Housing (RSH), we are a
landlord with a strong sense of social purpose, and we work with multiple agencies to
support vulnerable residents. We also aim to be a great place to work for all our
employees.

We have zero tolerance of modern slavery and human trafficking in our business and
supply chains. We have a number of supply chains across our business to help build,
manage and maintain our homes and we require our suppliers and contractors to
comply with the Act in order to work with us.

Employment & Training
We treat all colleagues fairly and equally.

• Our transparent and robust recruitment processes include verifying eligibility
and rights to work in the UK for all employees to safeguard against human
trafficking or individuals being forced to work against their will
• Our recruitment policy ensures that we source employees from reputable
employment agencies
• We pay at least the Living Wage and provide all employees with core
organisational benefits
• Employees are encouraged not to work in excess of the number of hours
permitted by law
• We make salary payments directly to employees and do not delay, defer or
without payments unless there is prior agreement or notification
• Our free, comprehensive Employee Assistance Programme offers guidance
and counselling relating to both the work activities and personal lives of our
employees

Our HR employees receive appropriate training to enable them to conduct checks on
documents, such as passports and other forms of identification, to avoid being party
to trafficking.

We have a comprehensive programme of compliance training for employees, all of
whom have received training advising of the general requirements of the Act and have
been provided with links to the modern slavery website to gain further information
about the types of slavery, signs to spot, online and telephone reporting and referral
processes for victims. https://www.gov.uk/government/collections/modern-slavery

Procurement
Our suppliers are required to comply with relevant legislation and regulation, to follow
our policies, and to understand the needs of the vulnerable people we work with. We
have:

• Specific requirements for suppliers tendering for contracts to confirm
compliance and to provide us with evidence of this
• A centralised and maintained contracts register containing all Housing
Solutions’ contracts, which allows us to review and amend terms with suppliers
so that they deliver against our requirements
• Continued to review our procurement policy and procedures and our terms with
suppliers so that they deliver against our requirements
• Require all contractors to be accredited with Constructionline, which includes a
requirement to comply with the Act
Relevant policies and procedures
Housing Solutions operates the following policies that describe its approach to the
identification of modern slavery risks and steps to be taken to prevent slavery and
human trafficking in its business practices, or those of our contractors and suppliers:
• Whistleblowing Policy – we encourage all colleagues to report any concerns
relating to Housing Solutions or its supply chains and has processes in place to
allow this. The Whistleblowing Policy is designed to make it easy for colleagues
to make disclosures, without fear of discrimination
• Procurement– we are committed to ensuring that our suppliers adhere to the
highest standards of ethics. 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.
• Recruitment policy – we use only specified, reputable employment agencies
to source labour and always verify the practices of any new agency we use
before accepting workers from that agency.
• Safeguarding – we have developed policies which promote and safeguard the
welfare of those living in our properties or receiving our services. We work
closely with other agencies and will report any suspected incidences of slavery
or trafficking to the relevant authorities
• Tenancy Audit – we visit all our tenants on a rolling basis as part of our tenancy
audit programme. During these visits we check for signs of modern slavery and
human trafficking, as well as any other welfare concerns which tenants or
members of their household may have. Where we have concerns, we use the
information gained through the tenancy audit in line with our wider safeguarding
approach.

Due Diligence
We will continue to take appropriate steps to ensure that there is no modern slavery
or human trafficking in our supply chains. This includes continuing to review our
existing policies and procedures in light of the requirements of the Act.
Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015
and has been approved by the Board of Housing Solutions and will be reviewed in
line with the requirements of the Act.

Signed:

 Liz Padmore signature
Date of approval: 16 December 2020