The nature of our business is to help combat homelessness and to provide safe accommodation for vulnerable people – vulnerable people who may otherwise fall victim, while homeless, to modern slavery and be coerced into labour.
To date, Concept Housing Association has not specifically documented the steps it is taking to ensure there is no modern slavery in our business, however there are many
examples of how support to our residents has helped them to live more independently and be less likely to become victims of modern slavery.
During 2023–2024 we will document against the key areas what steps we are taking to prevent modern slavery in our supply chains and business. However, our current position is stated below:
1. Structure and Supply Chains
We have a diverse supply chain providing a range of goods from accommodation to office supplies, to corporate services. We expect our suppliers, contractors, providers and business partners to share the same high standards and commitment to tackling modern slavery and human trafficking.
2. Policies relevant to Modern Slavery
- Code of Conduct – high standards of probity and ethical behaviour
- Probity Policy (Whistleblowing) – confidential communication and reporting arrangements are in place to encourage staff to report concerns and wrongdoing.
- Recruitment & Selection Policy – transparent procedures and checks in place to ensure compliance with legislation and guidance for both permanent and temporary staff.
- Safeguarding Policy – how to identify and report safeguarding incidents within our accommodation and local communities.
3. Due diligence relevant to modern slavery
- Concept have due diligence processes in place across employment and procurement. Our employment practices include requiring new employees to produce original documentation, evidencing their right to work in the UK prior to commencement of employment. We will terminate contracts if a provider or supplier is found to have committed an offence of slavery or human trafficking.
4. Risk Assessment
- we are confident that the processes and actions we have in place including our procurement framework, risk and assurance framework, policies, due diligence and suitably trained staff, can reduce the opportunities for slavery to arise.
5. Measuring effectiveness
- through our engagement with residents and providers we can identify and appropriately address instances of slavery, particularly in our properties and in the communities in which we operate.
- whilst no training specific in modern slavery and human trafficking has taken place, relevant staff are trained on safeguarding procedures, procurement, contract management.
Future Plans – during 2023/24 we will
- Review policies to ensure they reflect our commitment to the Modern Slavery Act 2015
- Ensure the Board and Executive continue to take responsibility to build on the commitment and ensure that there are adequate resources to ensure modern slavery and human trafficking is not taking place within the organisations or in our supply chains.
- Continue to work with staff, suppliers, providers and partners to ensure we maintain appropriate risk mitigations.
- Roll out mandatory training programme for all staff and providers.
This statement is made pursuant to Section 54(1) of the Modern Slavery Action 2015 and constitutes Concept Housing Association’s Modern Slavery Act Statement for the financial year ending August 2023.
Approved by the Concept Housing Association Board on 25th September 2023.