Modern Slavery and Human Trafficking Statement
In accordance with the Modern Slavery Act 2015, we set out the Group’s actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking within the Group and its supply chains. This statement relates to actions and activities during the financial year 1 April 2022 to 31 March 2023.
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.
This statement covers the activities of the Group who own and manage over 12,000 homes. The Group operates mainly in Lancashire but provides supported living homes for people with a learning disability and/or autism nationally, as well as keyworker accommodation in Lincolnshire. We also manage two women's refuges and three supported housing schemes for people who are facing homelessness. The Group also provides technology enabled care and support services through Progress Lifeline to over 67,000 customers.
Our Group structure from September 2022 is as detailed in Appendix A:
Our Supply Chain
The Group offers a varied business proposition with our principal services being the provision and development of social housing. This is reflected in our supply chain as we engage with a wide variety of organisations for a broad range of goods and services. Our supply chain members are diverse not only in the goods and services they provide, but also in the size and structure of their organisations. We actively encourage through our procurement processes that Small and Medium-sized Enterprises (SMEs) apply to join our supply chain in order to promote local business initiatives.
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 them from further involvement in a tender process.
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.
The Group continuously reviews our existing policies to ensure that they reflect the changing shape of the Group, the needs of our tenants and customers and the markets we serve. We are mindful that they promote the necessary awareness and behaviours amongst our colleagues and within our supply chain.
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 colleagues when representing the Group.
Recruitment and Employment – The Group will undertake all relevant pre-employment checks prior to colleagues 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 colleagues. 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 and training – The Group will raise and maintain colleague 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 Adults Board through which a number of related training courses and materials are accessible to all. We also have access to and have promoted the pan Lancashire tool kit for anti-slavery.
Vulnerable people may be more at risk of becoming victims of modern slavery. Equally, victims of modern slavery may also be vulnerable to becoming homeless where accommodation is linked to the work a victim is being forced to undertake. As such all front line housing teams access training on safeguarding via MYLO and this includes modern slavery. In recent years there has also been a growing trend in ‘cuckooing’ whereby criminals and traffickers may exploit vulnerable people and effectively move into their property and use as a basis for criminal activities.
The Group has a range of policies to tackle such activity, such as a Community Safety Strategy. The aims of this strategy are:
- To protect individuals, communities, colleagues and contractors, by providing an effective community safety service
- To promote early intervention and prevention of antisocial behaviour
- To work in partnership to provide an effective, holistic service
- To ensure our service is accessible and takes into account the needs of our diverse customer base, promoting anti-discriminatory practice in all actions
- To take proportionate enforcement action where this is required
- To use all reasonable measures to tackle antisocial behaviour
- To ensure our service is compliant with the relevant legislation and regulatory requirements
In addition, the Group has a Social Housing Fraud Policy which aims to prevent:
- Sub-letting (whole property or part of) including ‘non-occupation’
- Wrongly claimed succession
- Unauthorised assignment of a tenancy (ie mutual exchange without permission
- Key selling (selling the property to a 3rd party)
- Fraudulently obtaining a social housing tenancy by misrepresentation of identity or circumstances
- Fraudulent Right to Buy applications.
As one of the largest providers of supported living in the country, the Group ensures that all tenants are supported and receive commissioned support from a local authority or health body. This enables people with a learning disability and autistic adults to live independently with care support which keeps them safe. The Group carries out regular visits to properties and audits all aspects of the property and tenancies.
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 gives guidance to colleagues on the identification and reporting of modern slavery or human trafficking.
Activity in 2022/23
Our Business Partner Contract Management delivered a programme of training that provides guidance and support for contract management processes for all Group business areas. This includes ensuring compliance with relevant legislation such as the Modern Slavery Act 2015 and placing a stronger emphasis on management of Modern Slavery risk in contractual performance review sessions.
A procurement training package is available to all employees, this includes a specific module on Modern Slavery.
The Group promoted the My Learning Online (MYLO) Portal that includes an extensive training course on Modern Slavery. This is open to all employees and can be accessed at any time.
The Group commenced inviting suppliers within our supply chain with a >£36m turnover to complete the Modern Slavery Assessment Tool.
The Group was actively involved in the promotion of the Anti-Slavery Day on 18 October 2022.
The Group has used social media and our websites to raise awareness of Human Trafficking and Modern Slavery. This has included:
- Promoting safeguarding training and sharing an animated video on the Group's intranet and social media feeds.
- Sharing the “No Whispers” county lines training for volunteers on our social media feeds.
- Creation of an intranet article on a recently issued Procurement Policy Note (PPN) from HM Government for colleagues.
Scheduled activity for 2023/2024
The Group will be actively involved in the promotion of the Anti-Slavery Day on 18 October 2023.
We will utilise the Supplier Relationship Management System to issue formal requests to our suppliers to confirm that they comply with the Modern Slavery Act.
We intend to continue implementing the following actions:
- Share with suppliers with <£36m turnover, the Group’s awareness articles on a periodic basis.
- Explore options for joint working and establishing partnership arrangements with other local bodies such as the Police and Local authorities to raise awareness and knowledge.
The Group will continue to use social media and the Group's intranet and website to raise awareness amongst employees and customers.
This statement has been approved by the Board of Progress Housing Group Limited who will ensure it is reviewed and updated annually.
Last updated: September 2023
For review: August 2024