Modern Slavery and Human Trafficking Statement

saha Modern Slavery and Human Trafficking Statement

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that Salvation Army Housing Association (saha) has taken and continues to take to ensure that slavery and human trafficking is not taking place within the Association or its supply chain.

saha understands that it has a responsibility to take a robust approach to slavery and human trafficking and as such takes a zero tolerance approach to slavery and human trafficking and expects all those in its supply chain and contractors to comply with its values.

In addition to its own Modern Slavery and Human Trafficking Statement, saha also adheres to its parent company, The Salvation Army’s Modern Slavery Statement and relevant policies and practices.

Our Business and Organisational Structure

Salvation Army Housing Association (saha) is a Registered Provider that started developing supported housing and services in the 1970’s. Originally established by The Salvation Army, the Association is an independent organisation and has grown into a diverse specialist provider of accommodation and support services across England.

The Association is registered as a Community Benefit Society with charitable status under the Co-operative and Community Benefit Societies Act 2014 (registration no. 15210R) and is also registered with The Regulator of Social Housing (registration no. LH2429). It operates nationally in 85 local authorities across England and has four main business areas of operation; General Needs Accommodation, Older People’s services, Directly Managed Supported Housing services and Agency Managed services.

Responsibilities

saha is constantly working on identifying how modern slavery and human trafficking may affect our customers. We come across a wide range of customers who reflect a diverse variety of backgrounds and needs. saha recognises that isolated residents and people with learning difficulties may be particularly vulnerable or at risk. saha have an extensive and robust framework of policies, procedures and contractual requirements in place which contribute towards the prevention of slavery or human trafficking within our organisation and our supply chains Effective implementation of these policies and procedures ensure saha conducts business in an ethical and transparent manner. All policies are reviewed by the Executive and Senior Management team and key policies are approved by the Board/Committee, on a rolling basis in response to audit, statutory or regulatory changes and feedback from customers and partners.

Procurement and Supply Chain

The Association is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. We manage projects and procurements where services and products are sourced from suppliers. Most of these products are not sourced by us directly but are sourced by our contracted suppliers of services, goods and works. As an organisation that does not wish to work with any business knowingly involved in slavery or human trafficking in any part of its operations, we take the following steps:

    1. Require new suppliers to declare that they are not involved in slavery or human trafficking and have not been subject to any investigation in connection with any offence involving slavery or human trafficking
    2. Incorporate provisions in our contract and sub-contract documentation requiring our suppliers to take appropriate steps to ensure that there is no slavery or human trafficking in their supply chains
    3. Include within all tender documentation instructions that we expect all suppliers to comply with the Modern Slavery Act
    4. All suppliers must complete and sign the saha Contractors Code of Conduct agreement stipulating that they comply with the Modern Slavery Act
    5. Work collaboratively with suppliers identifying those procured goods/services which may carry the highest risk of modern slavery within their supply chain and requiring our suppliers/contractors to confirm the steps taken to ensure there is no slavery or human trafficking in their supply chains
    6. A whistleblowing policy for all staff.

saha has robust procurement processes in place to ensure that it only engages with reputable suppliers and contractors who adhere to appropriate legislation, regulation and practices.

Recruitment/Agency Workers

The Association operates a comprehensive and transparent recruitment policy which is subject to the oversight of the Human Resources team and periodic internal audit.

As an equal opportunities employer saha operates a rigorous recruitment process. saha’s recruitment process is predominantly managed in-house and where agency workers are used, these are only sourced from reputable employment agencies. Using this approach we seek to avoid inadvertently engaging those who present as looking for work for themselves but who are actually ‘ controlled’ by others. Our recruitment practices include ‘Right to Work’ checks for all prospective employees.

Training

The Head of People and the Executive Director of Corporate Services are responsible for sourcing and making training available on modern slavery and human trafficking to staff.

    1. All new saha employees receive induction training on equality and diversity which seeks to recognise and work with vulnerable people and children in our communities.
    2. Specialist training is provided for all front-line employees in safeguarding, domestic abuse and violence services, including identifying potential cases of modern slavery and human trafficking and how to report them.

Investigations/Due Diligence

Individual members of the Senior Management Team, with assistance from the Head of People are responsible for investigations and due diligence in relation to known or suspected instances of slavery or human trafficking.

Future Action

saha will continue to consider what action can be taken and procedures implemented in relation to modern slavery to mitigate risk over the coming years.

The Association will continue to raise awareness and deliver training to new and existing staff and will extend this to its suppliers and contractors, where appropriate.

 

This statement has been approved by the Association’s Group Board.

 

Nigel Hills

Chief Executive

September 2019