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 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

saha is a Registered Provider and Charity 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 under the Co-operative and Community Benefit Societies Act 2014 (registration no. 15210R) and is also registered with the Homes and Communities Agency (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 and Supported Housing services and Agency Managed services.

Responsibilities

saha believes there is low risk of slavery and human trafficking within its operations. Potential risks are mitigated by its policies and procedures which ensure that it is conducting business in an ethical and transparent manner. All policies are reviewed by the Executive and Senior Management team and approved by the Board/Committee, on a rolling basis in response to audit, statutory or regulatory changes and feedback from customers and partners.

The policies that are relevant to slavery and human trafficking are:-

  • Recruitment Policy
  • Equality, Diversity and Inclusion Policy
  • Disciplinary Policy
  • Whistleblowing Policy
  • Bribery Policy
  • Money Laundering Policy
  • Staff Code of Conduct
  • Contractors’ Code of Conduct
  • Governance Handbook
  • Declaration of Interest Policy
  • Safeguarding Adults Policy
  • Safeguarding Children Policy

Our 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. Its supply chains include sourcing of goods, services and works for the delivery and maintenance of quality homes and associated support services.   It 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

saha uses only specified, reputable employment agencies to source labour. The Association operates a comprehensive and transparent recruitment policy which is subject to the oversight of the Human Resources team and periodic internal audit.

It has rigorous Human Resources procedures in place to ensure that all employees provide original documents to verify a legal right to work in the UK, are paid a fair and legal wage, and are under no duress.

Training

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

  • 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.
  • Specialist training is provided for all front-line employees in safeguarding, domestic abuse and violence services, including identifying potential cases of 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 Human Resources are responsible for investigations and due diligence in relation to known or suspected instances of slavery or human trafficking.

Future Action

saha has taken initial steps to assess the risk of modern slavery occurring within the Association but will continue to consider what action can be taken and procedures implemented 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 our its suppliers and contractors, where appropriate.

This statement has been approved by the Association’s Executive Management Team, which will review and update it annually.

Nigel Parrington

Chief Executive

November 2017

 

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