We recognise the critical role procurement plays in preventing modern slavery and human trafficking within our supply chains. Within our centralised procurement process, we: 

• require suppliers to agree to follow our Anti-Modern Slavery and Human Trafficking and Safeguarding policies;
• make use of standard terms and conditions that require suppliers to comply with all relevant laws and regulations, including the Modern Slavery Act 2015, and ensure these obligations extend to their subcontractors; and
• utilise procurement frameworks that assess suppliers’ responses to anti-modern slavery requirements as part of their eligibility. 

During 2024/25, we began developing a more structured category management approach to strengthen our ability to identify and manage modern slavery risks. This includes the creation of risk criteria to assess categories and commodities based on their exposure to exploitation risks. These criteria will be embedded into our procurement strategy and aligned with our wider business risk management framework, enabling a more consistent and proactive approach to risk mitigation across sourcing and contract management. 

We also conducted an internal contract management audit during the year, which identified areas for improvement in how we monitor supplier compliance and manage contractual obligations. These findings will be progressed into 2025/26 and will inform enhancements to our contract management processes, supplier engagement practices, and assurance mechanisms. 

We take safeguarding extremely seriously and recognise its vital role in identifying and responding to potential indicators of modern slavery and human trafficking. All safeguarding concerns are reported through our centralised system, which enables accurate recording, monitoring, and scrutiny. 

Our Safeguarding Panel meets every two months to review casework, monitor policy implementation, and oversee continuous improvement. The panel has prioritised the acting upon the recommendations from the completed Safeguarding Audit, including the appointment of a trustee with lead responsibility for safeguarding in relation to charitable entities. It also conducts deep dives into cases, supports lesson-learning, and ensures feedback is provided to colleagues who raise concerns. Panel members also contribute to regional safeguarding boards and forums, helping to share best practice and sector insights. 

We have a dedicated Health and Safety team within the business who provide advice, support and assurance on health and safety matters. Detailed scrutiny of health and safety management is provided by an Operational Scrutiny and Assurance Panel that receives assurance relating to health, safety, and compliance, in line with our obligations and policies. 

We also use learning from both inside and outside the housing sector to improve knowledge and ensure this informs anything we do. Our health and safety policies are in place to protect our colleagues and keep them safe in all that they do. 

Our colleague (including agency staff) recruitment processes and procedures minimise the risk of slavery or human trafficking taking place within our organisation, including: 

• appropriate checks are carried out on potential employees to confirm that they are legally entitled to work in the UK.
• DBS checks have been expanded across the organisation to include all frontline employees.
• written contracts of employment are in place for all employees; and
• our recruitment and onboarding processes meet “safe recruitment” principles where applicable, as defined by our regulators such as CQC. 

We will continue to raise awareness of the signs of modern slavery and human trafficking throughout the organisation. We aim to create an environment where colleagues feel able to openly share any concerns and provide restorative practice training to support a culture of open and honest communication. 

Confidential avenues for raising concerns are also available, with a Probity and Integrity Policy and Speak Up procedure available. We have actively promoted our Speak Up approach via colleague communications, ensuring everyone understands the different channels available to them to speak up, and the importance of doing so.  We’ve also had a regular pipeline of colleague communications to ensure understanding of safeguarding, health and safety and procurement processes across the workforce. 

All colleagues across Aster Group, including permanent staff and agency workers, are required to complete mandatory safeguarding training. Completion rates are monitored centrally, and refresher training is delivered in line with Care Quality Commission (CQC) requirements for regulated services, particularly where colleagues interact with vulnerable customers. 

Safeguarding training includes modules on recognising signs of trafficking, exploitation, and slavery, although it is not exclusively focused on modern slavery. These modules help colleagues identify subtle indicators of abuse and understand the importance of reporting concerns through our safeguarding procedures. Leaders within our landlord function receive enhanced safeguarding training, which includes more detailed content on modern slavery and human trafficking.

To strengthen our organisational response, we have made Diversity & Inclusion and Modern Slavery e-learning mandatory for all colleagues. This training is: 

• Completed annually, with updates incorporated based on changes in legislation, guidance, and internal policy.
• Developed collaboratively with internal subject matter experts and external partners, including safeguarding professionals.
• Reviewed annually to ensure relevance and effectiveness, with feedback from learners used to improve content and delivery.

 Training covers: 

• Definitions and types of modern slavery and human trafficking.
• Risk factors and vulnerable groups.
• Legal responsibilities under the Modern Slavery Act 2015.
• Reporting mechanisms and whistleblowing procedures. 

Our commitment to continuous improvement means we regularly assess training effectiveness through completion tracking and compliance dashboards, post-training surveys, and integration of lessons learned from safeguarding cases and audits. 

All policies have an approval process that must be followed. Key stakeholders are consulted before the policy is scrutinised and approved by the appropriate panel or governing body within the business. When appropriate, we consult with and get customers' approval through our involved customer groups. This feedback enables us to improve policies and ensure opportunities to prevent or recognise slavery or human trafficking are not missed.

This statement and our legal requirements under the Modern Slavery Act 2015 have been scrutinised and discussed by our Board and our Operational Scrutiny & Assurance Panel. These panels provide oversight and scrutiny throughout senior parts of the business and recognise the importance we place on getting our approach right. 

Our established Risk and Compliance team uses a management system to record and monitor risks and compliance within the business. It identifies when monitoring or action is required and ensures there are owners of risks and actions.