Modern Slavery Statement 2020/21
This statement sets out our actions to ensure modern slavery does not exist within our own business or across our supply chain for the year ended 31 March 2021.
We are committed to ensuring modern slavery does not occur in our business or supply chain. We will adopt procedures and policies which address the risks of violations of anti-human trafficking and anti-modern slavery laws, and we expect other organisations that we work with to adopt and enforce policies to comply with the legislation.
Our Modern Slavery and Human Trafficking Policy reflects our commitment to acting ethically and with integrity across our own activities and to provide assurance we have effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains.
Our approach to modern slavery is reflected in our culture of trusting, respecting and empowering people.
We are working towards our vision of ensuring everyone has a home. Our purpose is to provide safety and security through our reliable landlord and independent living services, and we supply a wide range of housing options in response to the housing crisis Founded in 1990, today the Group manages over £1bn of property assets and employs over 1,300 people.
We operate as a not-for-dividend business, aiming to generate a financial surplus each year that we can reinvest back into our organisation – with a focus on building more new homes. We are spending £2.1bn on new housing development programme over our seven-year plan, across a mix of tenure types, which will see us build approximately 10,000 homes.
As well as Aster Group Ltd (29573R), this statement covers all the subsidiaries detailed in the diagram below:
Our supply chain
Our supply chain is varied and falls into the following main areas:
Development – our property construction business
Customer Services - – management and maintenance of our property portfolio, community care and support services for our customers
Aster Group – central functions which support the business.
We typically spend 60 – 65% of our annual revenue with our suppliers, equating to circa £100m per annum.
Supply chain approach
We have an extensive supply chain of contractors, suppliers, and partners. Some of our suppliers’ subcontract work or rely on recruitment agencies to supply temporary or permanent staff.
By the nature of their businesses, some of our suppliers are potentially at higher risk of exposure to modern slavery than others, for example, construction companies.
We require all our suppliers, delivery partners, organisations within our frameworks and other suppliers we engage with to ensure their goods, materials and labour-related supply chains fully comply with the Modern Slavery Act 2015.
We have implemented clear procurement policy principles and procedures that we expect all our stakeholders to comply with, which include a commitment to the following:
- declaration of interest
- systems and processes to measure procurement performance
- due diligence given to addressing issues of equalities and diversity.
- in procurement exercises staff will have regard to improving the economic, social, and environmental impact, benefits, and risks in the area in which that exercise takes place.
- We are conscious that there may be new or increased modern slavery risks in our operations and supply chains. We undertake regular risk assessments and review risks to ensure they are appropriately considered and mitigated against.
Our people approach
Within Aster, our recruitment and people management processes and policies are designed to make sure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment. They include:
- carrying out pre-employment checks such as right to work in the UK by the production of appropriate original documentation, DBS (where applicable) and references.
- paying at least the national living wage in line with Living Wage Foundation.
- implementing appropriate grievance procedures and having a comprehensive Speak Up Policy, with breaches managed under the Disciplinary Policy and Procedures; and
- having a robust framework of health and safety policies and procedures overseen by our Health and Safety Panel.
Colleagues with any evidence of non-compliance with the Act, including any concerns about our supply chains or about any issues relating to our residents should refer to the Safeguarding Policy and are encouraged to use our Speak Up Policy.
The requirements of the Act and this statement have been discussed at our Corporate Performance and People Panel, Risk and Compliance Committee and our Board has approved this annual statement and provides oversight to our approach.
Awareness raising articles have been published on our intranet site (AsterNet) to remind colleagues of the importance of continued vigilance. We have a range of probity policies that are regularly reviewed, and which cover a variety of subjects, including safeguarding and whistleblowing. We ensure that all staff are required to read and acknowledge these policies upon joining the Group and they are encouraged to review their knowledge via awareness-raising exercises.
We have reviewed our existing policies and procedures considering the Act:
- The Aster Way.
- Diversity and Inclusion Policy
- Gifts, Hospitability and Anti-Bribery Policy
- Anti-Modern Slavery Policy
- Anti-Money Laundering Policy
- Management of Contractors Procedure
- Speak Up Policy
- Health and Safety Policies
- Safeguarding Policy; and
- Recruitment and Selection Policy and Procedures.
Actions for 2021/22
We will continue to make our staff aware of the Modern Slavery Act through our intranet and will seek to launch an e-learning module to increase awareness further.
We will carry out ongoing due diligence to support procurement and contract management.
We will carry out spot checks and audits of suppliers to ensure that we are proactively seeking assurance on supplier compliance with the Act.
We will implement appropriate KPIs to monitor the effectiveness of our controls over modern slavery and human trafficking.
We will continue to remind staff that any concerns that they have should be acted upon and will be treated in the strictest confidence and that our Speak Up Policy offers guidance and support should they wish to do so.
We will continue to review our risk management framework to ensure that the relevant risks are up to date and any new risks that have been identified are included and appropriately mitigated.