Modern Slavery Statement 2022/23
What we do enables better lives. We have a responsibility to prevent and recognise slavery and human trafficking within our business and supply chains. We will never knowingly support or deal with any business whose operations involve slavery or human trafficking in any way.
This statement (made under section 54(1) of the Modern Slavery Act 2015) sets out the steps we have taken during the 2022/23 financial year to prevent and recognise modern slavery. We are committed to continually improving our approach and have set out our intentions for the next year to ensure we do not knowingly have modern slavery or human trafficking within any part of our business or activities.
1. Our structure, our business, and our supply chains
We’re a registered housing association providing quality, affordable homes to thousands of people across the south of England and London. Our vision is that everyone has a home.
The Group manages approximately £2.2bn of social housing assets and employs over 1,900 people. As a not-for-dividend business, we reinvest profits from open market sale and shared ownership to support the development of affordable housing options for those in need. We provide safety and security through our reliable landlord, care and support, and independent living services.
Central and Cecil Housing Trust (C&C), East Boro Housing Trust (EBHT), and Enham Trust form part of the Aster Group our structure can be found here.
We have a zero-tolerance approach to modern slavery and trafficking both within our own business, by anyone employed by us and across our supply chains. We have controls and checks in place for all colleagues (including agency workers). We do not believe that we have any significant areas of risk within our workforce. We continually monitor any risks.
Our homes and customers are based in the south of England and London. Our contractors are also predominantly UK-based, although some have supply chains that carry out work worldwide (and may therefore contain greater risk). We know that some of our activities have a risk of slavery or human trafficking, such as within our:
- Communities: We own and maintain over 36,000 homes. We are alert to safeguarding concerns in every interaction that we have with our customers. We understand that modern slavery and human trafficking may be more common in communities where people are vulnerable, and we know that many of our homes are in underprivileged areas.
- Supply Chains: We spend approximately £80m through our supply chains providing decent, safe, and reliable homes. We recognise that there are some areas of our supply chains that may present more risk than others, such as sourcing uniforms and ensuring they have ethical supply chains. Our ambitious development programme relies on developers and housebuilders to ensure their construction supply chain is free of slavery and trafficking.
2. Our Policies
To prevent or assist recognising modern slavery or human trafficking, we have several policies and procedures in place, including:
- Anti-Modern Slavery and Human Trafficking
- Safeguarding Children
- Safeguarding Adults at Risk
- Procurement
- Diversity and Inclusion
- Gifts, Hospitality and Anti-Bribery
- Anti-Money Laundering
- Management of Contractors
- Speak Up
- Group Health and Safety
- Recruitment and Selection
- The Aster Way – (a set of behaviours that all Aster colleagues are expected to adhere to).
Every time a policy comes up for renewal it will be reviewed to see whether it is effective in helping to identify slavery or human trafficking. The review will also look to minimise the risk of either occurring within our business activities and supply chains. If not, we will consider explicitly referring modern slavery in the revised policy.
Our policies go through a set process for approval. This includes scrutiny and approval with relevant stakeholders.
3. Due Diligence Processes
We have numerous processes that allow us to manage the risk of slavery or human trafficking within our business activities, including:
a. Procurement:
We understand the importance of effective procurement processes preventing human trafficking and slavery within our supply chains. We have carried out an independent review of our centralised procurement service, which allows us to understand and strengthen any weaknesses. Within our centralised procurement process, we:
- Ask suppliers/bidders to agree to follow our Anti-Modern Slavery and Human Trafficking policy.
- Make use of standard terms and conditions so that suppliers must follow all related laws and regulations including the Modern Slavery Act 2015, referring to their, or their subcontractors’ supply chains.
- Have an approved supplier list which contains trusted suppliers.
- Make use of procurement frameworks, where suppliers set out their response to anti-modern slavery to participate.
b. Safeguarding and Health and Safety:
We take Safeguarding extremely seriously and work closely with partner agencies to respond to safeguarding concerns. We have safeguarding policies in place and expect all safeguarding concerns to be reported through an online platform that allows us to record, monitor and scrutinise whether that policy is being followed. Our dedicated safeguarding group considers any safeguarding concerns raised and assesses whether they have been dealt with in an acceptable way. We use safeguarding concerns to learn and make improvements to our processes.
We have a Health and Safety Operational Panel that manages risk relating to health and safety and compliance, in line with our obligations and policies. They 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.
c. Recruitment and HR:
Our staff (including agency staff) recruitment processes and procedures minimise the risk of slavery or human trafficking taking place within our organisation, i.e.
- Appropriate checks are carried out on potential employees to confirm that they are legally entitled to work in the UK. DBS checks are carried out where applicable and references are taken.
- Written contracts of employment are in place for all employees.
We will continue to raise awareness of the signs of modern slavery throughout the organisation. Colleagues are encouraged to report their concerns through our Speak Up Policy (whistleblowing). This includes concerns for colleagues or policies and practices. We also offer a free independent Employee Assistance Programme for our colleagues if they need support or advice.
We have a Grievance procedure for all colleagues. We also provide colleagues with restorative practice training.
d. Scrutiny:
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 Corporate Performance and People Panel. These panels provide oversight and scrutiny throughout senior parts of the business and recognise the importance we place on getting our approach right.
e. Risk and Compliance Management
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.
4. Identifying and minimising risks of slavery and human trafficking
We minimise the risk of slavery and human trafficking through our:
- Procurement processes, our policies and procedures relating to our people.
- Effective risk management and scrutiny within the business.
Our colleagues are paid at least the minimum wage, and we intend to consider the Real Living Wage for colleagues in the future. For customers, we have a Financial Wellbeing team that supports those on some of the lowest incomes to maximise their income.
We can use safeguarding knowledge and procedures to identify slavery and human trafficking through contact with customers, ongoing supplier and contract management, and time on-site during development activities. Training and increasing awareness of slavery and human trafficking throughout our organisation can ensure that these opportunities are not missed, and we provide mandatory online training to support this.
5. Our effectiveness in ensuring that slavery and human trafficking is not taking place
Our dedicated safeguarding group regularly monitors concerns raised by colleagues. We have developed multiple business performance dashboards that allow us to understand and scrutinise the data and information we have. This provides information on matters such as safeguarding, health and safety, people, training, and policy compliance.
6. Training
All our staff undertake mandatory safeguarding training, and we monitor whether this training has been completed. The signs of trafficking, exploitation and slavery may be subtle, and many signs will often raise alarm through our safeguarding processes and procedures. While this training is not specific to anti-modern slavery, it does have some information specific to slavery and trafficking. This allows colleagues to recognise safeguarding issues and emphasises the importance of reporting any concerns. Leaders within our landlord function have received enhanced safeguarding training which included modern slavery and human trafficking.
To be effective in recognising and preventing slavery or human trafficking we need to do more to equip our colleagues with the right knowledge. We have made our Anti-Modern Slavery and Human Trafficking e-learning mandatory training for all. We intend that more in-depth training will be given to those who scrutinise, sign-off policies and make decisions; those who procure goods and services; and those who manage our supply chains.
We have provided updates to everyone in the business on Anti-Modern Slavery to continue to raise awareness of it.
Action Plan for the coming year
We are committed to the continued improvement of our approach, and we understand that global events such as the war in Ukraine and the cost-of-living crisis within the UK increase the risks of modern slavery. Within the 2023/24 financial year, we will:
- Review our Anti-Modern Slavery and Human Trafficking policy and make this mandatory for everyone within the business to read and adhere to.
- Carry out a modern slavery risk assessment to identify risks within our business activities and develop individual action plans where needed. We will use our risk management system to monitor those risks and actions, to ensure that we continually seek to reduce the risk of slavery and human-trafficking.
- Continue to integrate any subsidiaries, ensuring that processes and procedures are all aligned.
- Consider what key performance indicators or operational performance indicators may be used to measure our effectiveness in ensuring that slavery and human trafficking is not taking place, and to consider incorporating them into our corporate performance framework.
- Use the findings from our Procurement Review to continue to improve our procurement process and continue to work across the business to provide support and share expertise to minimise the risk of modern slavery.
- Ensure that all our employees continue to receive at least the National Minimum Wage.