Modern Slavery Statement 2025/26

Introduction 

At Aster Group, what we do enables better lives. We recognise our responsibility to prevent, identify and respond to modern slavery and human trafficking risks within our organisation, our communities and our supply chains. 

Modern slavery remains one of the most serious abuses of human rights and can exist in every sector, community and geography. As a housing association, developer, care and support provider, employer and purchaser of goods, works, and services, we recognise the important role we play in helping to identify vulnerability, protect individuals at risk of exploitation, and promote ethical practices throughout our operations and supply chains. 

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and sets out the steps Aster Group has taken during the financial year ending 31 March 2026 to prevent modern slavery and human trafficking.

Our structure, business, and supply chains 

Aster Group is a housing association which provides quality, affordable homes to thousands of people across the south of England and London. Its vision is that everyone has a home.  

The not-for-dividend business was established in 1990 and has £2.7 billion worth of social housing assets. The Group reinvests profits from open market sale and shared ownership to support the development of affordable homes. It owns and maintains over 38,000 homes and employs over 2,000 people. 

Aster Group is committed to playing its part in tackling the housing shortage by delivering a wide range of housing options. During 2025/26 the business delivered 978 homes offering affordable and social rent, shared ownership and open market sale options. 

Aster is relentless in its mission to extend a positive impact into its communities. This is achieved in many ways including its entities, Enham Trust, Central and Cecil Housing Trust (C&C), East Boro Housing Trust (EBHT) and the Aster Foundation. Our structure can be found here. 

We maintain a zero-tolerance approach to slavery, servitude, forced labour, compulsory labour and human trafficking. We recognise that modern slavery risks may arise within:

  • Our Communities

We own and maintain over 38,000 homes and support a diverse customer base across a wide geographical area. Through our housing, care and support services we regularly engage with individuals who may be vulnerable to exploitation due to age, disability, poor physical or mental health, financial hardship, domestic abuse, social exclusion or other circumstances. We understand that modern slavery and human trafficking can occur within communities and remain vigilant in identifying indicators of exploitation. 

  • Our Workforce

We employ over 2,000 colleagues and engage agency workers and specialist contractors where appropriate. We recognise that labour-intensive sectors and temporary workforce arrangements can present increased risks and therefore maintain robust recruitment, right-to-work, safeguarding and workforce assurance processes. 

  • Our Supply Chains

We spend more than £200 million annually with suppliers, contractors and partners in support of housing management, development, maintenance, care, support and corporate services. Whilst most of our suppliers are UK-based, we recognise that some supply chains extend internationally and require enhanced scrutiny and monitoring.

Governance and Accountability 

The Overlap Boards retain ultimate responsibility for ensuring that effective measures are in place to identify, prevent and respond to modern slavery and associated risks. 

Our governance framework includes oversight through:

  • Aster Group Limited Board
  • Executive Board
  • Operational Scrutiny and Assurance Panel
  • Safeguarding Panel
  • Risk and Compliance Team 

Modern slavery risks are incorporated within our wider governance, safeguarding and risk management arrangements, enabling effective escalation, monitoring and scrutiny. The Board receives assurance regarding the effectiveness of controls, key risk indicators, safeguarding activity and compliance with relevant policy requirements. 

We review the effectiveness of our approach through a range of assurance activities, including safeguarding reporting and case reviews, training compliance, supplier due diligence, Speak Up disclosures, internal audits and policy compliance monitoring. Together, these activities help us to identify areas of good practice, emerging risks and opportunities for continuous improvement.

Our policies 

Our commitment to preventing modern slavery is supported by a suite of policies and procedures which promote ethical conduct, protect vulnerable individuals and ensure compliance with relevant legislation. 

Policies and procedures include: 

  • Anti-Modern Slavery and Human Trafficking
  • Safeguarding Children
  • Safeguarding Adults at Risk
  • Procurement and Contract Standing Orders
  • Diversity and Inclusion
  • Probity and Integrity
  • Anti-Money Laundering
  • Group Health and Safety
  • Talent Acquisition 

All Aster Group policies follow a structured lifecycle to ensure they remain current and effective. They are developed collaboratively by subject matter experts and operational teams, reviewed at least every three years or sooner if required, and consulted on with internal stakeholders and, where appropriate, customer groups. Policies are scrutinised and approved by governance panels such as the Operational Scrutiny and Assurance Panel and the Executive Board. Once implemented, compliance is monitored through audits, dashboards, and feedback mechanisms, with corrective actions taken where necessary. 

During 2025/26, we embedded the revised Safeguarding Adults at Risk and Safeguarding Children policies introduced in the previous reporting period. Oversight has continued through our Safeguarding Panel, which has led a programme of improvements to strengthen safeguarding arrangements, including the development of a role-specific training approach to ensure colleagues have the knowledge and confidence to recognise and respond to safeguarding concerns. 

We also launched The Aster Way Culture Handbook, which brings together our values, behaviours and expectations, reinforcing our commitment to creating a safe, inclusive and respectful working environment where colleagues feel empowered to speak up. Alongside this, we introduced the Aster Leader Playbook, providing leaders with practical guidance to lead consistently, support their teams and foster a culture where safeguarding, ethical conduct and accountability are embedded in everyday decision-making.

Our Operations 

We have numerous processes that allow us to manage the risk of slavery or human trafficking within our business activities, including: 

   a: Safeguarding 

Safeguarding is fundamental to our approach to preventing, identifying and responding to modern slavery and human trafficking. We are committed to ensuring colleagues have the knowledge, confidence and support to recognise concerns and take appropriate action. 

All safeguarding concerns are reported through our centralised system, enabling effective recording, monitoring, scrutiny and organisational learning. Our Safeguarding Panel continues to provide oversight of safeguarding arrangements, review casework, monitor performance and drive continuous improvement activity. Following the completion of our safeguarding audit, the Panel has increased the number of safeguarding deep dives undertaken, providing greater assurance through the review of a higher volume of cases, trends and learning opportunities. 

During 2025/26, we continued to strengthen our safeguarding framework through a range of improvements, including refreshing safeguarding e-learning, undertaking a training needs analysis and delivering the first phase of role-specific classroom training to identified colleague groups. We also reviewed and refined our DBS checking matrix, commenced a programme of re-checks and established a clear process for volunteers. 

To further strengthen safeguarding awareness, we improved communications relating to safeguarding responsibilities, including guidance on responsible adult requirements and regular customer communications on safeguarding-related topics, such as radicalisation. We also developed a Strategic Safeguarding Plan to 2030, providing a clear framework for the continued enhancement of safeguarding arrangements across Aster Group. 

   b: Procurement

Recognising the important role procurement plays in preventing modern slavery, we continue to strengthen our approach in line with the Procurement Act 2023 and wider expectations relating to responsible procurement and supply chain management. 

During 2025/26, we:

  • Improved visibility of modern slavery obligations throughout our tender and contract documentation.
  • Increased collaboration between procurement, safeguarding, and operational teams to support the identification and management of potential risks.
  • Further developed supplier onboarding, due diligence and assurance activities. 

We expect our suppliers and contractors to share our commitment to preventing modern slavery and human trafficking. Suppliers are required to:

  • Comply with the Modern Slavery Act 2015 and all relevant legislation.
  • Demonstrate that appropriate policies and controls are in place.
  • Assess and manage modern slavery risks within their own operations and supply chains. 

We continue to utilise procurement framework agreements that assess suppliers against modern slavery requirements as part of eligibility and selection processes. 

   c: Health and Safety 

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.

   d: Risk and Compliance 

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. 

We minimise the risk of slavery and human trafficking through our:

  • policies and procedures relating to our people and procurement practices, and
  • effective risk management and scrutiny within the businessTalent Acquisition and People Services 

   e: Talent Acquisition and People Services 

Our recruitment processes and procedures, including those relating to agency workers, are designed to minimise the risk of modern slavery and human trafficking within our workforce. These include: 

  • Carrying out appropriate pre-employment checks to confirm all colleagues are legally entitled to work in the UK.
  • Extending DBS checks across the organisation to include all frontline colleagues.
  • Ensuring all colleagues are employed under written contracts of employment. 

Our colleagues are paid at least the minimum wage, and for customers, we have a Financial Wellbeing Team that supports those on some of the lowest incomes to maximise their income. 

During 2025/26, our care services implemented a workforce platform that provides access to carefully vetted agencies operating to high recruitment and compliance standards. Alongside this, we have continued to apply robust safe recruitment practices, where required by regulators such as the Care Quality Commission (CQC), including enhanced right-to-work, visa and compliance checks, providing additional assurance that our employment practices remain fair, lawful and ethical. 

We continue to raise awareness of the signs and indicators of modern slavery and human trafficking across the organisation. Through ongoing training, communications and restorative practice approaches, we seek to create an environment where colleagues feel confident to raise concerns, share experiences and engage in open and honest conversations. 

Colleagues have access to a range of confidential channels for reporting concerns, supported by our Probity and Integrity Policy and Speak Up Procedure. Throughout the year, we have actively promoted our Speak Up approach through colleague communications to ensure colleagues understand the reporting channels available to them and feel empowered to use them. 

   f: Learning and Development 

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, Diversity & Inclusion and Modern Slavery e-learning is 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.

Looking Ahead: 2026-27 Priorities 

We remain committed to playing our part in tackling modern slavery and human trafficking and to ensuring our homes, workplaces and supply chains remain safe, ethical and inclusive. 

During 2026/27, we will continue to strengthen our approach by: 

  • Enhancing oversight through the appointment of a dedicated Safeguarding Trustee, providing additional scrutiny and challenge to support our arrangements.
  • Strengthening supply chain assurance by developing and implementing an approach to embed DBS requirements into relevant procurement specifications and contractual arrangements.
  • Further improving workforce safeguards by establishing a more structured framework for the engagement of agency workers, interim resources and consultants.
  • Embedding modern slavery considerations within contract management, increasing visibility of supplier obligations and strengthening ongoing monitoring and assurance activities across higher-risk contracts. 

Declaration 

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 on behalf of Aster Group Limited and its subsidiaries for the financial year ended 31 March 2026. 

It was approved by the Board of Directors of Aster Group Limited on 08 September 2026.

Modern Slavery Policy

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