This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2016/2017. The statement seeks to
provide assurance as to the measures taken or to be taken to ensure that no incidents of slavery and human trafficking take place
in either its supply chain or in any other part of its business.
We fully support and commit to the intent of the legislation that closely matches and aligns with our own commitment and aspiration
to be a business with a social conscience. As a social housing landlord we are committed to overcoming disadvantage and promoting
opportunity through whatever means are available. Our strategic organisational value proposition is to be an organisation which is
‘creative, inclusive and works with integrity'. Our strategic milestone to 2020 is to be ‘an enterprise with social impacts'.
In 2015, we were a European Foundation for Quality Management (EFQM) Business Excellence Award winner and in 2017 were rated as a
platinum business as part of the launch of the EFQM global index programme.
Accordingly, the WDH Board takes a zero tolerance position on slavery, servitude or forced or compulsory labour and human trafficking
in both this organisation and those with whom we have a business relationship.
WDH is a registered social housing provider regulated by the Homes and Communities Agency (HCA). It was formed as a
large scale voluntary stock transfer from Wakefield Council, established in March 2005. We own and manage over 31,000
properties within the Wakefield district and our range of housing comprises general needs rented housing, supported and
sheltered living and shared ownership. We also build houses for commercial sale and offer services to other registered
social landlords and customers. This includes a 24 hour emergency alarm responder service, a debt consultancy service
and a commercial construction and maintenance services subsidiary.
In addition, we have a shared services agreement with other social landlords to provide maintenance services. Through
this agreement we provide maintenance services to a further 14,000 properties throughout the North of England. We are
also a significant regional employer undertaking the provision of the majority of our services through our own in house teams.
This Statement applies to the following businesses that WDH either fully owns or has a financial and commercial interest in.
For the avoidance of doubt, only Wakefield and District Housing Limited has a current turnover above the £36m annual threshold
for reporting purposes.
In the financial year 2016/2017, we spent £58 million, excluding VAT, on externally provided goods and services. This comprised spend with
945 separate supplying organisations. The range of goods and services procured was wide ranging and diverse but the largest grouped spend
areas are listed below.
This is reported by reference to the key business and risk areas relevant to the provisions of the Modern
Slavery Act 2015 (MSA).
We directly employ over 1,400 personnel within our operations and have a robust suite of Human Resources (HR) policies
that promote transparency, equal treatment and opportunity in line with both best practice and legislative requirements.
Under the particular requirements of the MSA the following policies and guidance have been identified as of direct relevance.
These include the Code of Conduct, Recruitment and Selection Policy, Agency Workers Policy, People Strategy and Whistleblowing
Code of Practice.
We have employment practices, which ensure a standardised, fair and transparent approach to the employment and management
of its workforce. This includes pre employment checks that identify the right to work and previous employment history and
a remuneration policy based on standardised employment packages linked to defined job roles. On those occasions when
temporary agency employment is required, the same requirements are expected and mandated as from our own processes.
We continue to be vigilant and proactive in ensuring that all tenancies are managed lawfully and in accordance with the tenancy agreement and
management policies. We have a visible and proactive presence on our estates through the work of our neighbourhood management teams and engage
with the local community through both formal and informal means. Where reports of alleged criminal and / or inappropriate behaviours are received,
then we will act swiftly and in partnership with key agencies to ensure that all intelligence is shared and joint actions taken. Where we identify
or receive neighbourhood information regarding activity that may specifically alert to human trafficking or modern day slavery, then immediate contact
will be made with the Police and Wakefield Council's Safeguarding Team, using existing means of information exchange.
External procurement requirements are varied in nature reflecting the wide scope of activities within the business. All tier one or end suppliers to us are located within the UK reducing the international risk dimension. The supplier base does vary in size with not all subject to the requirements under the MSA. The following have been identified as the high risk areas that will require most surveillance and due diligence.
All standard terms and conditions for the procurement of goods and services have been amended to include MSA provisions, as has the relevant procurement procedures guidance document for employees. We have adopted the Cabinet Office Supplier Questionnaire for MSA screening of suppliers involved in higher value projects, whilst amending our own supplier due diligence questionnaire. During 2016/2017, an exercise has been undertaken to make all current suppliers aware of the provisions of MSA and what we may require going forward. This targeted many suppliers where economic activity may be defined as being within the potential scope of MSA provision; irrespective of whether they had a turnover above the £36 million statement threshold and had a compliance duty.
Our philosophy is that the Act’s ethos and requirements are valid irrespective of the size of turnover. Of the 930 suppliers registered on our purchase ledger system and in regular use during the year, responses were received from approximately one third. From that, concentrated effort has been placed on the top 100 suppliers who accounted for 83.7% (£37.1m) of the regular expenditure and are key suppliers of relevance to MSA. Only one supplier out of the top 100 has not replied and whom we believe will be subject to the provisions of the Act.
Future developments will now concentrate on developing an approach that can be utilised when high risk procurements as it relates to MSA is undertaken.
This Statement is made in accordance with s54 of the Modern Slavery Act 2015 and constitutes the WDH position on slavery and human trafficking for the completed financial year 2016/2017.
Approved by the Board of Directors
Signed by: Stephen Green, Board Chair
Date: 14 September 2017