Modern Slavery Act - Slavery and Human Trafficking Statement


This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2015/2016. 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.

WDH fully support and commit to the intent of the legislation which 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.

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.

Our structure and business

WDH is a registered social housing provider regulated by the Homes and Communities Agency. It was formed as a large scale voluntary stock transfer from Wakefield and Metropolitan District 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 12,000 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 which 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 £38m annual threshold for reporting purposes.

  • Wakefield and District Housing Limited, Company number: 04948519
  • WDH Solutions Limited, Company number: 05802087 - Subsidiary
  • Northern Shared Services Limited, Company number: 08466580 - Subsidiary
  • Bridge Homes (Yorkshire) LLP. Company number: OC394414 - Joint Venture

In the financial year 2015/2016, WDH spent £61m, excluding VAT, on externally provided goods and services. This comprised spend with 990 supplying organisations. The range of goods and services procured was wide ranging and diverse but the largest grouped spend areas are listed below.

  • New build construction.
  • Property phased capital renewals.
  • Vehicles.
  • Utilities.
  • Maintenance materials.
  • Consultancy and professional services.
  • Accommodation cleaning.
  • Insurance.
  • Grounds and environmental maintenance.
  • Communications and IT services.

Our policies and due diligence in relation to slavery and human trafficking

This is reported by reference to the key business and risk areas relevant to the provisions of the Modern Slavery Act 2015 (MSA).

  • Human Resources.
  • Property and tenancy management.
  • Supply chain.

Human Resources

WDH directly employs over 1,450 personnel within its operations and has 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.

WDH has 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.

Future action

  • WDH reviews all its policies and issued guidance on a regular cyclical basis. Over the next year it will review its HR policies specifically with regard to MSA and any amendments that are considered desirable in the light of agreed best practice. An initial assessment has indicated that no significant changes are immediately required.
  • Build on briefings already provided to senior management and key staff groups to raise awareness of the potential risks posed by modern slavery, forced labour and human trafficking throughout the organisation.

Property and tenancy management

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.

Current actions:

  • Our Safeguarding Children and Vulnerable Adults Guidance document provides a reference point for employees to help identify potential cases of abuse and how this should be reported both internally and to other relevant agencies.
  • Continue to develop and deliver a programme of periodic tenancy visits to monitor compliance with the tenancy agreement and undertake identification checks on residents.
  • Undertake measures to both detect and deter tenancy fraud within neighbourhood services to help prevent the misuse of our property.
  • Provision of seven Police Constables (Tenancy Support Team) within WDH to help deal with antisocial behaviour and facilitate the direct exchange of neighbourhood intelligence with more specialised Police teams if criminality is reported.
  • WDH attendance at weekly tasking meetings involving Police and other partner agencies where local priorities regarding community safety are actioned.
  • We have become an inaugural member of the recently formed Wakefield Human Trafficking and Modern Day Slavery (HTMDS) Network. This is a multi-agency partnership in the Wakefield area set up to address local MSA requirements.

Future action

  • Safeguarding Children and Vulnerable Adults Guidance document and neighbourhood management procedures are reviewed in the light of changes which might be applicable under MSA.
  • Maintain membership of the HTMDS Network and contribute to the future development and roll out of any agreed action plan.

Supply chain

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.

Since the Act was published, all standard terms and conditions for the procurement of goods and services have been amended to include MSA provisions. The recently updated procurement procedures now include specific reference to MSA and the need for a risk based approach to identification and mitigation of vulnerable areas of procurement activity.

Initial assessment of risk has identified that our geographic location and the nature of demand for the consumption of services is likely to lead to a lower level of potential risk than in other sectors and localities. From the initial assessment, the following areas are determined to be of higher risk and consequently liable to require closer assessment.

Procurement of high risk products

  • Clothing - Uniforms / PPE.
  • Food and constituent commodities.
  • Products made from mineral type commodities.

Low paid / low skilled service type work

  • Security guarding, cleaning, care services.
  • Labouring and unskilled construction work.

Future action

  • Further analysis of the supply chain and its tiers to identify levels of potential risk and risk assurance requirements.
  • Where suppliers are not subject to MSA turnover reporting provisions to bring the requirements of the Act to their attention.
  • Revise current procurement documentation issued to suppliers including contractor behaviour code and tender and quote processes.

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 2015/2016.

Approved by the Board of Directors

Signed by: Stephen Green, Board Chair

Date: 15 September 2016