wdh

Modern Slavery Act - Slavery and Human Trafficking Statement

Introduction

This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2017/2018. 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 creating a model for sustainable living in mixed tenure communities 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'.

We take 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 Regulator of Social Housing (RSH). 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 the wider region. 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.

  • Wakefield and District Housing Limited, A charitable Community Benefit Society; registered number: 7530
  • 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 2017/2018, we spent £77m, excluding VAT, on externally sourced goods and services. This comprised spend with 932 separate supplying organisations, of which 47% was with local businesses. 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

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 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, Organisational Development Plan and Whistleblowing Code of Practice.

All our employees and representatives have an individual and collective responsibility to bring to the attention any knowledge or concerns they have or are aware of where providers of services to us fall short of the standards expected.

We have employment practices, which ensure a standardised, fair and transparent approach to the employment and management of our 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.

Through the procurement process organisations must demonstrate they also have policies that promote transparency, equal treatment and opportunity in line with both best practice and legislative requirements. This requirement is audited against our ISO 18001 accreditation.

Specific Action

  • We review all our policies and issue guidance on a regular cyclical basis. Any changes to the MSA will be implemented as part of the regular reviews.
  • Following a series of awareness and training events held during 2017 our training modules have been updated to consolidate knowledge and understanding. We run a robust Corporate Induction process which all new employees complete.

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.

Specific Action:

  • Between 1 April 2017 and 31 March 2018, we have completed 1,823 periodic tenancy visits (6% of our housing stock) where tenants have been visited to check on property condition and compliance with their tenancy agreement. This is an opportunity to identify any inappropriate use of our properties including signs of potential modern slavery issues. None were identified.
  • We are members of the multi-agency Wakefield Serious Organised Crime (Bronze) Group. This group is led by West Yorkshire Police and meets quarterly to review and update partner agencies on organised crime within the district and the profile of actual crime groups that have been officially registered as such by the Police. Although the criminal activity of such groups is wide ranging, the forum also focuses on the possible impact on human trafficking / modern day slavery and whether this is a feature of such criminal activity.
  • We have now completed a restructure of the way that estate management services are delivered in our estates and implemented a focused approach to improving environmental quality and local visibility / accountability.
  • We provide a proactive tenancy and estate management service with employee resource dedicated to being visible and accountable within the neighbourhoods we serve. The role of the Estate Officer (Neighbourhood / Case Worker), in particular, is estate based and is at the forefront of community engagement working with residents to help address local issues or concerns.
  • Five seconded Police Constables (Tenancy Support Officer) working within our Community Safety Team also support local estate management services. Any community intelligence or concerns over potential human trafficking / modern day slavery is immediately fedback to West Yorkshire Police through the Tenancy Support Officers to enhance wider intelligence gathering and help develop more targeted police action that may need to be taken.
  • We hold regular partnership tasking meetings. These Neighbourhood Co-ordination Groups are made up of partners from the Police and other agencies within local management areas, sharing insight and information regarding priority issues and perpetrators of crime and antisocial behaviour across our seven neighbourhood areas. In addition, our Community Safety Manager and Area Managers meet with local Police Inspectors on a quarterly basis regarding wider strategic neighbourhood priorities and further joint working initiatives, including the challenges facing both us and our partners and how these can be overcome.

Supply chain

Our procurement requirements are varied in nature across the organisation, reflecting the wide scope and diversity 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.

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.

Specific Action:

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.

We actively engage with our existing supply chain through effective contract management and regular performance reviews. This further supports our commitment to managing relationships with our suppliers but also ensuring the responsibilities under the MSA are continually monitored throughout the life of a contract, especially so for all high risk procurements and services relating to the MSA and businesses with an annual turnover exceeding £36m.

We also utilise several national consortia and framework agreements, which are carefully checked for compliance with and adherence to the provisions of the MSA. Working closely with such existing procurement vehicles enables us to further embed our commitment to the highest standards of ethics within our supply chain and ensuring that suppliers we work with can demonstrate that they provide safe working conditions, treat workers with dignity and respect and act ethically within the law.

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 2017/2018.

Approved by the Board of Directors

Signed by: Stephen Green, Board Chair

Date: 13 September 2018