Slavery and human
trafficking statement

About The Guinness Partnership

We’re one of the largest providers of affordable housing and care in England. We own and manage nearly 60,000 homes, and provide housing services for more than 120,000 customers. We also provide care services to more than 10,000 people. Our core activities comprise: housing for social and affordable rent; affordable home ownership; housing and care services for older people; and support for customers who might need extra help with issues like managing their money or getting into work. Our social purpose means that any surplus we make is re-invested in new and existing homes and improving our services for the benefit of our customers and their communities.

Our activities are regulated by the Homes and Communities Agency (HCA) and the Care Quality Commission (CQC).

Purpose and scope of this statement

This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2016. It applies to all legal entities that form part of The Guinness Partnership Group.

Our commitment

We are opposed to slavery and human trafficking and are committed to doing what we can to combat such abuses in our business or in our supply chains.

We are committed to acting ethically and with the highest standards of integrity, quality, probity, openness and accountability in all our business operations and relationships.

We are committed to developing, implementing and enforcing processes and controls that seek to ensure slavery and human trafficking is not taking place within our business or in our supply chains.

We will not deal with any business knowingly involved in slavery or human trafficking.

Risk assessment – our business

We believe that there is a low risk of slavery and human trafficking within our operations. Any potential risk is mitigated as a result of our policies and procedures, the controls built into our business operations and the knowledge, skills and behaviours of our staff. In addition, we have processes in place to encourage the reporting of concerns and protect whistle blowers.

Our safeguarding and tenancy fraud policies and procedures enable us to take the appropriate action if slavery or human trafficking is identified within our homes or by our customers.

Risk assessment – our supply chain

Our procurement activities take place in England and our contractors and suppliers are predominantly UK based. Some of our suppliers subcontract work or rely on recruitment agencies to supply permanent or temporary staff. Whilst we consider that the risk in our supply chains is low, we recognise that no supply chain can be considered entirely risk free.

Our robust tendering process ensures we engage with reputable contractors who adhere to all appropriate legislation, regulation and practices. Our contract management arrangements help us ensure they maintain the standards required.

In 2015-16 we have:

  • Started to raise organisational awareness of this issue through the preparation of this statement
  • Agreed management responsibility for this statement
  • Implemented new safeguarding and tenancy fraud procedures and delivered training to staff.

In 2016-17 we will:

(a) Our direct operations

  • Raise general awareness amongst our staff of our commitment and encourage them to report concerns and ensure that these are acted upon
  • Deliver targeted training to embed the awareness
  • Co-operate with relevant authorities, and take appropriate tenancy enforcement action, where cases of slavery and human trafficking are identified within our homes or by our customers
  • Compare our activities against those undertaken by similar organisations in order to benefit from best practice
  • Review and update relevant internal policies and procedures to ensure we are taking effective and proportionate steps to ensure there is no slavery or human trafficking in our business.

(b) Our supply chains

  • Raise awareness of this issue, and our commitment, amongst our suppliers and require them to take appropriate steps to ensure that there is no slavery or human trafficking in their business or supply chains
  • Require new and existing suppliers to declare that they are not involved in slavery or human trafficking and are fully compliant with the Modern Slavery Act 2015
  • Monitor our business and our supply chains to ensure we have no association with slavery and human trafficking
  • Act promptly where a compliance breach has been identified, feedback lessons learnt and work with the supplier to minimise the risk of this occurring again.

This statement was approved by the Executive Team. It will be reviewed on an annual basis.