Slavery and human
About The Guinness Partnership
We are one of the largest providers of affordable housing and care in England. We own and manage nearly 65,000 homes, and provide housing services for more than 135,000 customers. We also provide care services to more than 10,000 people.
Our core activities are delivered by more than 3,000 staff in the UK and comprise: developing and managing housing for social rent, affordable rent and affordable home ownership; delivering housing and care services for older people; and providing 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 pursuant to section 54(1) of the Modern Slavery Act 2015 (“the Act”) and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2017. It applies to all legal entities that form part of The Guinness Partnership Group.
We are opposed to slavery and human trafficking. We will do what we can to combat such abuses in our business and in our supply chains.
We will act ethically and with the highest standards of integrity, quality, probity, openness and accountability in all our business operations and relationships.
We will develop, implement and enforce processes and controls that seek to ensure slavery and human trafficking is not taking place within our business nor in our supply chains.
We will not knowingly deal with any business involved in slavery or human trafficking.
In our own business
We believe there is a low risk of slavery and human trafficking within our operations. Potential risks are mitigated by our policies and procedures, controls built into our business operations and the knowledge, skills and behaviours of our staff.
Among the policies that are relevant to slavery and human trafficking are:
- Disciplinary policy
- Recruitment and selection policy
- Diversity and inclusion policy
- Anti fraud policy
- Code of conduct for members and staff
- Code of conduct of suppliers and contractors
- Staff whistleblowing policy
- Anti bribery and anti corruption policy
- Private use of contractors or consultants policy
- Code of governance
- Conflicts of interest policy
- Tenancy fraud policy
- Safeguarding adults, children and young people policy.
In 2016/17, we reviewed the whistleblowing policy to ensure staff can come forward and share their concerns. We also reviewed the disciplinary policy to ensure action can be taken where necessary.
We will continue to review and update relevant policies and procedures so that we take effective and proportionate steps to ensure there is no slavery and human trafficking in our business.
In our supply chain
Our procurement activities take place in England and our contractors and suppliers are predominantly UK based. We engage with a wide variety of organisations for a broad range of goods and services which are primarily corporate, construction and property related, but also to meet some more specialist requirements.
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 and suppliers who adhere to all appropriate legislation, regulation and practices. Our contract management arrangements help us ensure they maintain the standards required, including the prevention of slavery and human trafficking.
In 2016/17 we contacted all existing suppliers to inform them of our commitment to combat slavery and human trafficking and sought assurance that they comply with the Act. In addition, we have required that suppliers are compliant with the Act where a contract has been renewed during the year, or any new contract has been entered into.
We will continue to ensure that our approved suppliers take appropriate steps to comply with the Act and require new suppliers to declare that they are not involved in slavery or human trafficking.
We have not identified any breaches of the Act during 2016/17. We will continue to be vigilant and where a compliance breach is identified, we will act promptly, involve the appropriate lead agencies and feed back lessons learnt in order to minimise the risk of an incident occurring again.
Training and awareness
In 2016/17, we raised awareness of modern slavery and human trafficking through the publication of this statement and have considered where the risk may arise in our business and supply chain.
We may come across slavery and human trafficking in connection with the customers we support. In addition, our homes could be a potential base for modern slavery. We have robust safeguarding procedures in place and we have delivered training to encourage key customer facing staff to identify and report concerns.
We will continue to raise awareness and deliver training to new and existing staff and we will extend this to our suppliers and contractors, where appropriate.
This statement was approved by the Board. It will be reviewed on an annual basis.