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 2021. In this Statement slavery and human trafficking is referred to as modern slavery. This Statement applies to all legal entities that form part of The Guinness Partnership Group. The Guinness Partnership’s subsidiaries are listed at the end of this Statement.
About The Guinness Partnership
We are one of the oldest and largest providers of affordable housing and care in England. We own and manage 64,000 homes and provide services to over 140,000 customers across the country. Guinness Property, our in-house maintenance service, delivers repairs to 56,000 of our homes, and Guinness Care, our care service, delivers almost 7,500 hours of care each week. Our purpose is to improve people’s lives and create opportunities for them.
Our core activities are delivered by more than 3,000 staff. They comprise developing and managing homes for social and affordable rent, 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 Regulator of Social Housing and the Care Quality Commission.
Our commitment
We are strongly opposed to modern slavery. We will do what we can to prevent and combat such abuses in our business, in our supply chains and in connection with the customers we support.
We act ethically and with the highest standards of integrity, quality, probity, openness and accountability in all our business operations and relationships. We are committed to being open and transparent in how we conduct our business and interact with customers and other stakeholders, and we publish a range of information relating to our approach to transparency and sharing information.
We will continue to develop, implement and enforce processes and controls that seek to ensure modern slavery is not taking place within our business, our supply chains, or in connection with the customers we support.
We will not knowingly deal with any business involved in modern slavery. If any is found in a supplier we are working with, we will act collaboratively with them to resolve and prevent further occurrences. Our relationship with our supplier may be terminated if a serious breach occurs, or if sufficient improvement is not made.
In our own business
We believe the risk of slavery and human trafficking within our operations is low. We will continue to be vigilant and where a compliance breach is identified, we will act promptly, involve the appropriate agencies and feedback lessons learnt in order to minimise the risk of an incident occurring again.
We have a staff whistleblowing policy which enables all employees or others with serious concerns over any aspect of our work to come forward and express those concerns. If there is a case to answer, the person concerned would be reported to the relevant authorities and the matter will be dealt with under our Disciplinary Policy.
Employees who are victims of modern slavery may contact an Employee Assistance Programme provided by an independent health & well-being provider. This provides employees with 24 hours/365 days access to a confidential advice line. They also provide counselling services and legal and financial advice. Guinness would be responsive and supportive to any employee affected by modern slavery.
Our policies, training, internal controls, and regular reporting provide visibility, and assurance that risks are minimised. We are not aware of any incidents during the year. However, we will continue to be vigilant and where a compliance breach is identified, we will act promptly, involve the appropriate lead agencies and feedback lessons learnt in order to minimise the risk of an incident occurring again.
Our supply chain
We engage with a wide variety of organisations for a broad range of goods and services which are primarily corporate, construction and property maintenance-related, but also to meet some more specialist requirements. Our procurement activities take place in England and our contractors and suppliers are predominantly UK based, though their materials suppliers are often not.
Most of Guinness’ procurement activities are undertaken through a framework agreement, or through an open procedure process.
Our customers
We have a role to play to keep our customers, and the people who live with them safe, so they may live free from abuse and neglect. We operate on the basis that safeguarding is everyone’s responsibility and have robust procedures in place so that appropriate action is taken when concerns are raised. Safeguarding training is mandatory for all customer facing staff, as they are more likely to witness or receive safeguarding concerns.
Some of the people we house are vulnerable to modern slavery, particularly those that are lonely or isolated or those with a substance use addiction. The form the modern slavery may take includes financial control & abuse, cuckooing and forced criminality. In recent years, we have become aware of a low incidence of cuckooing. Where we became aware, if requested to do so, we help the police to gather intelligence so that enforcement action may be taken against the criminals. We additionally support the police and multi-agency partnerships to assist the victim, by enabling or providing rehousing, or where it was appropriate to do so, by improving the security of the property.
Recorded instances of cuckooing affecting our customers remained small during 2021/22.
Our policy framework
Our policies are reviewed at least every three years and are supported by training and effective communication.
Among the policies that are relevant to slavery and human trafficking are:
- Allocations
- Anti-bribery and anti-corruption
- Anti-fraud
- Anti-money laundering
- Anti-social behaviour, hate crime and hate incidents
- Conflicts of interest
- Customer domestic abuse
- Disciplinary
- Diversity and inclusion
- Health & safety
- Private use of contractors & consultants
- Recruitment and selection
- Safeguarding adults, children and young people
- Staff payments & benefits
- Tenancy fraud
- Whistleblowing.
Among the codes of conduct that are relevant to slavery and human trafficking are:
- Code of conduct for board members and staff
- Code of conduct for suppliers and contractors
- Code of governance.
In 2020/21, the Disciplinary, Recruitment & selection, and Staff payments & benefits policies were updated with additional controls relevant to reducing the risk of modern slavery. We will continue to review and update relevant policies and procedures as necessary, so that we take effective and proportionate steps to ensure there is no modern slavery in our business or our supply chains.
Risk management, due diligence and monitoring effectiveness
We take a group-wide approach to risk management through our Corporate Risk Plan and supporting Risk Management Strategy and Framework. Our approach enables us to consider the full spectrum of risk and manage the combined impact of those risks. Potential risks are mitigated by our policies and procedures, controls built into our business operations, internal audits and the knowledge, skills and behaviours of our staff. Examples of these controls include financial regulations, codes of conduct, staff training and performance monitoring. This provides assurance that the risks are minimised.
Our potential modern slavery risk areas are building construction works, repairs & maintenance works, agency managed and contract staff, and in the supply of raw materials to our contractors.
Within repairs, maintenance and building construction, risk may arise where there are complex sub-contractor arrangements. However, most of our suppliers are large companies with whom we have built strong relationships. Assurance is provided as we require these contractors to produce their modern slavery statement as part of the tendering process.
The due diligence conducted on suppliers joining a framework agreement, includes modern slavery compliance checks. The framework suppliers are monitored annually for statutory obligation compliance. Breach of contract failures result in removal from the framework.
Where the open procedure process is used, Guinness uses a government approved selection questionnaire which references modern slavery requirements. The exclusion grounds detailed in the Public Contracts Regulations 2015 are used, which includes serious infringement of contract terms. Contractors involved in modern slavery are excluded from bidding.
In 2021/21, Guinness introduced new framework agreements for procuring Employers’ Agents, Cost consultants, Architects and Consultants. The new frameworks include mitigations against the risk of modern slavery.
The risk in suppliers sourcing materials arises as materials may be from countries where slavery is more prevalent. To mitigate these risks, we include modern slavery clauses in contracts. We conduct supplier on-boarding checks, request method statements to understand whether the model raises any modern slavery concerns, and question bidders further when abnormally low costs are submitted. We have a specialist asset management contract management team and regular contract management monitoring meetings are held.
Additional protection is afforded by our financial regulations, Employers’ requirements and Schedule of services and appointment documents for consultants.
Our robust tendering process and due diligence ensures we engage with reputable contractors and suppliers who adhere to all appropriate legislation, regulation and practices. Our contract management arrangements help us ensure contractors maintain the standards required, including the prevention of modern slavery. Contract breaches may be addressed by removal from the Guinness framework / approved list or the Government selection questionnaire contractor list as applicable.
Where agency staff is supplied, we use reputable, well known agencies with whom we have enjoyed a strong relationship. Self-certification processes are used to check legal compliance, and evidence is required to corroborate that specific vetting checks have taken place in respect of the agency staff. Guinness only uses reputable employment agencies sourced from our approved list. Most of our supported housing agency staff are supplied by large registered providers taken from local authority approved lists and are required to produce a Statement in their own right. Our exposure to these risks has remained the same during the year.
We require that suppliers are compliant with the Act where a contract is renewed during the year, or a new contract entered into. These contracts contain robust conditions ensuring the provider, their staff and sub-contractors have not been subject to any investigation, inquiry, or enforcement proceedings in relation to modern slavery. We will continue to ensure that our 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.
For these reasons, we consider that the residual risk in our supply chains is generally low. We are not aware of any incidents during the year. However, we continue to be vigilant as we recognise that our supply chains cannot be considered entirely risk-free.
In 2021/22, we developed a modern slavery reporting system so that concerns about staff, suppliers, and our customers may be recorded as they occur.
Training and awareness
We will continue to raise staff awareness and deliver training to new and existing staff and we will extend this to our suppliers and contractors, where appropriate.
Specific customer facing colleagues attend externally hosted county lines and cuckooing events. We deliver safeguarding training which is mandatory for all customer facing staff and domestic abuse training for relevant customer facing staff. Additionally, we have an eLearning course on Modern Slavery and Human trafficking which is available to all staff.
During 2021/22 we:
- Developed guidance about modern slavery to raise awareness for all staff
- Introduced new framework agreements for procuring Employers’ Agents, Cost consultants, Architects and Consultants. The new frameworks include mitigations against the risk of modern slavery.
- Raised awareness about elder abuse during Safeguarding Adults Week
- Delivered mental health training to customer facing care staff.
In 2022/23, we plan to:
- Continue to raise awareness of modern slavery through incorporating it in our mandatory safeguarding training for all customer facing staff
- Develop modern slavery training for contract managers.
Compliance
We have not identified any breaches of the Act in our business or our supply chains during 2021/22.
This Statement was approved by the Board. It will be reviewed on an annual basis.
This Statement applies to The Guinness Partnership Limited (Charitable Community Benefit Society 31693R, Registered Provider of Social Housing 4729) and its subsidiaries as follows:
- Guinness Housing Association Limited -Non-Charitable Community Benefit Society 17017R. Registered Provider of Social Housing L2441.
- Guinness Care and Support Limited – Charitable Community Benefit Society 30337R. Registered Provider of Social Housing 4497
- Guinness Developments Limited – Private Limited Company, 04175094
- Guinness Homes Limited – Private Limited Company, 05710006
- Hallco 1397 Limited – Private Limited Company, 05998281
- City Response Limited (trading as Guinness Property) – Private Limited Company, 4471280
- Guinness Platform Limited – Private Limited Company, 06411652.