Slavery and human trafficking statement

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 largest providers of affordable housing and care in England. We own and manage around 65,000 homes and provide services to over 140,000 customers across the country.

Our core activities are delivered by more than 3,000 staff and comprise: developing and managing homes 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 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 or 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 will develop, implement and enforce processes and controls that seek to ensure modern slavery is not taking place within our business nor in 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, we will act collaboratively with them to resolve and prevent further occurrences.

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 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.

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.

Our contract management framework sets out our expectations for anyone managing a contract. This enables us to provide assurance for a range of compliance areas, including our commitment to the prevention of modern slavery. We monitor the effectiveness of the framework to ensure it provides the necessary
assurance.

Our particular risk areas are building construction works, repairs and maintenance contractors; agency managed staff and facilities contract staff. It is possible that contractors and sub-contractors may source their labour from smaller companies who might be more at risk of exposure to modern slavery practices. Similarly, materials sourced by contractors and sub-contractors may be from countries where slavery is more prevalent. However we mitigate this risk by incorporating the Act’s requirements in our procurement and contract management.

For these reasons, we consider that the residual risk in our supply chains is generally low. However during 2020/21 we recorded a very small number of individual incidents of apparent exploitation of contractor staff. Guinness employees were not involved in any incident and all were dealt with as appropriate by the police. We continue to be vigilant as we recognise that our supply chains cannot be considered entirely risk-free.

Our customers

Some of the people we house are vulnerable to modern slavery, in particular cuckooing (that is the takeover of a person’s home by criminals, usually drug dealers, for sexual exploitation and county lines drug trafficking). Customers may also be vulnerable to prostitution and their homes being used as brothels. 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. In addition, safeguarding training is mandatory for all customer facing staff as they are more likely to witness or receive safeguarding concerns.

During the year, in order to prevent and detect tenancy fraud, we made targeted tenancy checks to help us monitor that our homes continue to be occupied by the people we let them to. Following the implementation of our Customer Domestic Abuse policy in 2019, we received Domestic Abuse Housing Alliance
accreditation during 2020.

Recorded instances of cuckooing affecting our customers remained small during 2020/21. Where we became aware of cuckooing, we provided rehousing support and made safeguarding and National Referral Mechanism referrals as appropriate. We also liaised with the relevant authorities such as the police, social
services, and voluntary agencies.

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.Training and awareness

Risk management, due diligence and monitoring effectiveness

Risks are identified and managed through the Guinness risk strategy and risk management framework. Potential risks are mitigated by our policies and procedures, controls built into our business operations, and the knowledge, skills and behaviours of our staff. Examples of these controls include financial regulations, codes of conduct, staff training and performance monitoring.

Guinness only uses reputable employment agencies sourced from our approved list. Where properties are managed by managing agents, the agents are required to submit a questionnaire evidencing right to work checks on proposed employees.

Supply chain risks are managed by the due diligence we do on companies we work with during the supplier on-boarding process. This includes the use of supplier on-boarding checks, method statements and a specialist contract management team for asset management.

We require that suppliers are compliant with the Act where a contract has been renewed during the year, or a new contract has been entered into. These contracts contained 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.

Our robust tendering process and due diligence ensures we engage with reputable contractors and suppliers who adhere to all appropriate legislation, regulation and practices.

In building construction, we conduct business with companies of all sizes. Many are large enough to be covered by the Act themselves, and in all cases we include modern slavery clauses in contracts. Contract breaches can be addressed by removal from the Guinness framework or the Government selection questionnaire contractor list as applicable. Additionally, our Employer’s Requirements refer to modern slavery requirements.

For repairs and maintenance supply chains, we use supplier on-boarding checks, method statements and an asset management contract management team.

In 2020/21, the policies which we reviewed included: Anti-money laundering, Anti-social behaviour, hate crime & hate incidents, Conflicts of interest, Diversity & inclusion, Whistleblowing, and our Code of governance.

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 chain.

In 2021/22 reviews are planned to include: Anti-bribery and Anti-corruption, Anti-fraud, Customer domestic abuse, Disciplinary, Health & safety, Private use of contractors & consultants, Recruitment & selection, and Staff payments and benefits.

Training and awareness

Contract management training has been developed for staff responsible for managing contractors, suppliers or consultants. 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.

In 2021/22, we plan to:

• raise awareness of modern slavery through mandatory safeguarding training
• continue delivering contract management training; and
• raise awareness of elder abuse through communications.

We will roll out contract management training throughout the business, as well as guidance for all those
responsible for managing contractors, suppliers or consultants.

We are introducing a new mental health training course for customer facing care staff. This course will help raise awareness of relevant changes in customer behaviour which may indicate that they are potentially subject to slavery.

We will also deliver more domestic abuse training for relevant customer facing staff. This training will raise awareness of the potential signs of domestic abuse and action staff should take in response.

Compliance

We have not identified any breaches of the Act in our business during 2020/21. A very small number of apparent incidents within our supply chain were dealt with by the police.

This Statement was approved by the Board. It will be reviewed on an annual basis.

neil sig