Anti-slavery statement

ANNUAL SLAVERY AND HUMAN TRAFFICKING STATEMENT INTRODUCTION 
This statement is made pursuant to Part 6 Section 54 of the Modern Slavery Act 2015. This statement relates to activity during the financial year April 2019 to March 2020. Shepherds Bush Housing Group is committed to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains. We are committed to acting ethically and with integrity in all our business relationships and enforcing effective processesand controls to ensure slavery and human trafficking is not taking place anywhere is our supply chains. 
 
ORGANISATIONAL STRUCTURE
Shepherds Bush Housing Group (SBHG) is diverse: comprising Shepherds Bush Housing Association (SBHA) and SBH Developments Ltd (SBHD). 
 
Shepherds Bush Housing Association (SBHA), the parent organisation of the Shepherds Bush Housing Group (SBHG), is a registered Housing Association and is regulated by the Homes and Communities' Agency. 
 
We are much more than a landlord and between our businesses, we incorporate traditional housing provision, support services for the vulnerable, a repairs and maintenance service and provide furniture recycling. 
 
The Group works in west London Boroughs including Hounslow, Ealing, Richmond, Brent, Hillingdon, Kensington & Chelsea and Harrow. However, the majority of our stock is locatedin the London Borough of Hammersmith & Fulham. 
 
OUR SUPPLY CHAIN
Details of the Group's supply chain can be requested from the Contracts and Procurement Manager via customer.service@sbhg.co.uk.
 
RESPONSIBILITY
The Director for People & Culture, Caroline Moore, will take lead responsibility for the development and implementation of the Group's anti-slavery initiatives. 
 
RELEVANT POLICIES
The Group operates the following policies: 
Employee Charter - We strive to maintain the highest standards of employee conduct and ethical behaviour in delivering our services and managing our supply chain. The Employee Charter sets out the behaviours expected of our employees when representing Shepherds Bush Housing Group.
 
Procurement Policy - SBHG is committed to ensuring that its suppliers adhere to the highest standards of ethics as part of the procurement process. Suppliers are required to demonstrate that they provide safe working conditions, treat employees with dignity and respect and comply with relevant employment legislation. 
 
Recruitment - SBHG will undertake all relevant pre-employment checks prior to staff being employed. We will carry out fair and transparent recruitment processes and will ensure our recruitment agencies comply with these requirements in the provision of agency staff. 
 
Whistleblowing Policy - SBHG is committed to the highest standards of quality, probity, openness and accountability and as part of this commitment provides a confidential reporting process for employees to report serious concerns about any aspect of our work which includes abuse or neglect of vulnerable people. 
 
DUE DILIGENCE
SBHG will continue to apply the following actions to mitigate the risk of slavery or human trafficking in the delivery of its services and supply chain: 
  • All suppliers are asked to provide evidence of compliance with the principles of the Modern Slavery Act. Organisations with a turnover of more than £36 million will be required to provide a copy of their Slavery and Human Trafficking Statement.
  • The tendering of new contracts includes an obligation that suppliers comply with the Modern Slavery Act.
  • To ensure an understanding of the potential risks of modern slavery and human trafficking in delivering our services and managing our supply chain, we provide mandatory training to relevant members of staff. 
  • Where appropriate we will include reference to the Modern Slavery Act 2015 in our policies and procedures. 
 
This statement has been approved by the Board of Shepherds Bush Housing Association.
 
Further Details
Document owner: Human Resources
Frequency of review: Annually
Date document published: 1 July 2019
Date of next review: June 2020
Reviewed by: Robert Baker
Approved by: SBHA Board

 

Edition: 2019