Anti-Slavery and Human Trafficking Statement 2021-22
Modern slavery is a crime and violation of fundamental human rights. It includes recruitment, movement, harbouring or receiving of humans using force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.
Human trafficking is the trade of humans for the purpose of forced labour, sexual slavery, or commercial sexual exploitation.
Southern Housing Group is committed to acting ethically and with integrity in all our relationships. This means taking a zero-tolerance approach to modern slavery and human trafficking by implementing and enforcing effective systems and controls to ensure no such activity is taking place in any part of our business or anywhere in our supply chains in accordance with the Modern Slavery Act 2015.
This statement applies to all the Group’s companies as detailed in our annual report for the financial year ending 31 March 2022 and has been approved by the Group Board on 25 July 2022.
Where we might encounter slavery and human trafficking
The Group provides services and support to customers in over 30,000 homes. All individuals, regardless of age, ability, race, gender reassignment, sex, sexual orientation, faith or beliefs, should have the greatest possible control over their lives, and we have robust safeguarding processes to support this.
Our homes are available across all tenures and types.
We have approximately 1,100 staff.
We recognise our activities linked to housebuilding, property maintenance, care and support, IT and temporary staff are the areas of our business at greatest risk of modern slavery or human trafficking.
Actions we took in 2021/22
• maintained clear risk management arrangements for the purposes of ensuring the effective identification, monitoring and management of risk across the Group including those associated with modern slavery and human trafficking
• regularly reviewed the Group's policies and procedures which are designed to ensure that we maintain our high standards of probity, accountability and openness, preventing the risk of unknowingly harbouring illegal, unethical or improper conduct and continued to ensure our resident safeguarding and domestic abuse policies, procedures and training encompassed modern slavery.
• made relevant pre-employment checks such as ’right to work in the United Kingdom’ checks and worked only with reputable agencies
• paid all employees either the London Living Wage or UK Living Wage Foundation rates as a minimum for their basic salary and made payments directly to colleagues
• provided an independent Employee Assistance Programme
• only engaged with suppliers who complied with the Modern Slavery Act 2015 and conducted robust due diligence to assure ourselves
• published our annual anti-slavery and human trafficking statement on our website
• reported attempted or actual breaches to the Audit and Risk Committee and Board (zero instances were recorded)
• maintaining our links with other housing associations to share information about best practices in tackling modern slavery
• encouraged reporting of concerns related to our own activities or our supply chain through our speak up (whistleblowing) policy
Actions we’ll take in 2022/23
We will continue to undertake all the activities we carried out during 2021/22 and in addition will be aiming to:
• include a link to the slavery and human trafficking statement in a prominent place on our homepage and publish our statement on the government’s registry
• explore performance indicators to measure our effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chains
• improve visibility of our suppliers’ full supply chains to improve transparency regarding how suppliers monitor their third-party operations
• develop training for employees to further improve understanding of the implications of the Modern Slavery Act and what they should do to recognise and report potential incidences
• ensure all our relevant resident policies encompass modern slavery