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This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2015/2016. The statement seeks
to provide assurance as to the measures taken or to be taken to ensure that no incidents of slavery and human trafficking
take place in either its supply chain or in any other part of its business.
WDH fully support and commit to the intent of the legislation which closely matches and aligns with our own commitment
and aspiration to be a business with a social conscience. As a social housing landlord we are committed to overcoming
disadvantage and promoting opportunity through whatever means are available. Our strategic organisational value proposition
is to be an organisation which is 'creative, inclusive and works with integrity'. Our strategic milestone to 2020 is to be
'an enterprise with social impacts'. In 2015 we were a European Foundation for Quality Management (EFQM) Business Excellence
Accordingly, the WDH Board takes a zero tolerance position on slavery, servitude or forced or compulsory labour and human
trafficking in both this organisation and those with whom we have a business relationship.
WDH is a registered social housing provider regulated by the Homes and Communities Agency. It was formed as a large scale
voluntary stock transfer from Wakefield and Metropolitan District Council established in March 2005. We own and manage
over 31,000 properties within the Wakefield district and our range of housing comprises general needs rented housing,
supported and sheltered living and shared ownership. We also build houses for commercial sale and offer services to
other registered social landlords and customers. This includes a 24-hour emergency alarm responder service, a debt
consultancy service and a commercial construction and maintenance services subsidiary.
In addition, we have a shared services agreement with other social landlords to provide maintenance services. Through
this agreement we provide maintenance services to a further 12,000 properties throughout the North of England. We are
also a significant regional employer undertaking the provision of the majority of our services through our own in house
This Statement applies to the following businesses which WDH either fully owns or has a financial and commercial interest
in. For the avoidance of doubt only Wakefield and District Housing Limited has a current turnover above the £38m
annual threshold for reporting purposes.
In the financial year 2015/2016, WDH spent £61m, excluding VAT, on externally provided goods and services. This comprised
spend with 990 supplying organisations. The range of goods and services procured was wide ranging and diverse but the
largest grouped spend areas are listed below.
This is reported by reference to the key business and risk areas relevant to the provisions of the Modern
Slavery Act 2015 (MSA).
WDH directly employs over 1,450 personnel within its operations and has a robust suite of Human Resources (HR) policies
that promote transparency, equal treatment and opportunity in line with both best practice and legislative
requirements. Under the particular requirements of the MSA the following policies and guidance have been
identified as of direct relevance. These include the Code of Conduct, Recruitment and Selection
Policy, Agency Workers Policy, People Strategy and Whistleblowing Code of Practice.
WDH has employment practices which ensure a standardised, fair and transparent approach to the employment
and management of its workforce. This includes pre employment checks that identify the right to work and
previous employment history and a remuneration policy based on standardised employment packages linked to
defined job roles. On those occasions when temporary agency employment is required the same requirements
are expected and mandated as from our own processes.
We continue to be vigilant and proactive in ensuring that all tenancies are managed lawfully and in accordance
with the tenancy agreement and management policies. We have a visible and proactive presence on our estates
through the work of our neighbourhood management teams and engage with the local community through both formal
and informal means. Where reports of alleged criminal and / or inappropriate behaviours are received, then we
will act swiftly and in partnership with key agencies to ensure that all intelligence is shared and joint
actions taken. Where we identify or receive neighbourhood information regarding activity that may specifically
alert to human trafficking or modern day slavery, then immediate contact will be made with the Police and
Wakefield Council's Safeguarding Team, using existing means of information exchange.
External procurement requirements are varied in nature reflecting the wide scope of activities within the
business. All tier one or end suppliers to us are located within the UK reducing the international risk
dimension. The supplier base does vary in size with not all subject to the requirements under the MSA.
Since the Act was published, all standard terms and conditions for the procurement of goods and services
have been amended to include MSA provisions. The recently updated procurement procedures now include
specific reference to MSA and the need for a risk based approach to identification and mitigation of
vulnerable areas of procurement activity.
Initial assessment of risk has identified that our geographic location and the nature of demand for the
consumption of services is likely to lead to a lower level of potential risk than in other sectors and
localities. From the initial assessment, the following areas are determined to be of higher risk and
consequently liable to require closer assessment.
This statement is made in accordance with s54 of the Modern Slavery Act 2015 and constitutes the WDH position
on slavery and human trafficking for the completed financial year 2015/2016.
Approved by the Board of Directors
Signed by: Stephen Green, Board Chair
Date: 15 September 2016