This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2020/2021. 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.
We fully support and commit to the intent of the legislation that 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 creating a model for sustainable living in mixed tenure communities 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'.
We take 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 Charitable Community Benefit Society registered under the co-operative and Community Benefit Societies Act 2014 regulated by the Regulator of Social Housing (RSH). It was formed as a large-scale voluntary stock transfer from Wakefield 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 and a commercial construction and maintenance services subsidiary. We are also a significant regional employer undertaking the provision of the majority of our services through our own in-house teams.
This Statement applies to the following businesses that 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 £36m annual threshold for reporting purposes.
In the financial year 2020/2021, we spent circa £35m, excluding VAT, on externally sourced goods and services. This comprised spend with 670 separate 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).
We directly employ over 1,350 personnel within our operations and have 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 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, and Whistleblowing Code of Practice.
All our employees and representatives have an individual and collective responsibility to bring to the attention of management any knowledge or concerns they have or are aware of where providers of services to us fall short of the standards expected.
We have employment practices, which ensure a standardised, fair and transparent approach to the employment and management of our 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.
Through the procurement process, organisations must demonstrate they also have policies that promote transparency, equal treatment and opportunity in line with both best practice and legislative requirements. This requirement is audited against our ISO 45001 accreditation.
We carry out periodic tenancy visits to check on property condition, compliance with the WDH Tenancy Agreement and enquire over tenant well-being. This is also an opportunity to identify any inappropriate use of our property including signs of modern slavery issues.
Our procurement requirements are varied in nature across the organisation, reflecting the wide scope and diversity 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. The following have been identified as the high-risk areas that will require most surveillance and due diligence.
All standard terms and conditions for the procurement of goods and services have been amended to include MSA provisions, as has the relevant procurement procedures guidance document for employees. We have adopted the Cabinet Office Supplier Questionnaire for MSA screening of suppliers involved in higher value projects, whilst amending our own supplier due diligence questionnaire.
We actively engage with our existing supply chain through effective contract management and regular performance reviews. This further supports our commitment to managing relationships with our suppliers but also ensuring the responsibilities under the MSA are continually monitored throughout the life of a contract. This is especially so for all high-risk procurements and services relating to the MSA and businesses with an annual turnover exceeding £36m.
We also utilise several national consortia and framework agreements, which are carefully checked for compliance with and adherence to the provisions of the MSA. Working closely with such existing procurement vehicles enables us to further embed our commitment to the highest standards of ethics within our supply chain and ensuring that suppliers we work with can demonstrate that they provide safe working conditions, treat workers with dignity and respect and act ethically within the law.
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 2020/2021.
Approved by the Board of Directors
Signed by: Board Chair
Date: 23 September 2021