Modern Slavery Act - Slavery and Human Trafficking Statement


This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2016/2017. 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 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 Award winner and in 2017 were rated as a platinum business as part of the launch of the EFQM global index programme.

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.

Our structure and business

WDH is a registered social housing provider 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, 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 14,000 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 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.

  • Wakefield and District Housing Limited, A charitable Community Benefit Society; registered number: 7530
  • WDH Solutions Limited, Company number: 05802087 – Subsidiary
  • Northern Shared Services Limited, Company number: 08466580 – Subsidiary
  • Bridge Homes (Yorkshire) LLP. Company number: OC394414 – Joint Venture

In the financial year 2016/2017, we spent £58 million, excluding VAT, on externally provided goods and services. This comprised spend with 945 separate supplying organisations. The range of goods and services procured was wide ranging and diverse but the largest grouped spend areas are listed below.

  • New build construction.
  • Property phased capital renewals.
  • Vehicles.
  • Utilities.
  • Maintenance materials.
  • Consultancy and professional services.
  • Accommodation cleaning.
  • Insurance.
  • Grounds and environmental maintenance.
  • Communications and IT services.

Our policies and due diligence in relation to slavery and human trafficking

This is reported by reference to the key business and risk areas relevant to the provisions of the Modern Slavery Act 2015 (MSA).

  • Human Resources.
  • Property and tenancy management.
  • Supply chain.

Human Resources

We directly employ over 1,400 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 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.

We have 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.

Specific Action

  • We review all our policies and issued guidance on a regular cyclical basis. Over the next year or so, we will review our HR policies specifically with regard to MSA and any amendments that are considered desirable in the light of agreed best practice. An initial assessment had indicated that no significant changes were immediately required. Any changes will be implemented as part of the regular reviews.
  • Over the last year, a series of awareness and training events have been held with various staff groupings and MSA has formed a focus on the agenda of a number of standing groups. This has included the WDH Safeguarding Working Group and the WDH Procurement Forum of key organisational purchasers. An awareness session was held with the key Business Leaders within the organisation comprising 127 senior and middle managers. We also participated in an initial awareness course run by the multi agency Wakefield Human Trafficking and Modern Day Slavery Network (HTMDS) of which we are a member.
  • Future training developments will consider the possibility and practicality of an eLearning approach to further cascading of knowledge and understanding.

Property and tenancy management

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.

Specific Action:

  • Between 1 April 2016 and 31 March 2017, we have completed 4,957 periodic tenancy visits (16% of our housing stock) where tenants have been visited to check on property condition and compliance with their tenancy agreement. This is an opportunity to identify any inappropriate use of our properties including signs of potential modern slavery issues. None were identified.
  • We continued as a standing and active member of Wakefield HTMDS. Meetings are currently held quarterly to share intelligence and discuss current issues. This has included discussion of the development of a multi agency training / awareness programme and learning more from the Police over the presence of serious organised crime within the Wakefield district which may impact on human trafficking and modern day slavery issues.
  • We are currently restructuring the way that estate management services are delivered with the emphasis on environmental quality, and local visibility / accountability. The role of the frontline estate officer is currently being redeveloped to increase staff resource towards proactive tenancy and estate management. The new structure aims to be completed by October 2017 and will contribute to MSA vigilance.
  • We attend weekly tasking meetings with Police and other agencies within local management areas to share insight and information regarding priority issues and perpetrators of crime and antisocial behaviour. In addition, our Community Safety Manager and both Area Managers (east / west) meet with local Police Inspectors on a quarterly basis regarding wider neighbourhood priorities and further joint working initiatives.

Supply chain

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. The following have been identified as the high risk areas that will require most surveillance and due diligence.

Procurement of high risk products

  • Clothing – Uniforms / PPE.
  • Food and constituent commodities.
  • Products made from mineral type commodities.

Low paid / low skilled service type work

  • Security guarding, cleaning, care services.
  • Labouring and unskilled construction work.

Specific Action:

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. During 2016/2017, an exercise has been undertaken to make all current suppliers aware of the provisions of MSA and what we may require going forward. This targeted many suppliers where economic activity may be defined as being within the potential scope of MSA provision; irrespective of whether they had a turnover above the £36 million statement threshold and had a compliance duty.

Our philosophy is that the Act’s ethos and requirements are valid irrespective of the size of turnover. Of the 930 suppliers registered on our purchase ledger system and in regular use during the year, responses were received from approximately one third. From that, concentrated effort has been placed on the top 100 suppliers who accounted for 83.7% (£37.1m) of the regular expenditure and are key suppliers of relevance to MSA. Only one supplier out of the top 100 has not replied and whom we believe will be subject to the provisions of the Act.

Future developments will now concentrate on developing an approach that can be utilised when high risk procurements as it relates to MSA is undertaken.

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 2016/2017.

Approved by the Board of Directors

Signed by: Stephen Green, Board Chair

Date: 14 September 2017