Slavery and Human Trafficking Statement

Introduction

This statement is made by Wakefield and District Housing Limited (WDH) for the financial year 2023 / 2024. 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.

 

Our structure and business

• 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 1,350 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.

 

Specific Action:

• We review all our policies and issue guidance on a regular cyclical basis. Any changes to the MSA will be implemented as part of the regular reviews.

Property and tenancy management

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.

 

Specific Action:

•  We are members of the multi-agency Wakefield Modern Slavery and Organised Crime Group (Silver). This group is led by West Yorkshire Police and meets to review and update partner agencies on organised crime within the district and the profile of actual crime groups that have been officially registered as such by the Police. Although the criminal activity of such groups is wide ranging, the forum also focuses on the possible impact on human trafficking / modern day slavery and whether this is a feature of such criminal activity.
•  We provide a proactive tenancy and estate management service with employee resource dedicated to being visible and accountable within the neighbourhoods we serve. The role of the Estate Officer (Neighbourhood / Case Worker) in particular is estate based and is at the forefront of community engagement, working with residents to help address local issues or concerns.
•  Five seconded Police Constables (Tenancy Support Officers) working within our Community Safety team also support local estate management services. Any community intelligence or concerns over potential human trafficking / modern day slavery is immediately fed back to West Yorkshire Police through the Tenancy Support Officers or via our access to the Police Intelligence Portal (PIP) to enhance wider intelligence gathering and help develop more targeted police action that may need to be taken.
•  We hold regular partnership tasking meetings. These Neighbourhood Co-ordination Groups are made up of partners from the Police and other agencies within local management areas, sharing insight and information regarding priority issues and perpetrators of crime and antisocial behaviour across our seven neighbourhood areas. In addition, our Community Safety Manager and Area Managers meet with local Police Inspectors on a quarterly basis regarding wider strategic neighbourhood priorities and further joint working initiatives, including the challenges facing both us and our partners and how these can be overcome.
•   We are committed to safeguard the wellbeing of our customers and have a duty to report instances where people are at risk of harm.
•  We work in partnership with social care teams and the Police, and have Safeguarding policies and procedures in place for referring people who are at risk.

Supply chain

Our procurement requirements are varied in nature across the organisation, reflecting the wide scope and diversity of activities within the business. The majority of tier one or end suppliers are located within the UK reducing the international risk dimension. The supply base varies in company size with not all subject to the requirements under the MSA. The following have been identified as the high-risk areas that require greater surveillance and due diligence.

Procurement of high-risk products

• Clothing – Uniforms / Personal Protective Equipment (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 include MSA provisions, as do the relevant procurement procedures guidance document for employees.

We have adopted the Cabinet Office Standard Supplier Questionnaire for MSA screening of suppliers involved in higher value projects, and our own supplier due diligence questionnaire includes MSA screening at all contract values.

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 2023 / 2024.