Modern Slavery Statement 2016
This statement highlights the Vale of Aylesbury Housing Trust's approach to understand all potential modern slavery risks related to its business in compliance with section 54 of the Modern Slavery Act 2015. This approach is aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to the financial year 1 April 2015 to 31 March 2016.
The Vale of Aylesbury Housing Trust operates solely in England and all of the organisation's first-tier suppliers are UK based. However, as the organisation commissions construction and refurbishment projects for its properties, the Vale of Aylesbury Housing Trust effectively operates in a 'high risk' sector. The organisation is aware that the construction industry is more susceptible to modern slavery and human trafficking than many other sectors, even for those companies operating solely within the UK.
The Trust recognises that it has a responsibility to take a robust approach to slavery and human trafficking. The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its infrastructure is free from slavery and human trafficking.
The organisation has conducted a survey of its significant construction related suppliers to ensure there is no known modern slavery or human trafficking in the supply chain. There was a 100% response rate from the 26 suppliers asked to complete the questionnaire. Of those 26 suppliers 4 are required to prepare their own transparency in supply chains statement.
No supplier had any reason to suspect there is slavery or trafficking in its supply chain. Many suppliers have specific anti-slavery and anti-trafficking policies in place. 20 of the organisation's suppliers are members of a construction industry federation. All suppliers confirmed they pay all their UK staff at least the national minimum wage and all suppliers with overseas branches confirmed they comply with the minimum wage legislation in the countries in which they operate. 20 of the suppliers ensure they check the identity of employees of sub-contractors from high risk countries including Slovakia, Romania, Poland, Lithuania and Hungary.
Most of the organisation's suppliers are well known to the Vale of Aylesbury Housing Trust and the organisation has no reason to suspect that its suppliers might have slavery or human trafficking in their own organisations or their supply chains. The responses to the questionnaire, combined with the organisation's relationships with and knowledge of its suppliers, has satisfied the Vale of Aylesbury Housing Trust that there is no slavery or human trafficking in its supply chain. It is further satisfied that there are robust procedures in place to ensure that any occurrence of slavery or human trafficking will be identified by the organisation itself or by its suppliers.
The organisation operates the following policies that support preventing slavery and human trafficking in its operations and supply chain:
- Whistleblowing Policy - the organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. The organisation's whistle blowing policy is contained in an internal document (confidential reporting policy) and made available to all staff on the Intranet.
- Employee Code of Conduct - the organisation's code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour.
- Recruitment / Agency Workers Policy - the organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
The organisation has raised awareness of modern slavery issues by informing all of our employees by using our intranet service. This information explains to employees:
- The basic principles of the Modern Slavery Act 2015;
- How employers can identify and prevent slavery and human trafficking;
- What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
- What external help is available, for example through the Modern Slavery Helpline
This statement will be reviewed and published annually.
Chair of Vale of Aylesbury Housing Trust.