1 April 2022 – 31 March 2023

Introduction

Ingleshaw Housing is committed to preventing, identifying and reporting modern slavery and human trafficking in our business, communities and supply chains. We do this through:

• our procurement activities,
• our employment practices, and
• our role as a social housing provider, informing relevant authorities of any suspected
• modern slavery or human trafficking in our communities.

This statement sets out how we seek to prevent modern slavery. It is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and is Ingleshaw Housing’s slavery and human trafficking statement for the financial year 1 April 2022 to 31 March 2023.

We are pleased to state that no incidents of modern slavery in our operations have been reported during this period.

Structure and supply chains

Ingleshaw Housing (the Group) is a charitable registered society under the Co-operative and Community Benefit Society Act 2014 and is a provider of social housing and related services registered with the Regulator of Social Housing.

We own and manage around 13,000 homes across Knowsley and the wider Liverpool City Region. We’re committed to providing safe and warm homes while achieving positive impact and flourishing communities. Our main objective is to work alongside our customers and local, regional, and national partners to be the provider of choice for great homes and much more.

We do this through our structure, which is outlined below.

We have a diverse supply chain including:

• Property contractors (housing development, repairs and maintenance)
• Corporate goods (IT, recruitment services and training)
• Marketing and Communications
• Office supplies

The majority of our suppliers are registered in the UK but some of their operations and supply chains are global.

We’re aware that we have a responsibility to take a robust approach to identifying and preventing slavery and human trafficking. We’re also committed to ensuring there is transparency in our own business and our approach to tackling modern slavery is consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect our contractors, suppliers and business partners to share the same high standards.

Policies on modern slavery

The Group has a Policy and Strategy Framework which is approved by the Board.

The following strategy and policies comprise our approach to identifying modern slavery risks and preventing slavery and human trafficking in our operations.

We review our policies at least every three years to make sure that they reflect the Group’s aims and our regulatory and statutory obligations.

• Procurement Policy and Strategy

Our Procurement Policy sets rules and principles for procurement and contract management which enable us to manage contract risk. All employees engaged in managing or leading contracts for goods or services must also adhere to our contract management framework. Through our Procurement Strategy we aim to continually improve our approach to procurement.

• Whistle blowing Policy

We encourage all employees, customers and other business partners to report any concerns related to any direct activities or the supply chains of the Group. Our

whistle blowing policy is designed to make it easy for employees to make disclosures without fear of retaliation.

• Colleague Code of Conduct

We make clear to employees the actions and behaviour expected of them when working for or representing the Group. We strive to maintain the highest standards of employee conduct and ethical behaviour when managing our supply chain.

• Recruitment and Selection Policy and Agency Worker Policy

We carry out Right to Work checks for all new employees. We have a Preferred Supplier List for recruitment and agency workers. We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency.

• Safeguarding Policy

We seek to tackle modern slavery in our communities in our role as a social housing provider. All employees, agency workers and contractors are responsible for sharing information and raising alerts where there is a concern of modern slavery. Customers are also able to report to us any suspicions they may have regarding potential instances of modern slavery.

• Risk Management Policy

Our Risk Management Framework, including our Risk Management Policy, ensures we have a consistent approach to risk management and assurance. The policy identifies and assigns responsibilities in relation to risk management, control and assurance. We carry out an annual modern slavery risk assessment.

Due Diligence processes

The Group will only trade with suppliers who fully comply with the Modern Slavery Act or are taking the necessary steps towards compliance.

We undertake due diligence when we take on new suppliers and procure new contracts. Our procurement procedures require potential suppliers to declare whether they comply with the Modern Slavery Act. If they are not compliant, they are required to explain why. We will reject any bids which state they are not compliant and fail to provide sufficient detail of their proposed reasonable measures to achieve compliance.

Our Standard Terms and Conditions of Purchase for suppliers include a requirement to comply with the Modern Slavery Act.

We have enhanced our central contracts register and are in the process of refreshing our framework, which ensures consistency across Ingleshaw Housing and allows contracts to be managed and actioned accordingly. Contract managers are required to maintain and review contract records including evidence of supplier policies and procedures. We carry out contract monitoring reviews on a sample basis.

Assessing the Risk

The Group has completed a risk assessment for 2023-24 which has identified the Group is at low risk of slavery and human trafficking within our operations. This is based on an assessment of a range of controls and assurances to manage the risks, an assessment of the country and sector we operate in, and the transaction and business partnership arrangements we have in place.

Potential risks are mitigated by our policies and procedures, controls built into our business operations and the knowledge, skills and behaviours of our employees.

We maintain a range of risk registers which reference the risk and related controls of modern slavery. 

Training

The Group requires all employees to complete a compulsory training course on modern slavery as part of their induction, and then every three years. We also seek to maintain ongoing employee awareness through training and communication on safeguarding.

Our procurement partners have carried out training sessions with contract owners, in order to reaffirm and ensure a consistent approach to managing contracts across the Group.

Performance and Future Plans

We will continue to work and communicate with our suppliers, partners and employees to maintain our robust processes on modern slavery and, where possible, enhance them.

We will enhance our procurement information request forms to specifically identify reasonable measures that will be taken in circumstances of non-compliance with the Modern Slavery Act. We will also document expectations.

We will strengthen modern slavery content in our safeguarding training for our housing management employees and roll out this training to our customer-facing repairs and maintenance employees too. We will provide training for relevant staff on how to monitor the risk of modern slavery through contract management.

We will also raise employee awareness of modern slavery and how to identify it through our internal communications. 

Approval

This statement was approved by Ingleshaw Housing 20 July 2023.