Modern Slavery and Human Trafficking Policy

1. Introduction and Commitment from the Board

Shropshire Rural Housing Association is fully opposed to, and committed to preventing, modern slavery and human trafficking within our organisation and with contractors.

We have put in place a Modern Slavery and Human Trafficking Policy to demonstrate our commitment to acting ethically and with the highest standards of integrity in all our business dealings and relationships.

We are committed to developing, implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking are not taking place anywhere within our business or with contractors.

We will never knowingly deal with any business involved in modern slavery or human trafficking.

2. Purpose and Scope of this Statement

This statement is made on a voluntary basis with reference to Section 54 (1) of the Modern Slavery Act 2015. It relates to the year ended 31 March 2018 and applies to all legal entities within Shropshire Rural Housing Association.

This statement sets out the steps we have already taken and intend to take, to minimise the risk of modern slavery and human trafficking in our business activities and within our relevant supply chain.

3. Organisational Structure and Business Function

Shropshire Rural Housing Association is registered with the Financial Conduct Authority as a charitable rules registered society, and is registered with the Regulator of Social Housing as a social housing provider.

Shropshire Rural Housing is a rural housing provider in Shropshire, England. We own and manage 290 properties throughout Shropshire and employ 8 staff. Our main business is the provision and management of affordable housing to people with housing need.

4. Areas of Risk – Our Business

We estimate the risk of modern slavery and human trafficking occurring within our own business as being low. Shropshire Rural Housing Association has robust policies and procedures in place for carrying out background checks on all new employees. We ensure that all staff are eligible to work in the UK and we only pay salaries directly into employees’ personal bank accounts.

5. Areas of Risk – Our Properties

We estimate the risk of using a Shropshire Rural Housing Association property for any criminal, immoral, anti-social or illegal purposes as being low. Any of these activities is a breach of the tenancy agreement. We carry out tenancy audits on our properties, including identification checks to ensure the correct people are living there. We have appropriate mechanisms to end the tenancy agreement where breaches have occurred.

6. Areas of Risk – Our Supply Chain

Shropshire Rural Housing Association maintains an existing supplier list. We may conduct due diligence checks on suppliers, both before and after joining our existing suppliers list.

All contractors and suppliers should warrant that neither they, nor any of their officers, employees nor, so far as they are aware, any sub-contractor or other persons associated with them, have been convicted of any offence involving modern slavery and/or human trafficking.

Should any contractor or supplier not be able to provide the required warranties, Shropshire Rural Housing Association will need to take a view on their commitment to having a business free from modern slavery and human trafficking.

7. Future Actions – Our Business

We will raise employees’ awareness of modern slavery issues, encourage them to report concerns and ensure that these are acted upon and reported to the Board.

We will deliver training to all employees so that everyone understands the signs of modern slavery and human trafficking, and know what to do if they suspect it is taking place within the workplace, in our homes and within our relevant supply chain.

We will continue to take appropriate tenancy enforcement action where cases of modern slavery and human trafficking are identified within our homes.

We will continue to review and update relevant internal policies, procedures and practices, taking effective and proportionate steps to ensure there is no modern slavery or human trafficking in our organisation.

We will continue to build on our approach to modern slavery and human trafficking and periodically update this statement to reflect the best practice possible in these evolving changes.

8. Performance Indicators

We will consider the steps we are taking (to ensure that modern slavery and/or human trafficking is not taking place within our organisation or supply chain) to be effective if:

We receive no report from employees, residents, the public, or legal or government agencies, to indicate that modern slavery and human trafficking practices have been identified.

9. Review

The effectiveness of this policy and associated arrangements will be reviewed periodically by the Board of Shropshire Rural Housing Association.