Slavery and Human Trafficking Statement 2015/16
Slavery and Human Trafficking Statement 2015/16
Your Homes Newcastle (“the company”) is a not-for-profit Arms Length Management Organisation (ALMO) and a wholly owned subsidiary of Newcastle City Council. We were set up in 2004 to manage the Council’s properties, to improve housing in order to meet the Government’s Decent Homes standard and to provide a range of support services for Newcastle City Council and other landlords. We currently manage:-
- 25,947 council homes on behalf of Newcastle City Council;
- 1,817 homes on behalf of the Byker Community Trust; and
- 529 homes on behalf of Leazes Homes.
Our structure, business and supply chains
We have a group structure with Your Homes Newcastle as the parent company along with two subsidiaries. The two subsidiaries are Asfaleia Ltd, a charitable subsidiary, and Abri Trading Ltd, a trading subsidiary.
- Your Homes Newcastle provides our core housing management and administrative functions;
- Asfaleia Ltd delivers our community care alarm service, sheltered housing service, young peoples’ service, advice and support service and employability services; and
- Abri Trading Ltd includes the Newcastle Furniture Service (NFS) and Palatine Beds.
Further information about our activities is detailed on our web site at http://www.yhn.org.uk/
Our tier one supply chain is made up of UK/European based suppliers. Total buying value in 2015/16 for the group was £4.1m across 444 suppliers with 20 (5%) suppliers accounting for £3.4m (83%) expenditure. The main categories are summarised below:-
|White goods, small electrical and furniture items for NFS||£1.6m (39%)|
|Information technology and telephony||£0.9m (22%)|
|Raw materials to manufacture beds for Palatine||£0.6m (15%)|
|Miscellaneous other||£0.8m (19%)|
Policies in relation to slavery and human trafficking
Whilst we do not currently have a policy specifically covering Slavery and Human Trafficking we do have a comprehensive Corporate Procurement Strategy, supported by a number of policies including Anti Bribery, Fraud and Corruption, Whistle blowing and Corporate Equality, as part of our public sector equality duty which includes the elimination of unlawful discrimination.
YHN are also committed to continually assess the recruitment procedures and practices in order to comply with current employment legislation, and recruit staff according to best practice. Equality impact assessments are carried out on all HR related policies to ensure they promote equality of opportunity.
In addition as an organisation we have been assessed as excellent under the Social Housing Equality Framework and are a Stonewall top 100 employer, demonstrating our commitment to equality.
Due diligence processes in relation to slavery and human trafficking in our business and supply chains
As a group we are governed by the Public Contract Regulations 2015, which are underpinned by our Financial Regulations, incorporating a comprehensive supplier accreditation process. This includes, as appropriate, a supplier suitability or pre- qualification questionnaire containing checks relating to a suppliers economic and financial standing, as well as compliance with labour law.
In addition our standard contract terms require our suppliers to adhere to all of our policies and rules, together with compliance at all times with the Law in the performance of the contract.
Parts of our business where there is a risk of slavery and human trafficking taking place, and the steps we have taken to assess and manage that risk.
We have mapped out our third party spend and categorised the supply areas we think are most at risk of modern slavery. The areas we think that are most at risk are due to their relatively high level of spend and the fact that we do not have supply chain visibility below our tier one suppliers:-
- Supplies of white goods, small electrical and furniture items for NFS.
- Supplies of raw materials to manufacture beds for Palatine.
Effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chains
This is our first slavery and human trafficking statement. We therefore recognise that there are actions we need to undertake in order to ensure that slavery and human trafficking is not taking place in our business or supply chains.
We are confident that slavery and human trafficking is not taking place amongst our first tier suppliers due to the due diligence processes that we currently have in place, but we cannot be as certain that slavery and human trafficking is not taking place further down our supply chains.
Training about slavery and human trafficking available to staff
Whilst YHN staff do not currently undertake specific slavery training, following the introduction of the Care Act 2014 and the Modern Slavery Act 2015, ‘modern slavery’, a new category of abuse is covered within our in-house safeguarding adults training course. This training is targeted at staff / managers who are responsible for making a referral to other services or those managers who have organisational or professional responsibility to safeguard adults at risk and who partake in risk assessments and protection planning.
Actions to be delivered during 2016/17
We intend to:
- Develop a corporate anti-slavery policy to supplement our existing processes and procedures, which will form the base line for our supplier compliance.
- Update our procurement processes to include specific prohibitions against the use of forced compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children.
- Take a risk based approach to ensuring that slavery and human trafficking is not taking place in our supply chains. We spend a relatively large amount, £1.6m (39%), on the purchasing of white goods, small electrical and furniture for the NFS, where supply chains may extend beyond the UK, possibly from countries with a higher risk of slavery and human trafficking. Our priority for 2016/17 is therefore to undertake supply chain mapping for this category using guidance from the Chartered Institute of Purchasing and Supply. The supply chain mapping exercise will enable us to identify actions we need to take to ensure that slavery and human trafficking is not taking place in this supply chain. We intend to continue this supply chain mapping in 2017/18 targeting the next highest risk supply category.
- Develop training for relevant staff relating to our roles and responsibilities in relation to the eradication of slavery and human trafficking within the organisation and our supply chains.
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved and published by the YHN Board and will be reviewed annually.