Modern slavery statement

Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men using force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.

  1. We’re committed to being compliant with the Modern Slavery Act 2015, which gives law enforcement the tools to fight modern slavery, ensure perpetrators can receive suitably severe punishments for these appalling crimes and enhance support and protection for victims.
  2. Our Modern Slavery Statement applies to all companies within the mhs homes group. We are committed to renewing our modern slavery statement annually and reviewing any measurables that are outlined in the statement.

Procurement

We have a dedicated procurement team who adhere to all relevant procurement policy and legislation. As a result, we are able to fully consider quality, price and purpose prior to making buying decisions. We have contract managers in place for every supplier we use, which enables us to achieve and maintain the highest standards possible at all times. We only use specified, reputable employment agencies to source labour. This statement extends to all our suppliers as well as their subcontractors.

Currently, we follow the EU Procurement Directives as good practice as well as to ensure that any safeguarding incidents raised by our suppliers are acted on as necessary. We arrange for our supply chain to be regularly audited, and work with our suppliers to identify areas where slavery or human trafficking may be a risk.

All our contractors and suppliers are UK based, and we are committed to using small/local firms wherever possible, which allows us to develop close working relationships. This also links in to our commitment to social value and responsibility, living wage, sustainable procurement, a priority on supporting the local economy, and in working collaboratively with our suppliers (and their suppliers) to phase out, and, ultimately, put a stop to all forms of slavery and human trafficking.

We carry out an annual contractor health check to clarify and confirm that suppliers are compliant and meet the following requirements:

All employees:

  1. Are legally able to work
  2. Have freely chosen employment (no forced or bonded labour)
  3. Have a written contract
  4. Have not had to pay fees or lodge documents to obtain work
  5. Understand their statutory rights (i.e. sick pay and holiday pay)
  6. Are paid in accordance with national law 
  7. Are working in a safe and hygienic environment
  8. Are not expected to work excessively long hours and that working hours comply with national laws and guidelines
  9. Asses quotations and fees from any agency or supplier providing unusually low rates when compared with industry standards

The percentage of compliant suppliers is reported to mhs homes group Board annually.

Our customers and homes

We understand that our customer base is representative of a diverse set of backgrounds and needs, and that isolated customers or individuals with vulnerabilities may be especially at risk. We will, therefore, carry out all processes to help us identify any at risk or vulnerable residents or groups in our properties.

We carry out 1,000 tenancy audits, (including ID checks) on an annual basis, and ensure that there all appropriate processes are in place to make sure that homes are allocated appropriately. We will also ensure that all our front-line staff who visit customers homes have completed the appropriate safeguarding training and understand fully how to raise/report any safeguarding concerns they may have. We will ensure that we utilize our partnerships with external organisations to share intelligence, which will better our ability to identify where modern slavery could potentially be taking place.

We recognise that the use of our homes to facilitate modern slavery is a risk, and so, any suspected cases of tenancy fraud will be reported to our Finance, Risk and Audit committee quarterly. Likewise, any tenancy found to have been granted on a fraudulent application will be terminated through the appropriate mechanisms.

As part of the annual report to mhs homes group Board we will confirm how many tenancy audits have been completed against the target and by exception how many safeguarding issues were raised.

Our colleagues

We pride ourselves on being an employer of choice. We’ve been recognised as an Investor in People, with gold accreditation for the sixth year running. Our Leadership Behaviour Framework is just one way that we seek to encourage and empower staff across all levels to solve problems. We believe that everyone has a crucial part to play in tackling Modern Slavery and Human Trafficking, and we will continue to do all we can to raise awareness so that staff are able to understand, identify and report on any potential risks.

We ensure that all relevant processes to ensure compliance with UK employment law are drawn upon at all times. This includes a commitment towards meeting salaries in accordance with the Living Wage Foundation, and the National Living Wage for apprentices.

All our staff-based policies and procedures comply with UK employment law and work to mitigate the risks posed by modern slavery and human trafficking as follows:

  • All new employees go through robust vetting procedures and ID confirmation
  • Any temporary staff are sourced through reputable agencies and under the supervision of the HR team
  • All staff must complete mandatory training in the form of e-learning, and we monitor and report on the total percentage of staff who do so
  • The correct posts are in place for us to ensure the effective management of the risks associated with Modern Slavery – namely, Procurement Manager, HR Manager and Finance Director

As part of the annual report presented at mhs homes group Board we will report on the % of staff who have completed the mandatory training.

Sharing this statement

We produce an annual report on all measurables to show compliance with this statement. This report is provided to all Boards along with any tenancy fraud cases via the Fraud and Whistleblowing Report to FRAC. The statement is affirmed at all Boards annually. We also share this statement with our staff and regularly promote our whistleblowing procedure to ensure that staff are aware of how to raise any concerns.

Although we perceive the risks within our business to be small, we seek to constantly measure our performance in the fight against Modern Slavery and Human Trafficking, so we can see where we’re on track and where we need to improve. For instance, we regularly review our existing policies to make sure that they demonstrate best practice and to mitigate against potential risks.

Future Steps

We will ensure that there are ongoing training opportunities so that all staff recognise the importance of The Modern Slavery Act 2015, and where this sits in comparison to other relevant policies within the field, such as whistleblowing and recruitment, so that we remain fully compliant at all times.

References

Government publications: Modern slavery and public health

Modern Slavery Act 2015