Modern Slavery and Human Trafficking Statement
Below is Plus Dane Housing Limited’s annual modern slavery and human trafficking statement for the financial year ending 31 March 2020. It is divided into six sections, detailing the organisation’s work and tools to combat modern slavery. The six sections cover structure and supply chains; policies in relation to slavery and human trafficking; due diligence process in relation to slavery and human trafficking and risk assessment and management; effective action taken to address modern slavery; and training on modern slavery and trafficking. The final section is the declaration and signature. Plus Dane has noted the requirements of the Modern Slavery Act 2015 (the Act) in making this statement.
Structure and Supply Chains
Plus Dane Housing Limited (Plus Dane) is a registered housing provider and developer operating across Merseyside and Cheshire in the North West of England. Plus Dane owns and manages over 13,500 homes and have an asset value in excess of £570 million. Plus Dane is wholly registered within the UK and is a single entity after the company structure was simplified in 2017.
There are three main elements to Plus Dane’s operations. Firstly, we provide core landlord services as well as additional tenant care and neighbourhood outreach programmes to support our tenants and communities. Secondly, we manage our existing stock through our asset management function by maintaining homes and running a cyclical investment programme. Thirdly, we develop new homes through our development function, predominantly for affordable rent or shared ownership. We have a development pipeline of around 150 homes a year, with the ambition to increase this to 300 per year. These three key elements of our business are delivered by around 500 staff employed by Plus Dane.
Contracts and suppliers are procured in accordance with our Procurement Policy and procedures, Standing Orders, Financial Regulations and where applicable EU procurement legislation. We have a dedicated procurement team with the required expertise to run and guide procurement exercises to ensure legal, regulatory and statutory compliance.
In relation to modern slavery, for a supplier to be successful and provide services to Plus Dane, they need to fulfil the standard criteria issued by Cabinet Office. This requires suppliers to identify if Section 54 of the Act applies to their organisation. If so, they are required to provide assurance that they are fully compliant with the annual reporting requirements set out in Section 54 of the Act. Failure of a supplier to demonstrate their compliance with the requirements of the Act will result in removal from the procurement process.
All of Plus Dane’s operations are conducted within the UK and the majority of our first-tier supply chain is UK based. The business does not operate on a seasonal basis. A small percentage of staff at any moment in time may be employed on a fixed-term basis where, for example, work is attached to delivering a specific contract, but the business’ overwhelming preference is for permanent contracts of employment.
Policies in relation to slavery and human trafficking
All policies, strategies and key documents (including the Procurement Policy, Financial Regulations and Standing Orders) are managed centrally and are subject to regular review so as to ensure they remain relevant, accurate, and up to date and reflect the needs of the people and markets Plus Dane works with.
Our key policies that give us the power to identify and deal with modern slavery or human trafficking under the Act are:
Code of Conduct
Anti-Money Laundering Policy
Conflict of Interest Policy
Our Whistleblowing Policy makes clear that a report of concern in relation to modern slavery or human trafficking can be made under the protection of the policy.
Responsibility for Modern Slavery resides within our safeguarding function and therefore is a component of our Safeguarding Policy, which also covers how Plus Dane identify, support and signpost vulnerable or exploited people, whatever the circumstances.
We engage regularly with our recognised trade union body covering workers’ rights and employment welfare and we are compliant with UK employment law. Our line managers regularly engage with workers and create time for welfare issues to be discussed and investigated. Our People Team lead where there is any formal grievance or complaints process initiated and are represented on our MSWG to ensure our business-wide approach is joined up and coherent.
Due Diligence process in relation to slavery and human trafficking and Risk assessment and management
In January 2020 a Modern Slavery Working Group (MSWG) was constituted, bringing together expertise from across all relevant departments within Plus Dane. For example, the primary responsibility for modern slavery rests within our safeguarding function, but expertise is spread across other departments from Procurement to Governance, from HR to Development, from Asset Management to Housing.
In July 2020 the working group undertook a risk assessment of any high-risk areas within our business and supply chains using the ‘Identify your risk area’ toolkit created by Co-operatives UK Limited in 2017. Higher risk areas were identified in areas that we purchase raw materials for both the development of new homes and investment in existing ones. Most of this risk exists beyond the first tier of our supply chain.
Additionally, the MSWG identified that front line services are most likely to encounter any victims of modern slavery. For example, our repairs operatives enter properties and homes daily. Consequently, all areas of the business that operate front line services are represented on our MSWG.
The MSWG undertook a full business audit in July 2020 using the Co-operatives UK Limited 2017 ‘Checklist and Audit Tool’ and created an action plan for the year ahead, prioritising resources where the biggest benefit will be gained. The creation of the MSWG is by its nature designed to continuously improve Plus Dane’s modern slavery practices. It is not a one-off project group, but a team that will meet ad infinitum. The Group reports into our Neighbourhoods Committee for review and accountability.
Effective action taken to address modern slavery
No cases of modern slavery or human trafficking have been identified or reported to Plus Dane in recent years. However, our close working relationship with local authorities has highlighted that cases on are on the increase in the areas in which we work, and therefore the timing of the strengthening and targeting of our approach is appropriate.
Liverpool City Council has recently noted an increase in modern slavery and human trafficking cases, in part they believe, due to being a dispersal area for asylum seekers. The City Council is seeking to work with partners to deliver an action plan, this includes registered providers as they recognise that inadequate housing is a key risk factor in modern slavery. They have commissioned University of Liverpool to support partners to undertake an audit of their supply chains which we will engage with.
In Cheshire East, as part of their approach, our front-line staff attended training delivered by community safety teams focusing on awareness around modern slavery. Specific training around modern slavery for our staff will be planned as part of our training programme.
Training on modern slavery and trafficking
Plus Dane is committed to the continuous learning and development of our employees. In carrying out our role of supporting vulnerable customers we may come across slavery and/or human trafficking, in particular those from minority or socially excluded groups who may be subject to forced labour and/or domestic servitude, and potentially in connection with our workforce or accommodation provided by Plus Dane could be a venue for modern slavery.
Modern Slavery is built into our mandatory safeguarding training for all colleagues in Plus Dane. We are in the process of developing a mandatory, standalone, training module for all colleagues. This will be available through our online training portal.
We have discussed the Act, its purpose and Plus Dane’s attitude to it at Board. Senior Managers have been alerted to the implications of the Act and are expected to continue to consider where the risks of modern slavery or human trafficking may occur in their areas of the business.
Our Procurement Team have been provided with guidance on the need to avoid these risks and how to identify indicators of them within the Plus Dane supply chain. We will continue to enhance the assurances sought from members of our supply chain regarding their avoidance of modern slavery and human trafficking.
This statement is made pursuant to section 54(1) of the Act for the financial year ending 31 March 2020 (1 April 2019 to 31 March 2020) and approved by the Plus Dane Board on 17 September 2020.
Signed by Ian Reed
Acting Chief Executive Officer of Plus Dane Housing Limited: