|Purpose||To set out Mount Green’s approach to tackling issues of forced|
labour and human trafficking within the business and supply
|Applies to||All employees and temporary workers working at Mount Green|
Housing Association (together “team members”) and
contractors who deliver services on our behalf.
|Date first implemented||March 2020 Version 1.0|
|Author||Assistant Director of Corporate Services|
|Date first approved by Exec|
|Date first approved by the|
|Service Area||Corporate Services|
Document Status: This is a controlled document. Any printed copies of this document are not controlled. As a controlled document, this document should not be saved onto local drives but always accessed from the Policy Library.
|Revision Date||Version No.||Revised by||Approved by|
|March 2021||2.0||Alison Robson-Young, Finance and|
|April 2022||3.0||Clare Maryan, Assistant Director of|
|May 2023||4.0||Clare Maryan, Assistant Director of|
Current Statement Revision
|Date revised||May 2023|
|Revised by||Clare Maryan, Assistant Director of Corporate Services|
|Executive approval date||17 May 2023|
|HR & Remuneration Committee Approval and Board Ratification date||24 May 2023 / 2 August 2023|
|Next revision due||February 2025|
1.1. Mount Green is committed to an ethical approach to all its work, and expects its suppliers, partners, and contractors to meet those standards. As a housing association serving its local communities, Mount Green recognises that it has a responsibility to train its team members to protect vulnerable people and where possible to identify modern slavery and human trafficking and take action
1.2. This statement summarises the steps Mount Green is taking to ensure that everybody understands their responsibilities, and the actions available, for safeguarding against slavery and human trafficking throughout its business and direct supply chains.
2. The Modern Slavery Act 2015
2.1 The Modern Slavery Act 2015 requires certain organisations to be transparent about their efforts to ensure there is no modern slavery, including human trafficking, in their own businesses or supply chains.
2.2 Modern slavery is a serious crime where people are exploited, abused and treated as a commodity. It includes slavery, servitude and forced labour and human trafficking. Victims can be of any age, gender, nationality and ethnicity and may be subjected to more than one form of slavery or exploitation. Because modern slavery is a hidden crime it is often difficult to detect and victims may not come forward because of fear of violence or repercussions. They may also not recognise themselves as a victim. The Act sets out steps that should be taken to prevent modern slavery.
2.3 In accordance with the Act, Mount Green strongly opposes slavery and human trafficking and would never knowingly conduct business with partners, contractors, supply chains or employees that engage in such practice.
3. About Mount Green
3.1 Mount Green’s role is to offer a range of affordable, good quality accommodation for local people to rent or part buy/part rent. We have been meeting people’s housing needs for 60 years and, as an independent housing association based in Leatherhead, we currently have around 1,600 properties that we own and manage mainly within the communities of Surrey and North Sussex.
3.2 Due to the nature of Mount Green’s business, it works with a wide range of suppliers and partners some of whom may sub-contract work, employ temporary staff directly or rely on recruitment agencies for staff.
3.3 Whilst not currently of sufficient size to be covered by the Act, the Board of Mount Green considers that it is best practice to address the issue of modern slavery and act accordingly. The Board believe that because Mount Green is a small business, and the nature of the work undertaken, that slavery or human trafficking is less likely to occur. Nevertheless, Mount Green have a series of robust policies and provides training for team members. Additionally, Mount Green undertakes pre-contract due diligence and contract management with its contractors. This combined approach ensures that everyone involved with Mount Green understands their responsibilities under the Modern Slavery Act for safeguarding and, as far as possible, minimising the likelihood of an occurrence.
4. Relevant Policies
4.1 Mount Green has a range of documents and processes to minimise the risk of slavery and human trafficking across its operations, including:
- Whistleblowing Policy: Mount Green encourages all its team members, residents, and partners to report any concerns about its activities or supply chains. This includes the risk of slavery or human trafficking.
- Team Handbook & Performance Management Framework: Mount Green makes clear to its team members what actions and behaviours are expected of them. Mount Green strives to maintain the highest standards of employee conduct and ethical behaviour.
- Contractor Code of Conduct: Mount Green are committed to ensuring that their suppliers meet the requirements of the Modern Slavery Act 2015. Serious violations of Mount Green’s Contractor Code of Conduct will lead to the termination of the contract.
- Recruitment Policy: Mount Green only uses reputable employment agencies to source temporary employees and verifies the practices of any new agency it intends to use.
5.1 To alleviate any risks and to ensure compliance with the Modern Slavery Act, Mount
Green carries out the following activities:
- Before entering into a tenancy agreement, identification checks are complete to ensure Mount Green is confident it knows who it is housing.
- Residents are made aware of the Modern Slavery Act 2015 through the publication of this statement on Mount Green’s website.
- Mount Green has a safeguarding policy and procedure in place, as well as links with external agencies, which assist team members in identifying, monitoring, and supporting vulnerable residents.
5.1.2 Team Members
- Mount Green maintains a robust and transparent recruitment policy.
- All new employees are requested to confirm they have the appropriate permissions to work and identification checks are completed to ensure Mount Green is confident it knows who it is employing.
- All team members are provided with training on safeguarding and the Modern Slavery Act 2015 in order to raise their awareness and understanding of what to do if they suspect a case of slavery or human trafficking.
- Team members are encouraged to look for the signs, which may not always be obvious, that someone may be a victim of modern slavery, and to signpost them to the appropriate support.
- Mount Green is a National Living Wage employer.
- Mount Green undertakes due diligence when taking on any new suppliers/contractors. Mount Green expects its suppliers/contractors to carry out their own due diligence of their suppliers and contractors.
- Mount Green will review its existing supplier and contractor list to ensure all are compliant with the Modern Slavery Act.
- Evidence of compliance with the Act will be collated for all existing and potential suppliers/contractors. If suppliers do not have a Modern Slavery Statement they will be expected to sign up to Mount Green’s before they can become an approved supplier.
- When undertaking a procurement exercise of any size, Mount Green will ensure that to be successful, new suppliers will pay the living wage and agree to the principles of the Modern Slavery Act 2015 regardless of their size.
6.1 Team members receive an overview of Mount Green’s approach to safeguarding, including combating slavery and human trafficking during induction then regular training updates on the Modern Slavery Act; the signs and what appropriate actions they should take.
7. Reporting of Non-Compliance
7.1 Mount Green has a Whistleblowing Policy in place, which outlines the process that individuals can follow to raise concerns that the Modern Slavery Act 2015 is not being adhered to across the organisation or any of its partners or supply chains. Mount Green treats all information provided confidentially.
8. Board Approval
This statement has been approved by our Board.
Chair of the Board