We are one of the largest housing associations working in England, owning or managing circa 50,000 homes in London, Kent, Surrey, Sussex, Hampshire, the East of England and East Midlands.
We recognise the detrimental effect modern slavery has on global society and we are committed to acting ethically and with integrity within our business and with others to combat this. We take care to ensure slavery and human trafficking is not taking place in our business or supply chains through implementing and enforcing effective systems and controls.
This statement sets out how we deliver our commitment to comply with the Modern Slavery Act 2015 (“the Act”). It reflects on the work carried out in the financial year 2020/21.
Like most organisations, Hyde has had to adapt its ways of working as a result of the Coronavirus pandemic. Our focus has been the maintenance of our core services and ensuring the health and safety of our staff and customers. To this end and in line with government guidance, we closed or adapted our offices and construction sites, suspended face to face training and elements of our controls testing programmes, including some of those relating to modern day slavery. Subject to the successful delivery of the government’s roadmap to recovery, the suspended arrangements will be reintroduced during 2021 following a review of risk assessments.
Hyde Housing Association is the charitable parent organisation of a number of subsidiaries, together known as the Hyde Group (“the Group”).
This statement is made under section 54(1) of the Modern Slavery Act and constitutes our Group’s slavery and human trafficking statement for the financial year ending 31 March 2021. The statement applies to the Group and its relevant subsidiaries.
This statement has been approved by the Board of The Hyde Group on 27 April 2021.
Our core purpose remains the same as it did when we were established in 1967, which was to help people excluded from the mainstream housing market. However, we also build and develop open market housing to help subsidise the development of even more affordable homes. We are transparent in reinvesting our profits to fulfil this social purpose.
Our approach to combatting modern slavery and human trafficking is in keeping with our social business purpose, our desire to demonstrate ethical business practices that are aligned with our ethos, and to meet our legal and regulatory duties.
Due diligence processes for slavery and human trafficking
We have a robust framework of policies, procedures and contractual arrangements in place which contributes towards the prevention of slavery or human trafficking within our organisation and our supply chains.
These include, but are not limited to, areas such as housing management, risk management, safeguarding, health and safety, recruitment, whistleblowing, procurement, terms and conditions of employment, and codes of conduct for staff, suppliers and contractors, as well as due diligence and checks when recruiting staff or engaging suppliers or contractors.
Staff and Workforce
We employ over 1000 members of staff and are committed to treating those who work for us fairly.
We are committed to paying the London Living Wage to all our directly employed staff in London and the Living Wage to those staff outside of London. We regularly review our terms of employment to ensure that they comply with all relevant legislation.
We only use specified, reputable employment agencies to source labour and always verify the practices of any new agency we use before accepting workers from that agency. This is reflected in our Recruitment & Selection Policy.
We expect all employees to adhere to the Group’s Staff Code of Conduct. We ensure that we have systems in place with an overarching policy statement as well as a whistleblowing policy to encourage the reporting of concerns and the protection of whistle blowers.
Procurement and Supply Chain
Our supply chains include the sourcing of products and services related to the development and management of housing.
Our procurement activities take place in England and our contractors and suppliers are predominantly UK-based. We follow The Public Contracts Regulations 2015, which govern good practice in procurement.
Managed by a dedicated procurement team, we adhere to our own Procurement Policy and Procedure, which ensures we engage with reputable contractors who comply with all relevant legislation, regulation and practices. The Procedure considers the Modern Slavery Act to be an important piece of legislation that governs registered providers.
Significant contracts require suppliers to sign our Modern Slavery Code of Conduct in order to be considered during a tender process; we do not trade with suppliers who do not sign our code of conduct. In addition, our standard contract terms include the requirement for all suppliers to comply with the Act. These arrangements help us ensure maintenance of our standards.
All our policies are reviewed on a regular basis to ensure that they reflect best practice and to mitigate against risks.
Performance - this year we have:
- Reviewed our policy for Procurement to strengthen approval processes for large spend and procurement waivers.
- Reviewed procedures relating to Safeguarding for staff and tenants.
- Reviewed our statement and policy for management of whistleblowing.
- Reviewed our policy and procedure for recruitment of staff.
Future actions 2021/22
Given that our working arrangements are still affected by the government’s Covid-19 guidance, our planned actions for 2021/22 are subject to review but will continue to focus on our high-risk areas in procurement and staff awareness.
We will realign our risk and assurance activities to encompass responsibility for reviewing and monitoring activities related to modern day slavery and human trafficking across the business.
We will review and refresh our training, including for Construction, Procurement and Safeguarding staff, to ensure awareness is more firmly embedded.
We will implement checks on high-value suppliers who are subject to our tender terms and conditions, including the requirement to produce a MDS annual statement if needed.