The Hyde Group Modern Day Slavery Statement for 2023/24
We are one of the largest housing associations working in England, owning or managing circa 50,000homes 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 2023/24.
Following the Coronavirus pandemic, like most organisations Hyde has adopted a hybrid model system of working whereby, dependant on role, employees work from a Hyde office two days a week while the focus remains on the delivery of services and ensuring the health and safety of our staff and customers.
Following the removal of Covid restrictions, previously suspended arrangements such as face-to-face training and elements of our controls testing programmes, including those relating to modern day slavery (MDS) have now been reinstated.
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 2024. This statement will be reviewed and updated annually and applies to the Group and its relevant subsidiaries.
This Statement has been approved by the Hyde Group Audit Committee on 11 May 2023.
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
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, regulations 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 strictly reviewed to a formal timetable to ensure that they reflect best practice and to mitigate against risks.
Performance - this year we have
- Reviewed Hyde’s well established risk management framework and policies/procedures for Anti-Money Laundering, Procurement and Health & Safety.
- Completed assurance activities with all high-value suppliers and all were able to produce their MDS annual statement when requested. This ensures Hyde only trades with suppliers that comply with the MDS Act in adherence with Hyde’s contract terms.
- Identified and promoted tailored modern slavery training to key staff and implemented mandatory training for key managers.
Future Actions 2022/23
The planned actions for 2022/23 will continue to focus on our high-risk areas in operations
and procurement, along with a focus in enhancing staff awareness.
- We will continue to monitor our high value suppliers to ensure they remain fully compliant with the Act.
- We will make MDS awareness training mandatory for relevant staff and identify tailored training for key staff and managers.
We will review and refresh the following key policies relating to Hyde’s commitment to the MDS Act:
- Procurement Policy Statement
- Whistleblowing Procedure
- Anti-Fraud and Corruption Procedure
- Probity Policy