The Hyde Group Modern Day Slavery Statement for 2023/24
The Modern Slavery Act requires the publication of a statement setting out how the potential slavery and human trafficking risks within our business and supply chain is addressed.
We are one of the largest housing associations working in England, owning or managing circa 44,600 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 preventative 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.
Organisation’s structure
Hyde Housing Association is the charitable parent organisation of a number of subsidiaries, together known as the Hyde Group (“the Group”).
The Group operates within the UK and contracts out the development and construction of properties, as well as some maintenance and repair services. The Group considers its activities to be low risk of modern slavery and human trafficking.
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.
Our purpose
Our core purpose remains the same as it was 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
Policies
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 1400 members of staff and are committed to treating those who work for us fairly.
We are committed to paying the Real Living Wage to all our directly employed colleagues. We regularly review our terms of employment to ensure that they comply with all relevant legislation.
We have an in-house recruitment model. Agencies are only used by exception and we have procured a preferred supplier list of reputable employment agencies. The practices of agencies are verified before accepting workers from that agency.
We expect all employees to adhere to the Group’s 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. Whilst working for, or on behalf of the Group, an approved supplier must adhere to the specific ethical provisions, which are consistent with the values of Hyde, and prevent modern slavery and human trafficking.
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
- Implemented a revised Code of Conduct which applies to all staff and board members, and reminds staff of the need to declare gifts and hospitality and any conflicts of interests.
- Reviewed Hyde’s policies and procedures for the management of Whistleblowing, Anti Money Laundering, Anti-Fraud and Corruption and the Housing of Staff.
- 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.
- Reviewed and refreshed our training.
Future Actions 2022/23
The planned actions for 2024/25 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 continue to provide awareness training for all staff and tailored training for key staff and managers.