Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. Homes for Lambeth (‘HFL’) has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in our supply chains.
HFL is committed to:
- Undertaking and promoting ethical practices and policies to prevent modern slavery and human trafficking;
- Ensuring our personnel and assets are not involved or exploited for the benefit of those involved in such activities;
- Ensuring transparency in our business including throughout our supply chains; and
- Providing a full statement as required under the transparency provisions of the Modern Slavery Act 2015.
This policy applies to all persons working for HFL or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
Risk Assessment and Our Supply Chains
HFL has set out, and circulated to all staff, this Anti-Modern Slavery policy to enhance the various policies which were already in operation.
HFL has risk assessed the group’s business and suppliers and determined that greatest risk lies in our construction operations and use of our housing assets. We expect the high standards from all of our contractors, suppliers and other business partners, and as part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
HFL has adapted the procurement system to require our suppliers to:
- declare that they are not involved in slavery or human trafficking and that they will ensure that they remain slavery and human trafficking free;
- take appropriate steps to ensure that there is no slavery or human trafficking in their own supply chains; and
- Provide a copy of their own Modern Slavery Act statement where required.
HFL’s policy is that it will only deal with suppliers who comply with the above requirements and will not undertake business with suppliers who are known to have engaged in modern slavery and are not taking positive verifiable steps to eliminate such activity from their businesses.
The Board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Chief Executive Officer has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. Comments, suggestions and queries are encouraged and should be addressed to the Director of Operations.
The Board is responsible for approving an annual statement declaring any issues of Modern Slavery within HFL’s businesses or supply chains during the year. HFL will use provide training to relevant staff to ensure that they understand the potential risks of Modern Slavery in delivering our services and managing our supply chain.
Compliance with the Policy
Staff, contractors, agency workers etc must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of HFL’s business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager as soon as possible. You should note that where appropriate, and with the welfare and safety of workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains.