Slavery and Human Trafficking Statement

 

Background

The Modern Slavery Act 2015 introduced an obligation on organisations to produce an annual statement of the measures they have taken to ensure there is no modern slavery (including human trafficking) in their own businesses or supply chains.

Any commercial organisation in any sector carrying on a business in the UK, with a total annual turnover of £36 million or more, is required to produce a slavery and human trafficking statement for each financial year. The obligation is to produce a statement of the steps taken to ensure there is no modern slavery taking place, not to guarantee that it isn’t happening. This statement sets out the steps that Clearsprings Ready Homes Ltd (Ready Homes) has taken, and continue to take, in the current financial year.

Ready Homes provides accommodation services across London, the South of England and Wales, managing over 2,000 properties, with a workforce now of approx. 200 employees. Its current supply chain includes over 700 active suppliers for the last financial year with spend in excess of £20m.

Steps taken to address Modern Slavery and Human Trafficking

Ready Homes continues to monitor modern slavery and human trafficking in line with the Clearsprings Group Anti-Slavery and Human Trafficking Policy, which was first introduced in 2017. The policy reflects the Group’s commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in the supply chains of the constituent group companies. Board approval of the policy was re-affirmed at the end of March 2021 when it was last reviewed / updated.

Ready Homes Supply Chain

The current supply chain includes major national companies, regional companies and small medium enterprises together with local family businesses.

The Ready Homes policy is for suppliers with spend above £50k per annum to have a signed contract in place and for them to confirm that they have their own Modern Slavery statement (if they meet the statutory thresholds) in place.

New tenders have the legal requirement for antislavery and human trafficking to be included and bidders are expected to uphold the same values as part of the bidding process they are required to:

  • Confirm that they have their own Modern Slavery statement [if they meet the statutory thresholds] and provide a copy

  • Accept clauses into new supplier contracts that the supplier will take its own steps to eradicate slavery, and that prohibit the use of forced, compulsory or trafficked labour.

Our Employees

When we are carrying out recruitment, we ask candidates to bring with them to interview proof of their eligibility to work in the UK.  Ideally, the candidate will produce their passport. If they do not have a passport or it has expired, they are required to provide other evidence, as outlined in the Asylum and Immigration Guidance.

Ready Homes Whistleblowing Policy is mentioned within the organisations Code of Conduct/ Employee Handbook. This is cascaded to all new employees at their day one induction, where we check that they have read the policies and, if not, ensure they have time to do so within their first week of employment.

All Ready Homes staff have been made aware of the Whistleblowing Policy, which provides details of how to raise a concern about issues such as modern slavery. Anyone who raises a genuine concern under the Whistleblowing Policy is protected against reprisals.

Our Customers

As part of the day-to-day operations for customer facing employees the following guidance is accessible and communicated:

How staff and contractors can spot the signs of modern slavery

Abuse of individuals is not always clear cut.  Someone could choose to work for less than the minimum wage, or in an unsafe condition, and not necessarily be forced or deceived.

Signs of slavery are often hidden, making it even harder to recognise victims.  Some are more apparent, for example:

  • A tenant’s home taken over against the tenant’s will by drug dealers to use as a base from which to supply drugs

  • Persons forced into prostitution and controlled.

  • Enforced production or growing of drugs such as cannabis.

Victims are forced to carry out housework and domestic chores in private households with little or no pay, restricted movement, very limited or no free time, minimal privacy and joint surrender in favour of a sole tenancy

  • Often sleeping where they work.

How staff and contractors can spot the signs of modern slavery

  • Physical Appearance: Victims may show signs of physical or psychological abuse, look malnourished or unkempt, or appear withdrawn

  • Isolation: Victims may rarely be allowed to travel on their own, seem under the control, influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work.

  • Poor living conditions: Victims may be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address, locks on internal doors together with lots of mattresses present in the property

  • Few or no personal effects: Victims may have no identification documents, have few personal possessions and always wear the same clothes day in day out. What clothes they do wear may not be suitable for their work

Restricted Freedom or Movement:

  • Unusual Travel Times: Victims may be dropped off/collected for work on a regular basis either very early or late at night

  • Reluctance to seek help: Victims may avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family.

All contractors are aware of Ready Home’s Safeguarding Policy and, where appropriate, training is also provided to contractors. The policy has a clear reporting mechanism for all staff/contractors to ensure that if any concerns are noticed, they will be actioned.

Further Steps

This statement and our Anti-Slavery and Human Trafficking Policy are available to all directors, managers and employees via the company’s internal Sharepoint drive.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the company’s financial year ending 31st January 2021.

It was approved and signed by our Board on 22nd March 2021.