Anti-Slavery Statement

Who we are

Shepherds Bush Housing Association (SBHA) is committed to ensuring that there is no modern slavery or human trafficking in any part of our business or our supply chains. We are committed to acting ethically and with integrity in all our business relationships and enforcing effective processes and controls to ensure slavery and human trafficking is not taking place anywhere is our supply chains.

SBHA is a registered Housing Association regulated by the Regulator of Social Housing (RSH). As of 4 December 2023, SBHA has been a subsidiary of the Guinness Partnership Limited (TGPL) whose own and separate statement on modern slavery can be found here.

SBHA is diverse. We are much more than a landlord that provides traditional housing provision. We provide a range of services including support for vulnerable people, community investment activities, repairs and maintenance. We have over 5,000 homes in the West London Boroughs including Hounslow, Ealing, Richmond, Brent, Hillingdon, Kensington & Chelsea, and Harrow. Most of our stock is in the London Borough of Hammersmith & Fulham.
 

Statement of Intent

This statement is made pursuant to, and is published in accordance with, section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 March 2024.

Modern slavery is defined as the recruitment, movement, harbouring or receiving of children, women or men using force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.

SBHA is committed to being compliant with the Modern Slavery Act 2015, which gives law enforcement the tools to fight modern slavery, ensures perpetrators receive suitably severe punishments for appalling crimes, and enhances support and protection for victims.

The SBHA Board is responsible for ensuring compliance with the legislation and has delegated authority to the Senior Leadership Team to implement the necessary internal controls, policies, training and reporting to ensure that the risks are minimised. The Managing Director has lead responsibility for ensuring the development and implementation of SBHA’s anti-slavery initiatives. All staff have a role in ensuring that they carry out their roles in accordance with this Statement and in compliance with SBHA’s policies and processes.

We are committed to reviewing this statement annually and reviewing any measurables that are outlined in the statement
 

Our Supply Chain

SBHA engages with a wide variety of organisations for a broad range of goods and services. These are primarily corporate, construction and property maintenance-related services, but also to meet some more specialist requirements. Our procurement activities take place in England and all our contractors and suppliers are UK based. We are committed to using local firms wherever possible allowing us to develop close working relationships. This also links into our commitment to social value and responsibility and our wider commitment to being an ethical and sustainable organisation.

This statement extends to all our suppliers as well as their subcontractors and confirmation of their commitment to this is required as part of the tendering process. Tender packs and contracts include wording around statutory compliance, which includes Modern Slavery. All our supplier are also asked a self-certification question as part of the onboarding process with 5% being checked by the Procurement Compliance Team.

Should any unethical or high-risk practices be identified or observed by SBHA with any supplier, contractor or subcontractor this will be investigated and appropriate steps will be taken to remedy matters, including terminating third-party relationships where necessary. In addition, and in line with its zero-tolerance commitment to modern slavery and human trafficking, SBHA will not continue to work with suppliers and contractors where they fail to demonstrate minimum required standards of transparency.
 

Our Residents & Properties

We understand that our customer base is made up of a diverse set of backgrounds and needs, and that isolated customers or individuals with vulnerabilities may be especially at risk. We will, therefore, carry out processes to help us identify any at risk or vulnerable residents or groups in our properties.

We carry out tenancy audits (including ID checks) on an annual basis, and ensure that all appropriate processes are in place to make sure that homes are allocated appropriately. We will also ensure that all our front-line staff who visit customers’ homes have completed the appropriate safeguarding training and understand fully how to raise/report any safeguarding concerns they may have. We will ensure that we utilise our partnerships with external organisations to share intelligence, which will better our ability to identify where Modern Slavery could potentially be taking place.

We recognise that the use of our homes to facilitate Modern Slavery is a risk, and so, any suspected cases of tenancy fraud will be reported to our Audit & Risk Committee on a quarterly basis. Likewise, any tenancy found to have been granted on a fraudulent application will be terminated through the appropriate mechanisms.

As part of the annual report to SBHA’s Board, we will confirm how many tenancy audits have been completed against the target and by exception how many safeguarding issues were raised.
 

Our Colleagues

We believe that everyone has a crucial part to play in tackling Modern Slavery and Human Trafficking, and we will continue to do all we can to raise awareness so that staff are able to understand, identify and report on any potential risks.

We ensure that relevant processes comply with UK employment law. This includes a commitment to meeting salaries in accordance with the Living Wage Foundation, and the National Living Wage for apprentices.

All our staff-based policies and procedures comply with UK employment law and work to mitigate the risks posed by Modern Slavery and Human Trafficking as follows:

• All new employees go through robust vetting procedures and ID confirmation, including, where required, the necessary DBS checks
• Any temporary staff are sourced through reputable agencies and under the supervision of the HR team
• All staff must complete mandatory training in the form of e-learning, and we monitor and report on the total percentage of staff who do so
   

Relevant Policies

We operate the following policies that are relevant to slavery and human trafficking. Our policies are reviewed at least every three years and supported by training and communication:

Employee Charter - We strive to maintain the highest standards of employee conduct and ethical behaviour in delivering our services and managing our supply chain. The Employee Charter sets out the behaviours expected of our employees when representing SBHA.

Procurement Policy - SBHA is committed to ensuring that its suppliers adhere to the highest standards of ethics as part of the procurement process. Suppliers are required to demonstrate that they provide safe working conditions, treat employees with dignity and respect and comply with relevant employment legislation. SBHA moved to a new Procurement Strategy in 2023 as part of its merger with The Guinness Partnership Limited. This will further strengthen our approach to procurement, contract management, and supplier onboarding.

Safeguarding Policy - this policy sets out how SBHA will manage our obligations related to the Care Act 2014 and The Children’s Act of 1989 and 2004 when safeguarding of adults and children living in our properties. We recognise and encourage the need for diversity and are committed to promoting this objective. This policy was revised and approved by the SBHA Board during the year.

Recruitment - SBHA will undertake all relevant pre-employment checks prior to staff being employed. We will carry out fair and transparent recruitment processes and will ensure our recruitment agencies comply with these requirements in the provision of agency staff.

Whistleblowing Policy - SBHA is committed to the highest standards of quality, probity, openness and accountability and as part of this commitment provides a confidential reporting process for employees to report serious concerns about any aspect of our work which includes abuse or neglect of vulnerable people. This policy was replaced by the Guinness Whistleblowing Policy in late 2023 to ensure consistency in approach across the Group.
 

Future areas of focus

During 2024/25 SBHA will continue to integrate into TGPL. This will include continuing to embed TGPL’s procurement, contract management, supplier onboarding processes, training and assurance processes. This will strengthen and diversify SBHA’s approach to mitigating the risk of slavery or human trafficking in the delivery of our services and supply chain.

This statement has been approved by the Board of Shepherds Bush Housing Association. This is expected to be SBHA’s last standalone Statement. As of 2024/25, SBHA will be included in the TGPL Statement.
 

Compliance 

We have not identified any breaches of the Act in our business or our supply chains during 2023/24. 
 

This Statement was approved by the Board on 17 July 2024.