Modern Slavery Act 2015
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. Second City Housing Ltd is committed to improving our practices to combat slavery and human trafficking.
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 financial years 2021 – 2023.
Organisational structure
As one Birmingham’s largest accommodation providers, we provide temporary accommodations for the local authorities for homeless families, social services and domestic violence individuals. Second City Housing Ltd, was set up in 2016 to provide accommodation and support to individuals who are at risk of homelessness. Our main aim is to deliver holistic housing services to maximize tenancy
sustainability and assist individuals on a pathway into employment, training & advice. Second City Housing employs over 50 paid staff, with an annual turnover of £5 million at year-end October, 2022.
Our policies on slavery and human trafficking
Second City Housing Ltd is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. In light of the obligation to report on measures to ensure that all parts of our business and supply chain are slavery free we have put in place a designated Modern Slavery and Human Trafficking Policy. Our Modern Slavery and Human Trafficking Policy demonstrate our 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 our supply chains.
Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have in place:
Human Resource procedures:
- A comprehensive range of policies and practices have been applied including an Equality and Diversity Statement, Dignity at Work, formal grievance and disciplinary policies to protect and ensure that staff rights and responsibilities are upheld.
- Regarding pay, Second City Housing Ltd uses the national single pay spine structure, operated by most higher education institutions in the UK and has safeguards to ensure that the hourly rate of staff not fall below the current national Living Wage.
Procurement procedures:
- Engage with our supplier base.
- Identify and monitor potential risk of slavery and human trafficking in our supply chains.
- Incorporate within the tender process to address slavery and human trafficking with potential new suppliers.
Supplier adherence to our values
Second City Housing Ltd has a zero tolerance to slavery and human trafficking. To ensure all those in our supply chain (including contractors) comply with our values we have in place a supply chain compliance action list.
- Engage with supplier base to secure a commitment to work with us to identify and monitor slavery and human trafficking down the supply chain.
- Register all supplier responses on an annual basis.
- Engage with potential new suppliers about commitment to our Modern Slavery
Policy. - Reduce and identify our key supply chains in the following areas of
expenditure:
a. Facilities
b. Estates
c. Equipment
d. Professional Services
e. Advertising
f. IT
g. Library
h. Marketing
i. Travel
j. Print
k. Subscriptions
l. Catering
m. Stationery
n. Banking
o. Equipment’s and Consumables
Raising awareness
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we intend to provide training to our staff, via Modern Slavery as a regular agenda item to be discussed at management meetings within the company and support Departments, with information to be cascaded through the organisation. Monitoring will be managed through the current, Disclosure of Conflict of Interest.
We also require our business partners to provide training to their staff and supplier chains, this will be facilitated through a variety of supplier engagement activities identified below.
Our effectiveness in combating slavery and human trafficking
We have built upon existing monitoring already in place and developed further processes to allow for more effective reporting in the longer term.
Further steps
Following a review of the effectiveness of steps we have taken to date to ensure that there is no slavery or human trafficking in our organisation and supply chains we intend to take the following further steps to combat slavery and human trafficking.
Human Resources
Second City Housing Ltd.’s policies and reporting mechanisms are regularly reviewed to identify areas for further review and issues to be addressed. To inform the company of possible inconsistencies between policy and practice, Second City Housing Ltd undertakes company-wide Surveys, which includes questions about the experiences of staff relating to their experience of the company, instances of bullying/harassment/discrimination and the ability to manage work-life issues as employees of Second City Housing Ltd.
The results are compared against past surveys and sector benchmarks. Action plans are developed to tackle issues that are identified. The latest Survey was undertaken in July, 2022, with results, analysis and actions to be shared across the institution. Monitoring of Modern Slavery will be incorporated into this mechanism.
Review of Procurement and Payment Systems
An outcome of a review of our procurement and payment systems will be streamlining of the current supplier base, which will enable:
Engagement with a manageable supplier base, to complete and return a questionnaire, which seeks to collect and identify suppliers’ position and progress against Modern Slavery within their organisation and supply-chain.
- Responses will be reviewed and appropriate action taken.
- All responses will be held centrally on the Finance System, to allow for monitoring and reporting.
- Reporting will be on an annual basis.
APPROVED BY Senior Management of Second City Housing Ltd
Darren Davey,
Director