Modern slavery and human trafficking statement
West Kent Housing Association (West Kent) is fully committed to preventing modern slavery within our organisation and throughout our supply chains. This statement sets out the steps we have taken, and actions we intend to take, to minimise the risk of modern slavery in connection with our operations.
Organisational structure and business function
West Kent consists of West Kent Housing Association, West Kent Extra Limited and West Kent Ventures Limited.
West Kent Housing Association is registered with the Financial Conduct Authority under the Co-operative and Community Benefit Societies Act 2014 and is registered with the Homes and Communities Agency as a social housing provider. West Kent Extra Limited is a registered charity and West Kent Ventures Limited is a wholly owned commercial subsidiary.
West Kent owns and manages over 7,000 properties and employs around 280 staff. Our main function is to supply housing to people with a housing need, with the objective of being the leading community provider of affordable homes in Kent. A large proportion of our business also consists of providing support services to people in need.
Areas of risk
West Kent operates exclusively within the South East of the United Kingdom. We have deemed the risk to modern slavery occurring within our organisation and supply chains as relatively low. However, we have identified the biggest areas of risk to be:
- contracted (and subcontracted) labour in relation to construction and property maintenance
- our assets, specifically the homes we provide, being used to facilitate human trafficking and modern slavery.
Procurement and supply
We are reviewing our standard contract terms for procurement to ensure that potential future suppliers are aware of West Kent’s position on slavery, and mechanisms are in place to terminate contracts where involvement in slavery has been discovered.
We are in the process of updating our due diligence checks to identify any potential future supplier with a high risk of involvement in slavery.
We aim to review our existing supplier and contract list by 30 June 2018 to ensure suppliers and contractors are taking appropriate steps to minimise slavery.
We will never knowingly deal with any business involved in slavery or human trafficking.
West Kent has robust procedures in place for vetting new employees and confirming their identities. We ensure that all staff are eligible to work in the UK and only pay salaries directly into employees’ personal bank accounts. We have sufficient processes in place to ensure that we comply with UK employment law.
We will only work with employment agencies that are compliant with the Modern Slavery Act 2015 and this statement.
We have identified the use of our properties to facilitate modern slavery as a risk. To use a West Kent property for any criminal, immoral, anti-social or illegal purpose is a breach of tenancy and one which we will enforce to ensure that our homes are not being used to facilitate modern slavery. We carry out tenancy audits on our properties, including identification checks, to ensure the correct people are living there. We work in partnership with a number of organisations to share intelligence to increase our ability to identify where modern slavery may be taking place.
We manage the housing register for the Sevenoaks district on behalf of Sevenoaks District Council. We have sufficient procedures in place to ensure the appropriate allocation of our homes, and carry out checks to confirm identities. Where a tenancy has been granted subsequent to a fraudulent application, we have appropriate mechanisms to end the tenancy.
We have an e-learning module available to all staff to complete on identifying and reporting modern slavery.
Staff are also encouraged to undertake safeguarding training to identify when someone they come into contact with needs help. For staff whose work predominantly involves direct contact with residents, safeguarding training is mandatory.
We have existing policies which contribute to preventing human trafficking and modern slavery. These include:
- Adult Safeguarding Policy
- Safeguarding Children Policy
- Recruitment Policy
- Whistleblowing Policy
This statement was approved by our board and will be reviewed as and when necessary.
Finance Director and Company Secretary