Here at Twenty11 Homes, we are committed to an ethical approach to all our work, and expect our suppliers, partners and contractors to meet our standards. We are committed to ensuring we comply with our legal and regulatory responsibilities, including the Modern Slavery Act 2015. This statement sets out how we deliver that commitment, understanding and mitigating the risks of slavery or human trafficking taking place within our business or supply chain, and demonstrating compliance with the Modern Slavery Act 2015 (the Act). Additionally, it summarises the steps we are taking to minimise the risk of slavery or human trafficking in our business or our direct supply chains.
As a community-based housing company, we aware of the risk of modern slavery existing within our homes. We have a strong approach to safeguarding and fraud to ensure that we can prevent, identify and act upon any concerns.
We take seriously our responsibility to ensure a robust approach to ensuring slavery and human trafficking does not exist in any part of our business or supply chain.
Organisational structure and supply chains
Twenty11 is a charitable housing company registered under the Co-operative and Community Benefit Societies Act 2014. We are a community-based housing company in the Wycombe District area of Buckinghamshire, England. We work with a range of contractors and suppliers to manage our homes. Our main contractors are those delivering our repairs and health & safety services. In addition, we purchase goods and services to facilitate the running of our business and our office premises.
Risk assessment and management
Responsibility for compliance with the Modern Slavery Act rests with our Board and executive team, with specific responsibilities have been assigned to the heads of services which are identified as key risk areas:
- Supply chain
- In our homes
- People Services
We have an internal audit programme that supports our assurance in procurement, tenant services and people services. In addition, we have a designated Safeguarding Lead and have procedures in place for reporting any safeguarding issues including suspicion of modern slavery.
Whilst we recognise the risk and impact, we have in place a number of preventative measures to mitigate the risk and consider our overall exposure to the risk of slavery and human trafficking to be low.
Relevant policies and documents
We have a robust framework of policies, procedures and contractual arrangements in place which contribute towards the prevention of slavery or human trafficking within our organisation and supply chain. These include:
- Whistleblowing policy: We encourage all our staff, tenants and business partners to report any concerns about our activities or our supply chains. This includes risk of slavery or human trafficking.
- Behaviour charter: Our charter makes it clear to our employees the actions and behaviour expected of them. We strive to maintain the highest standards of employee conduct and ethical behaviour in everything we do.
- Contractor code of conduct: We are committed to ensuring our key suppliers meet the requirements of the Modern Slavery Act 2015. We work with our key suppliers to ensure that they meet the standards of the Code. Serious violations of our Code of Conduct will lead to the termination of the contract.
- Safeguarding Policy: We are committed to safeguarding adults and children at risk of abuse to help ensure their safety and wellbeing. We play a key part in preventing, being alert to and responding appropriately to concerns of abuse. Staff, contractors, and the wider community are encouraged to report concerns via our safeguarding procedures.
- Procurement Strategy: Sets out our commitment to ensuring that key suppliers who have a turnover over £36m per annum have appropriate policies and procedures in place and have published their own Modern Slavery Statement. Also sets out our requirement for all key suppliers, irrespective of the value of the contract, to comply with our Modern Slavery Statement with particular attention to the use of forced labour and paying below the minimum wage throughout the supply chain, especially where agency staff are employed.
Due diligence processes
- Procurement: Our tender documentation notifies potential suppliers that we will expect them to comply with the Modern Slavery Act. We undertake due diligence when taking on new suppliers and carry out an annual review on our existing suppliers. We expect our suppliers and contractors on our contracts register to carry out their own due diligence on their supply chains (where applicable) and to certify annually that they comply with the requirements of the Modern Slavery Act.
- Contract management: For our contractors working in our homes, we ensure they are clear on our Safeguarding Policy and ways of reporting concerns. To strengthen this, we will seek to record their assurance that staff have completed safeguarding training including how to identify modern slavery and human trafficking.
- Employment: We have robust human resources policies and procedures and ensure that all employees have a legal right to work in the UK We regularly review our terms of employment to ensure that they comply with all relevant legislation. We comply with all minimum wage legislation and our pay awards are reviewed annually and approved by Board. Where we use recruitment agencies, we will ask them to provide assurance of their commitment to complying with the Modern Slavery Act.
- Training: our People team support line managers to ensure that all staff are appropriately trained allowing them to be vigilant to the signs of modern slavery and human trafficking in our homes and on our building/development sites.
Key performance indicators
Our indicators for 2024/25, to comply with the Modern Slavery Act are listed below:
- Key policies relating to modern slavery reviewed as per agreed cycle to ensure they remain up to date.
- All new suppliers who are part of our tendered services will be asked to confirm their compliance with the Act.
- Annual assurance statements from key suppliers on compliance with the Modern Slavery Act and commitment to our Modern Slavery Statement.
- Staff complete safeguarding and modern slavery training as per mandatory training cycle.
Training
All staff are made aware of the policies and documents related to their role and are required to confirm they have read and understood them. This includes our safeguarding, fraud and whistleblowing policies.
As part of our commitment to safeguarding and modern slavery all our permanent staff, irrespective of their role, are required to complete safeguarding training which includes modern slavery on a mandatory learning cycle. As part of this commitment, we will be introducing some standalone training on modern slavery and human trafficking. Our staff also receive training on recognising and reporting fraud.
Board approval
This statement has been approved by our Board, who will review and update it annually.
