Section 54 of the Modern Slavery Act 2015 requires larger employers to produce a modern slavery statement for each financial year. This is the Jigsaw Homes Group’s Modern Slavery Statement for 2017/18. The Group is absolutely committed to preventing slavery and human trafficking in our corporate activities and to ensuring that our supply chains are free from slavery and human trafficking and we will put in place arrangements to ensure there is no slavery or human trafficking in our own services, in our businesses and in our supply chains.
The Group was founded in April 2018 from the merger of Adactus Housing Group and New Charter Housing Trust. It has a turnover of £190m, employs over 1,400 staff and manages more than 34,000 homes located in the North West of England and the East Midlands. The Group’s business is primarily centred around the provision of social housing and associated services:
• Management and letting of properties
• Development of new homes
• Repair and maintenance of housing stock and estates
• Revenue collection
• Money and welfare advice
• Charitable donations to individuals and groups
• Supporting victims of domestic abuse
• Supporting vulnerable and/or client groups from disadvantaged backgrounds.
Jigsaw Homes Group and its subsidiaries trade only in the UK and not in any countries where the Group considers there to be a high risk of trafficking and modern slavery.
This statement is approved by the Group Board.
The Executive Management Team (EMT) is responsible for overseeing anti-slavery initiatives, led by the Executive Director for People and the Executive Director for Neighbourhood Services.
The Group’s managers have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.
Management at all levels are responsible for ensuring those reporting to them are given adequate and regular training on it and the issue of modern slavery in supply chains.
The prevention, detection and reporting of modern slavery in any part of the Group’s business or supply chains is the responsibility of all those working for the Group or under its control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.
The Group’s zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter.
The Group may terminate its relationship with other individuals and organisations working on our behalf if they breach this policy
The Group actively manages risk in line with its Risk Management Policy. The Group has determined that there are no areas of its business that are considered to be at high risk of slavery or human trafficking.
We maintain a comprehensive risk management framework and work closely with our Internal Auditors (currently KPMG LLP but being tendered in 2019).
Complementary policies are:
• Health and Wellbeing
• Financial Regulations
• Scheme of Delegations
• Recruitment and selection
• Equality and Diversity
• Probity and Anti Fraud
• Employee Handbook
• Board Member Handbook
The Group has strong links with other agencies through its participation in multi-agency community safety partnerships and safeguarding arrangements with the relevant local authorities where it has housing stock.
The Group expects its employees to report any suspicions of trafficking or modern slavery via its ‘concern card’ procedure. This procedure, which brings to the attention of the relevant Neighbourhood Safety Managers in the Group any safeguarding concerns, is communicated to staff via the mandatory safeguarding training provided to all staff by the Group’s Safeguarding Lead. The Group’s Safeguarding Lead has received training in reporting trafficking and modern slavery concerns.
The relevant Neighbourhood Safety Manager will take a decision as to whether the report merits contacting the local police. Employees may also contact the police direct where those who are committing such crimes or where victims are at risk merits an immediate 999 response, the Modern Slavery Helpline on 08000 121 700 or Crimestoppers on 0800 555 111.
Expectations of Suppliers and Due Diligence
The nature of our work means we engage with a diverse range of private and public sector organisations from local authorities, NHS trusts and the police to local businesses and tradespeople.
The Group is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure that they meet the required standards.
The Group uses employment agencies only by exception and when it does will only use specified, reputable employment agencies.
Jigsaw Homes Group undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. Responsibilities regarding procurement are as set out in the Group’s Financial Regulations. In terms of trafficking and modern slavery this means:
• Evaluating the modern slavery and human trafficking risks of each new supplier
• Conducting supplier assessment on an annual basis focusing on financial stability, covering insurance, compliance with various employment policies and which have a greater degree of focus on slavery and human trafficking where general risks are identified;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
• invoking sanctions against suppliers who fail to improve their performance in line with an action plan or who seriously violate our expectations of suppliers, including the termination of the business relationship.
Our targets for 2019/20 are:
• providing training on trafficking and modern slavery for all staff working in supply chain management and procurement and for our HR professionals
• requiring all our existing suppliers to confirm that they have a Modern Slavery Statement (or reasons for not having one) when reviewing existing contracts
• requiring all new suppliers to provide evidence of a Modern Slavery Statement as part of any future procurement
• celebrating Anti-Slavery Day on Friday 18 October 2019
• continuing to raise awareness and understanding across the organisation of the risk of slavery and human trafficking
• introducing the following statement in all invitations to tender for business with the Group: “We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains. The Group will not support or deal with any business knowingly involved in slavery or human trafficking.”
Review and Publication
This statement will be reviewed annually by the Group board and then published on the Group’s website.
• Jigsaw Homes Group Limited. Registered as a Community Benefit Society with FCA. Registration number: 29433R. Housing Regulator registration number: LH4345
• Adactus Housing Association. Registered as a Community Benefit Society with FCA. Registration number: 16668R. Housing Regulator registration number: LH0131
• Aksa Housing Association Limited. Registered as a Community Benefit Society with FCA. Registration number: 27003R. Housing Regulator registration number: LH3917
• Beech Housing Association Limited. Registered as a Community Benefit Society with FCA. Registration number: 24230R. Housing Regulator registration number: SL3463
• Chorley Community Housing Limited. Registered as a Community Benefit Society with FCA. Registration number: 30155R. Housing Regulator registration number: L4487
• Gedling Homes. Company number: 5975258. Charity Commission number: 1126523. Housing Regulator registration number: L4532
• New Charter Building Company Limited. Company number: 3807120
• New Charter Homes Limited. Company number 3807022. Charity Commission
nnumber 1146435. Housing Regulator registration number: LH4266
• Threshold Housing Project Limited. Company number: 2899314. Charity Commission number: 1054029
• The registered office address for the above companies is Cavendish 249, Cavendish Street, Ashton-under-Lyne, OL6 7AT except that the registered offices for AHA, Beech and CCH are Turner House, 56 King Street, Leigh, WN7 4LJ.
Responsible Officer/s: Brian Moran, Deputy Chief Executive
Richard Houghton, Director of Operations
Date of Approval: 28 March 2019
Approved by: Group Board
To be Reviewed Every: Year
© 2019 Jigsaw Homes Group Ltd