This statement sets out Riverside’s commitment to preventing slavery and human trafficking in all its business activities and within its supply chains. It outlines the steps we have taken to ensure compliance with the Modern Slavery Act 2015 (MSA) and minimise the risks of any association with practices which undermine the principles of safety and dignity for our customers and at work, particularly for people from vulnerable groups. It covers our current position on modern slavery and activities undertaken during the financial year 2016/2017.
Organisation Structure, Business and Supply Chains
Riverside is one of the largest charitable housing association groups in the country, owning and managing over 53,000 homes in England and Scotland.
With a substantial national profile and over 80 years of experience in developing affordable housing, we work in some of the country’s most challenging neighbourhoods. Our large supported housing and retirement living business, Riverside Care and Support, provides high quality support to more than 12,000 service users, with a diverse range of housing needs.
Riverside’s approach to corporate social responsibility is set out in our booklet Corporate Social Responsibility; Making it our Business. This states that we are committed to:
- Responsibly managing our supply chain.
- Treating customers and suppliers fairly and with respect.
- Allying ethical procurement with value for money.
The Riverside Group Limited (TRGL), our Group parent, is a charitable registered society under the Co-operative and Community Benefit Societies Act 2014; it is also a registered provider of social housing with the Homes and Communities Agency. Within our group structure there are a number of subsidiaries including Irvine Housing Association, Prospect, Compendium, Evolve and Riverside Estuary Ltd (REL).
Whilst our modern slavery statement applies to the whole Group, and all parts of the Group are expected to minimise the risks of slavery and human trafficking in their business and supply chains, REL is the only subsidiary with sufficient turnover to require formal coverage by this statement. We have taken steps to satisfy ourselves that the supply chain for REL is satisfactory in terms of the requirements of both the MSA as well as meeting any formal requirements we set out for our suppliers.
Responsibility for compliance with the MSA rests at the highest level with our Group Board and across the whole Leadership Team, with responsibility for the statement assigned to the Director of Governance & Legal Services. More detailed risk assessments have been assigned to heads of service for:
- Supply chain.
- Vulnerable clients.
- Human resources.
Our supply chain consists mainly of services rather than goods with the highest risk areas being associated with our building and maintenance activity. We do not have any supply chain outside the United Kingdom. We are increasingly moving to a centralised supply chain using a ‘purchase to pay’ system which requires the use of pre-approved suppliers; this means that there are more rigorous controls in place prior to expenditure being committed as well as improved visibility for retrospective checks.
We may also come across slavery and/or human trafficking in connection with the vulnerable people we support, in particular those from minority or socially excluded groups who may be subject to forced labour and/or domestic servitude, and potentially in connection with our workforce. Accommodation provided by the Group could also be a potential venue for modern slavery.
Policies on Slavery and Human Trafficking
The MSA requires that organisations take steps to address modern slavery and human trafficking in their businesses and supply chains. As Riverside has a turnover of over £36m, we are publishing this statement setting out what we have done to recognise and prevent potential incidences of modern slavery.
The most vulnerable groups in the UK include migrant workers, illegal migrants, asylum seekers and individuals such as homeless people and people suffering from learning difficulties. We are working on identifying how modern slavery and human trafficking may affect customers, our business and supply chains. This involves educating staff about potential risks and capturing best practice in policies and procedures.
Our procurement policy is designed to ensure that we operate in a legal, ethical and inclusive manner whilst achieving best value for money. This includes enabling our procurement activity to generate social and environmental, as well as commercial, benefits. It has recently been reviewed and includes a statement on modern slavery along with social value and sustainability.
The Riverside Safeguarding Policy includes reference to modern slavery as a type or pattern of behaviour which constitutes abuse of a person at risk. The MSA is available to all employees on the safeguarding pages of the Riverside intranet, alongside the safeguarding policies and procedures.
Our People Policy was reviewed in November 2015 and makes explicit reference to the MSA. The policy also emphasises that Riverside is committed to dignity at work and fair treatment of all colleagues. In 2016 we also reviewed our Whistleblowing Policy and Employee Code of Conduct.
The Group’s Recruitment and Selection Policy contains relevant requirements in terms of checking of eligibility to work in the UK and carrying out of necessary checks such as DBS (Disclosure and Barring Service) or Disclosure Scotland checks in Scotland.
We have taken time to understand the implications of the MSA and identify the areas within our business and supply chain where the greatest risks exist. These are:
- Procurement, and
- Supporting vulnerable clients within Riverside Care and Support.
We have undertaken risk assessments in respect of these key areas and put measures in place to mitigate them. These include:
- Undertaking a review of our policy framework and instigating amendments to support compliance.
- Sending a communication to every employee explaining the implications of the MSA and what they should do to recognise and report potential incidences.
- Screening our procurement documentation to ensure that adequate safeguards are in place at each stage in the process i.e. soft market testing, pre-qualification questionnaires and formal tender. Our documentation already reflects our commitment to corporate social responsibility by incorporating requirements on social value.
- Ensuring that both Riverside and any preferred supplier employment agencies we use have the correct checks and balances within recruitment systems such as eligibility to work in the UK and Disclosure and Barring Service (DBS) or Disclosure Scotland checks.
- Our approach to training has been assessed and new tools are in development (see below). Riverside Care and Support has been an area of focus due to greater exposure to risk associated with vulnerable people.
Whilst a wider range of performance indicators will be considered in the future, the main method of monitoring effectiveness within the supply chain will be as follows:
The pre-qualification criteria for suppliers will include a requirement to have measures in place to minimise the possibility of modern slavery in their business and supply chain.
A briefing providing background information and advice for staff on what to do if they suspect that slavery, human trafficking, forced labour or domestic servitude are taking place, and also providing guidance on the selection of suppliers, has been sent to all employees and posted on the Group’s intranet.
A module on modern slavery was incorporated into our new Learning Management System in 2016 and it is now an induction requirement that all new employees undertake this training.
The Safeguarding Policy requires all Riverside employees to complete training on safeguarding adults and children. In June 2015, to raise awareness and in response to the implementation of the Care Act 2014 requiring modern slavery to be included in safeguarding procedures, a leaflet on human trafficking and modern day slavery was communicated to all relevant employees.
Targeted training continues, for example in the Wakefield Area all employees in Riverside Care and Support have received training on human trafficking and modern slavery from Hope for Justice, a charitable organisation working to end human trafficking. A presentation drawn from this training and the MSA itself was delivered to the Safeguarding Working Group in December 2015, the working group is made up of safeguarding leads from all parts of Riverside.
Group Chief Executive
On behalf of the Board