This Statement sets out Riverside’s commitment to recognising and 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 staff, particularly with respect to people from vulnerable groups.
The most vulnerable groups in the UK include migrant workers, illegal migrants, asylum seekers and individuals, such as homeless people and people with learning disabilities. We continue to investigate and monitor how modern slavery and human trafficking may affect customers, staff and our business and supply chains and ensure that we respond effectively through our policies and our actions.
This Statement covers our current position on modern slavery and activities undertaken during the financial year 2019/20. The Statement applies to the whole Riverside Group, and all parts of the Group are expected to minimise the risks of slavery and human trafficking in their business and supply chains.
Organisation Structure and Business
Riverside is one of the largest charitable housing association groups in the country, owning and managing over 58,000 homes in England and Scotland for a diverse range of customers, giving a choice of housing for social and affordable rent, low-cost home ownership and outright sale.
With a substantial national profile and over 90 years of experience, 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 9,000 service users, with a diverse range of housing needs.
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 Regulator of Social Housing. Within our group structure, there are a number of subsidiaries including Irvine Housing Association Limited, Prospect (GB) Limited, Evolve Facility Services Limited, and Riverside Estuary Limited. In March 2020, subsidiary Impact Housing Association Limited became part of TRGL following a transfer of engagements.
TRGL (excluding Evolve, Impact and Riverside Direct) employ 2,413 employees of whom 100% work in the UK (working full and part time).
Riverside’s approach to being a responsible business sees us
- Responsibly managing our supply chain.
- Treating customers and suppliers fairly and with respect.
- Allying ethical procurement with value for money.
We have taken time to understand the implications of the MSA and identify the areas within our business and supply chain where the greatest risk exists. These are:
- Procurement – modern slavery can occur in a supply chain through inadequate or inappropriate procurement practices. Our supply chain consists mainly of services rather than goods, with the highest risk areas being associated with our building and maintenance activity.
- Supporting vulnerable clients within Riverside Care and Support – 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.
We have identified the main risks 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.
- Implementing mandatory training for 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 being a responsible business by incorporating requirements on social value. We have now extended this practise to all new suppliers irrespective of whether they have been through a formal procurement process or not.
- Ensuring 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.
Supply Chain & Procurement
We do not have any direct 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 have taken steps to satisfy ourselves that the supply chain for relevant subsidiaries is satisfactory in terms of the requirements of both the MSA, as well as meeting any formal requirements we set out for our suppliers.
Our Group Procurement Policy is designed to ensure that all business units, subsidiaries and commercial entities owned and controlled by The Riverside Group 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 was last reviewed in February 2019, and includes a Statement on modern slavery, along with how to be a responsible company (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; it also requires all Riverside employees to complete training on safeguarding adults and children. A guide to the MSA is available to all employees on the safeguarding pages of Riverside’s intranet, alongside the safeguarding policies and procedures.
As a result of the COVID-19 outbreak we have completed risk assessments for all staff and services. Riverside have increased the communication around Safeguarding which includes Modern Slavery with a number of internal bulletins being sent out to all staff to raise awareness. A specific bulletin has been sent on Human Trafficking and Modern Slavery to ensure all staff remain alert to the signs and understand how to report any concerns appropriately. A banner #YouAreNotAlone has been added to the front page of The Riverside Group website which links directly to the Safeguarding pages of the website.
Our People Policy makes explicit reference to the MSA. The policy also emphasises that Riverside is committed to dignity at work and fair treatment of all colleagues. We also have a Whistleblowing Policy and Employee Code of Conduct.
The Group’s Recruitment and Selection Policy contains relevant requirements in terms of checking eligibility to work in the UK and carrying out of necessary checks such as DBS (Disclosure and Barring Service) checks or Disclosure Scotland checks in Scotland.
Our learning management system, Learning Zone has an eLearning module which covers modern slavery and human trafficking and is a mandatory requirement for all new starters to Riverside. It has a systematic reminder for all staff set for every two years and is automatically added into colleagues’ learning plan when it is due for the completion.
Following completion of the module, every Riverside colleague will:
- Define and explain the meanings of adult and child trafficking, human exploitation and modern slavery.
- Be aware of and make sure to respect the rights of victims of human trafficking.
- Act in line with your own responsibilities as a professional and be aware of the responsibilities of other authorities in the UK.
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 the pre-qualification criteria for suppliers, which includes a requirement to have measures in place to minimise the possibility of modern slavery in their business and supply chain.
We will also monitor our supply chain using Dunn and Bradstreet. This system allows us to check a supplier’s financial viability, credit rating, risk of failure, company overview and names of directors. This facility is particularly important in the current pandemic to allow us to monitor our supply chain appropriately.
We are currently considering the introduction of Constructionline or similar whose gold membership includes legislation checks, such as modern slavery. However other options will also be considered such as employing an external auditor to do audits on our suppliers in relation to modern slavery.
Elements of contract management which are built into performance dashboards are mindful of not creating environments where modern slavery (particularly in the shape of bonded labour) may become a way a supplier or production site tries to deal with unrealistic short time pressure and related expectations on their operations or supplying partnership.
Ongoing frequent monitoring of employee relations cases ensure concerns regarding potentially vulnerable colleagues or circumstances are escalated accordingly. Employee relations cases are monitored and reported on monthly.
Completion of mandatory training is monitored and processes are in place to identify and address instances in which staff members have failed to complete.
During the COVID-19 pandemic the organisation recognised there was an increased risk of Modern Slavery. A number of measures were undertaken to ensure safety and wellbeing during this time including: individual risk assessments for those most vulnerable, social distancing measures, increased Personal Protection equipment and to ensure colleagues were communicated to regarding our policies and wellbeing initiatives.
Based on governance guidelines, we are ensuring that all our suppliers are being paid promptly for the works and services they continue to provide during this period.
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 & General Counsel. Specific responsibilities have been assigned to the heads of services which are identified as key risk areas:
- Supply chain
- Vulnerable clients
- People Services
Group Chief Executive
On behalf of the Board