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 2017/18.
Organisation Structure, Business and Supply Chains
Riverside is one of the largest charitable housing association groups in the country, owning and managing over 52,000 homes in England and Scotland.
With a substantial national profile and almost 90 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 being a responsible business is set out in our booklet Corporate Social Responsibility; Making it our Business. This states 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 Regulator of Social Housing. 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. 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 organisations to 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 with 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 the potential risks and capturing best practice in policies and procedures.
Our Procurement Policy is designed to ensure 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 was last reviewed in April 2016, 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; it also requires all Riverside employees to complete training on safeguarding adults and children. The MSA is available to all employees on the safeguarding pages of Riverside’s intranet, alongside the safeguarding policies and procedures.
Our People Policy was reviewed in December 2017 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 2017, 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) checks 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 being a responsible business by incorporating requirements on social value.
- 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.
- Our approach to training has been assessed and new tools are in development (see ‘training’ 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 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 have plans to engage with Constructionline for the monitoring of continued compliance of our supply chain to our standards for the whole contract period. This means we will be informed should any of our supply chain partners lose an accreditation, a certification, get a financial warning or let their insurances lapse etc. Gold Membership includes legislation checks, such as modern slavery.
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 reacquisition 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.
Group Chief Executive
On behalf of the Board