Modern slavery statement

This policy comprises the modern slavery statement of Southdown. Whilst Southdown is not a relevant commercial organisation that meets the threshold in Section 54 of the Modern Slavery Act 2015 (an annual turnover of at least £36 million) this policy seeks to demonstrate our commitment to the principles within the Act.

Southdown has zero tolerance to slavery and human trafficking across its entire business operations. We are also committed to the prevention of slavery and human trafficking, in all its forms. We will not tolerate or condone it within any part of our organisation or supply chain. This statement sets out our commitment to creating and ensuring a non-discriminatory and respectful working environment for all our people and sets out our associated policies for our supply chain.

Policy aims

The guidance on modern slavery is to:

  1. Comply with legislation and regulatory requirements.
  2. Make suppliers and service providers aware that we promote the requirements of the legislation.
  3. Consider human trafficking and modern slavery issues when making procurement decisions.
  4. Develop an awareness of human trafficking and modern slavery within our workforce.

Policy statement

Organisation structure

Southdown Housing Association Limited is a non-registered charity. We are also a registered society under the Co-operative and Community Benefit Societies Act 2014. We are a charitable, regulated organisation that deploys responsible, commercial disciplines in the way we conduct our business.

Our business

We support over 11,000 people a year (approximately 540 of whom are tenants), employ 850 staff and have a turnover of over £32 million. We deliver specialist, person-centred support across Sussex:

  • 24-hour care and support.
  • Mental and physical wellbeing.
  • Peer support.
  • Homelessness.
  • Learning & employment.
  • Social landlord.

Our clients and tenants have mental health difficulties, learning disabilities, housing support to maintain their tenancy or are people who are or have been homeless. A smaller number have addiction issues, sensory or physical disabilities.

Everything we do is driven by our core values (Force for Good, Brilliant with People, United, Responsive and Trustworthy), which are adopted and enacted day in, day out in all our services. Both modern slavery and human trafficking are incompatible with our core values.

Our supply chains

Southdown is committed to acting ethically and with integrity in all our business relationships and to implement and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. As a business for social purpose Southdown will not knowingly support or deal with any business involved in slavery or human trafficking.

Our supply chains include:

  • Supply of temporary staff via agencies.
  • Supply of permanent staff via recruitment agencies.
  • Supply and maintenance of motor vehicles.
  • Supply and maintenance of IT hardware and software.
  • Provision of property support services.

Our approach to procurement and our supply chain includes:

  • Ensuring that our suppliers are carefully selected through robust supplier selection criteria / procurement processes.
  • Requiring contractors to provide similar rigour and controls to prevent modern slavery in their organisation and supply chains.
  • Ensuring that our contract documents contain a clause on modern slavery, anti-bribery and corruption standards.
  • Ensuring that our contract documents contain clauses giving Southdown the right to terminate a contract for failure to comply with modern slavery and anti-bribery and corruption standards.

Our policies relating to slavery and human trafficking

As a responsible provider we have a number of polices that are relevant (either directly or non-directly) to modern slavery, human trafficking and/or child exploitation:

  • Confidential Reporting (Whistleblowing).
  • Anti Bullying and Anti Harassment.
  • Safeguarding Adults.
  • Child Protection and Safeguarding.
  • Complaints.
  • Grievance.
  • Recruitment.
  • Tenders and new business.
  • Procurement.
  • Property Services and Housing Management policies.
  • Employee Handbook, which provides information to all team members on their statutory rights, including, but not limited to, sick pay, holiday pay and any other benefits that they might be entitled to by virtue of their employment.

All our employees are required to comply with these polices in the course of their employment and where appropriate receive training on them.

We acknowledge that modern slavery often takes place in the course of employment and are committed to putting effective systems and controls in place to safeguard against any form of modern slavery taking place:

  • We are committed to treating those who work for us fairly, as an employer we are committed to paying the Real Living Wage (where affordable to do so) and regularly review our terms of employment to ensure they comply with all relevant legislation.
  • We take a robust approach to recruiting both our permanent and flexible workforce (i.e. bank workers). We communicate directly with people to discuss any work opportunities and to confirm details of any offer made. We have rigorous procedures in place for the vetting of new team members and flexible workers and ensure that we are able to confirm their identities and their right to work in the UK. We comply with UK employment law, which means pay at least the National Living Wage directly into a personal bank account. All new permanent team members are required to complete an induction, which includes information and training on the organisation’s policies.
  • We use a centralised agency staff procurement process to further enhance our stringent assurance checks on agency staff including right to work and advanced DBS checks. Only agency suppliers capable of evidencing agency staff compliance with these stringent requirements are added to the agency system as a potential provider of services to Southdown.

Training

Modern slavery is incorporated within our safeguarding policies and included within mandatory training programmes for all staff employed by us. Training on Modern Day Slavery has been delivered to all staff through our mandatory e-learning training as part of Safeguarding Adults Training.

Next steps

We recognise the continuously evolving nature of modern slavery and will continue to review our policies, processes, and training to ensure they are fit for purpose.