Modern Slavery Act
Modern Slavery Statement for Financial Year 2015/16
This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that emh group (consisting of emh group, emh homes, enable housing association, enable care & home support, Sharpes Garden Services and Midlands Rural Housing) has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Emh group has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
The Association was formed for the benefit of the community. Its objects are to carry on for the benefit of the community:
- The business of providing housing, accommodation, and assistance to help house people and associated facilities and amenities.
- Any other object that can be carried out by a Registered Provider registered as a social landlord with the Homes and Communities Agency.
We have around 900 suppliers across the Group.
Risk Assessment and Due Diligence
We consider no areas of our business to be of high risk. Following a research based risk assessment focussing on factors such as levels of staff turnover, procurement controls, outsourcing arrangements and levels of unskilled work, the area of greatest (although moderate) risk is construction, cleaning and care provision via agencies.
The risk has being included within our operational risk map and controls have been documented which will be subject to annual reviews.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
- Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help [see below].
- Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Code of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees to act.
emh group operates a supplier policy and undertakes due diligence on all suppliers that are procured through the Public Contract Regulations 2015 . This due diligence includes an online statement that each supplier is required to complete to show that the organisation has never been convicted of offences relating to modern slavery. Our anti-slavery policy forms part of our contract with all suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They have taken steps to eradicate modern slavery within their business.
- They hold their own suppliers to account over modern slavery.
- (For UK based suppliers) They pay their employees at least the national minimum wage / national living wage (as appropriate).
- (For international suppliers) They pay their employees any prevailing minimum wage applicable within their country of operations.
- We may terminate the contract at any time should any instances of modern slavery come to light.
We regularly conduct training for our procurement/buying teams so that they understand the signs of modern slavery and what to do if they suspect that it is taking place within our supply chain.
Approval for this statement
This statement was approved by the Board of Directors on 24th June 2016.
Name (Director): Chan Kataria, emh group Chief Executive
Date: 24th June 2016
EMH GROUP Anti-Slavery Policy
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. This policy explains emh group’s approach to modern slavery and sets out what you should do if you believe that any form of modern slavery is taking place within our business or supply chain. This policy applies to all individuals working for emh group in any form, including agency workers, volunteers or contractors.
2.0 Our policy
emh group has a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain. We accept that we have a responsibility to ensure, through our due diligence processes and so far as is possible, that workers are not being exploited, that they are safe and that relevant employment, health and safety, and human rights laws and standards are being adhered to, including freedom of movement and communication. If we believe that these rules are not being adhered to, we will notify the relevant authorities.
The prevention, detection and reporting of modern slavery in any part of emh group’s business or supply chain, whether in the UK or abroad, is the responsibility of everyone working for emh group. You must avoid any activity that may lead to a breach of this policy and should report any concerns immediately under the reporting procedure below.
3.0 The procedure to follow
If you believe or suspect that a breach of this policy has occurred, is occurring, or may be about to occur, you must report it either by speaking to your manager or by following the whistleblowing policy. You should raise any concerns that you have as soon as possible, provided that it is safe to do so. If you are unsure about whether a particular act, the treatment of workers, or their working conditions constitutes modern slavery, please raise it with your line manager. You can also call the Modern Slavery Helpline for advice and guidance on 0800 0121 700.
emh group encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. You will not suffer any detrimental treatment as a result of reporting in good faith a suspicion that modern slavery is taking place in any part of the business or our supply chain.
Nominated Officer Responsible: Executive Director Corporate Services
Approved emh group board: 24th June 2016