Modern slavery and human trafficking

Hastoe is fully opposed to, and committed to preventing, modern slavery and human trafficking within our organisation and throughout our supply chains. We have put in place, and regularly review, a Modern Slavery and Human Trafficking Policy to demonstrate our commitment to acting ethically and with the highest standards of integrity in all our business dealings and relationships.

We are committed to developing, implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere within our business or in our supply chains. We will never knowingly deal with any business involved in slavery or human trafficking.

This statement is made on a voluntary basis with reference to section 54(1) of the Modern Slavery Act 2015. It relates to the financial year April 2022 to March 2023. It applies to all legal entities that form part of the Hastoe Group. This statement sets out the steps we take to minimise the risk of modern slavery and human trafficking in our business activities and within our supply chain.

Organisational structure and business function

Areas of Risk – Our Business

We estimate the risk of slavery and human trafficking occurring within our own business as being low:

  • Hastoe has robust policies and procedures in place for carrying out background and identity checks on all new employees.
  • We ensure that all staff are eligible to work in the UK and we only pay salaries directly into employees’ personal bank accounts.
  • We will continue to review and update relevant internal policies, procedures and practices, taking effective and proportionate steps to reduce the risk of slavery or human trafficking in our business.

Areas of Risk - Our Properties

We estimate the risk of using a Hastoe property for any criminal, immoral, anti-social or illegal purpose as being low. Any of these activities is a breach of the tenancy agreement.

  • We will take appropriate tenancy enforcement action where cases of slavery and human trafficking are identified within our homes.
  • We have a Safeguarding Policy and Procedure and provide appropriate safeguarding training for relevant employees.

Areas of Risk - Our Supply Chain

We estimate the risk of slavery and human trafficking occurring within our supply chain as being low.

Hastoe has its own procurement regulations and:

  • We conduct due diligence checks on our suppliers.
  • We require suppliers whose turnover is £36M and over to acknowledge that they are required to comply with the Modern Slavery Act 2015. The Contractor warrants that it does so and will publish a Statement about the steps they are taking to ensure its operations and relevant supply chains are free of modern slavery and human trafficking.
  • We require suppliers (for contracts with a value of above £50,000) to warrant that neither they nor any of their officers, employees, nor so far as they are aware, any sub-contractor or other person associated with them, have been convicted of any offence involving modern slavery and human trafficking.
  • We have incorporated the compliance requirements of the Modern Slavery Act 2015 in our standard contract terms for development procurement.
  • We will take prompt action where a compliance breach has been identified and work with the supplier to minimise the risk of this recurring, or terminate the contract.

Working Practices

The following existing policies and procedures contribute to preventing modern slavery and human trafficking:

  • Anti-Fraud Policy
  • Anti-Money Laundering Procedure
  • Code of Conduct
  • Maintaining Standards of Probity
  • Procurement Policy and Procedure
  • Recruitment Policy and Procedure
  • Safeguarding Policy and Procedure
  • Whistle Blowing Policy and Procedure

Performance Indicators

We will know the effectiveness of the steps we are taking to ensure that modern slavery and/or human trafficking is not taking place within our business or supply chain, if we receive no reports from employees, residents, the public, or legal or government agencies, to indicate that modern slavery or human trafficking practices have been identified.

This statement was approved by the Hastoe Board on 20 July 2023 and will be reviewed annually.

Lindy Morgan
Chair, Hastoe Board

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