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.
Our full Modern Slavery and Human Trafficking Statement can be viewed below. It was approved by the Hastoe Board on 13 May 2021 and will be reviewed annually.
Purpose and scope
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 2020 to March 2021. 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
Hastoe Housing Association is registered with the Financial Conduct Authority as an exempt charity, and is registered with the Regulator of Social Housing as a social housing provider.
Hastoe is the leading rural housing provider in England. We own and manage over 7,000 properties across more than 70 local authority areas in the south of the country, and employ around 120 staff. Our main business is providing housing to people with a general housing need at social and affordable rents. We re-invest our operating surplus into new and existing homes and improving our services for the benefit of our customers and their communities.
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.
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 have appropriate mechanisms to end the tenancy agreement where breaches have occurred.
We have a Safeguarding Policy and Procedure and provide appropriate safeguarding training for relevant employees.
Areas of risk - our supply chain
Hastoe has its own procurement regulations and maintains a preferred supplier list. We conduct due diligence checks on all our suppliers before allowing them to become an approved supplier.
Actions - procurement and supply chain
- We require new approved suppliers to complete our targeted due diligence questionnaire to confirm that they are not involved in slavery or human trafficking, and that they are fully compliant with the Modern Slavery Act 2015.
- We have incorporated the compliance requirements of the Modern Slavery Act 2015 in our standard contract terms for development procurement and will look to broaden this to other areas of the business by 31 March 2022.
- 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.
Actions – our business
- We deliver training to all employees so that everyone understands the signs of modern slavery and human trafficking, and knows what to do if they suspect it is taking place within the workplace, in our homes or within our supply chain.
- We will take appropriate tenancy enforcement action where cases of slavery and human trafficking are identified within our homes.
- 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.
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
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.
Antisocial behaviour policy
Our antisocial behaviour policy provides a clear and effective commitment to tackling antisocial behaviour so that staff, residents and partners understand the approach we take.
Equality, diversity & inclusion
Our Equality, Diversity and Inclusion policy explains how we aim to ensure that equality, diversity and inclusion are embedded in all our internal and external services and activities.