Slavery and Human Trafficking Statement

This statement 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 all people particularly with respect to people from vulnerable groups.

It reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

Wandle and its subsidiaries will not tolerate slavery or human trafficking in any of its forms, in any aspect of our business.

The Modern Slavery act applies to ensuring that Wandle’s employees and customers are treated fairly and are not subject to such practices.

Wandle Housing Association Limited (Wandle) is a housing association, incorporated as a Charitable Registered Society, managing circa 7500 homes in South East London, with over 50 years of experience. It is also the parent company of three subsidiaries, which are limited companies. These are:

a. Delta Homes Limited, a wholly owned subsidiary which provides a building and property development service.
b. Ravensbourne Developments Limited, a wholly owned subsidiary which is a property development company focused on building and selling homes for outright sale.
c. Unitworthy Property Management Limited, which holds the head lease and provides management services for one block of properties and is majority owned by Wandle.

The wholly owned subsidiaries donate by way of Gift Aid any profit made to Wandle. The Wandle group has circa 170 employees with around 13 external consultants and agency staff. The Group’s annual turnover is projected to be £61m for 2022/23.

In September 2020, Wandle appointed MCP2 (now 4C Associates Limited) as procurement advisors. The contract with 4C Associates Limited permits for them to provide a procurement team over a three-year period. The majority of Wandle’s procurement exercises (tender and quotations) are undertaken via an e-Procurement platform called Delta e-Sourcing. Within the e-Procurement platform standard selection questionnaire must be filled in by all participating suppliers which includes a designated section on
Modern Slavery.

In instances of Wandle making use of pre-procured frameworks administered by other external organisations we require them to do so in accordance with Public Contract Regulations which, in turn, requires compliance with the Modern Slavery Act 2015.

Furthermore, Wandle’s Procurement Procedures (Part 11) require Modern Slavery Act compliance declarations / proof (i.e. the supplier’s Modern Slavery Policy Statement) to be obtained from suppliers with whom we plan to contract.

We have strengthened contract management and administration practises through resourcing, training, and awareness. This will deliver greater scrutiny to all aspects of contracts, including those touching on the Modern Slavery Act 2015.

Wandle’s procurement team developed a forward procurement plan which provides a continual review of all formally procured contractual relationships. We will also ensure that going our procurement procedures oblige all suppliers to pay a wage in line with the Living Wage Foundation’s wage levels for both London and the rest of the country. This requirement is included in the terms and conditions in our procurement contracts and will has been expanded to include the outside of London Living Wage from July 1st 2021. Our standard checks on supplier’s compliance with our contractual requirements, will include an annual confirmation of payment of the Living Wage Foundations wage levels.

Wandle will continue to review its procurement policies regarding tenders and contracts, to ensure they reflect best practice, and to mitigate against the risk of modern slavery.

We have policies and procedures in place that reflect anti-slavery and human trafficking.
These include:
a) Safeguarding Policy
b) Supplier code of Conduct
c) Procurement Procedures
d) Whistleblowing
e) Domestic Abuse Policy (Residents and Service Users)

All new starters are required to undertake online safeguarding training to build awareness and understanding of our vulnerable customers, how to identify potential risk factors and at-risk groups, including signs of exploitation and how to respond to them. The policy and training help to strengthen our support to staff to spot any abuse which may include modern slavery. We did not have any reports of modern slavery during the year.

With regards our workforce, all Wandle employees are paid at least the London Living Wage. We check identification and ensure all employees have the right to work in the UK. We also conduct DBS checks for all employees working with vulnerable people. These requirements are passed on to any employment agencies used by Wandle. Additionally, salaries will only be paid into bank accounts which are in the employee’s name. We also provide an Employee Assistance service whereby employees can confidentially discuss any issues they are experiencing, and this includes modern slavery. We have implemented an online reporting tool to support staff to report any bullying and harassment which may include modern slavery. This additional support removes any human contact and provides safety for staff to report incidents that they may find difficult to talk about to another person.

As part of our initiative to identify and mitigate risk we work to:
• Identify and monitor potential risk areas in our business, supply chains and properties.
• Mitigate the risk of slavery and human trafficking occurring.
• Protect whistle blowers. We have an up-to-date whistleblowing policy and procedure.

We continue to improve our blended repairs delivery model delivering repairs through a combination of:
a) In-house Direct Labour Organisation, which is directly managed through Wandle
b) Approved sub-contractors, who are sourced through Mears (Our repairs managed
service provider) and managed directly by Wandle.

We recognise that there is always more that we can do to prevent and detect modern slavery and human trafficking. Over the coming year we will continue to monitor the effectiveness of the systems in place to not tolerate slavery or human trafficking in any of its forms, in any aspect of our business. We will assess any evidence of non-compliance and will take appropriate remedial action.