Slavery and Human Trafficking Statement
This statement is made pursuant to s54 Modern Day Slavery Act 2015 and is Gentoo’s Slavery and Human Trafficking Statement for the financial year ending March 2019. This statement applies to Gentoo Group and its subsidiaries.
Our Structure and Business
Gentoo Group comprises the parent Gentoo Group Limited and its subsidiaries.
Gentoo is a housing association that owns or manages more than 28,000 properties. We believe that by putting people first we can build great homes and create strong communities. We are focused on delivering an outstanding service to our customers and as a responsible business, we pride ourselves on inspiring people to make a difference. We collaborate with key partners and other housing associations to influence things that affect our colleagues, customers and society. We are one of the largest employers in Sunderland and landlords in the North East.
Gentoo Homes is a subsidiary of Gentoo Group Ltd and is one of the North East's most successful housing developers. They have experience and expertise in property related activity ranging from regeneration and modernisation to new build schemes. Gentoo Homes are a profit for purpose business and reinvest back into Gentoo.
Our policies in relation to slavery and human trafficking
Housing management policies
Gentoo take a zero tolerance approach to human trafficking and slavery, in our supply chains or any other part of our business.
The Group’s safeguarding policies highlight that modern slavery, which encompasses slavery, human trafficking, forced labour and domestic servitude, are a form of abuse and must be dealt with as a Category 1, which is our highest priority. These policies give staff guidance to help recognise such signs of abuse, and how to deal with it with our partners.
As part of our Tenancy Management policy, Gentoo staff complete regular Customer Surveys, which aim to ensure that the legal tenant and their household are living in the property and that it is not used for illegal purposes, which includes human trafficking and slavery.
As Gentoo employs approximately 1200 employees we recognise the potential for slavery and human trafficking to affect employees working within its business.
To ensure its employees are not subject to undue influence and are treated with dignity and respect, Gentoo has robust HR policies and procedures in place across all its operations. These are regularly audited to ensure compliance with employment legislation and prevent unethical working practices. Gentoo is committed to ensuring that all staff receive fair remuneration for the job they perform and undertakes regular reviews of terms and conditions across the workplace. As stated in our Equality, diversity and Inclusion Policy, when using agencies and other bodies associated with the employment of the Group, the Group will ensure that steps are put in place to ensure that no slavery or human trafficking is in these supply chains and that thorough checks and procedures are in place to work with such bodies. Our Code of Conduct, which staff, contractors and suppliers must sign up to, requires adherence to all relevant legislation. This includes the Modern Slavery Act.
Our supply chains
Gentoo Group procures a wide range of goods and services via a diverse and varied supply chain, including but not limited to the following:
Due Diligence and supplier adherence to our values and ethics
Supply chain is the Group’s key risk area including suppliers, contractors and partners. The Group’s zero-tolerance approach to modern slavery will be communicated to all suppliers and contractors at the outset of our business relationship with them, and also reinforced as appropriate thereafter. Suppliers are required to abide by the Group’s Code of Conduct, which states that they must comply with all laws, this includes the Modern Slavery Act.
We require all of our contractors to register with the Contractors Health and Safety Scheme (CHAS) to the level of Premium Plus status. CHAS asks contractors multiple questions in relation to modern slavery. Gentoo previously used Constructionline who also capture information in relation to the Modern Day Slavery Act and we will continue to accept contractors with Constructionline membership until the end of December 2019 to allow time for a transition to CHAS. As part of their registration with both Constructionline and CHAS, the company is asked if they have a policy/statement that sets out the steps their organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of their supply chains or in any part of their own business and to provide any relevant information.
The OJEU tender process requires that all suppliers and contractors answer a question as to Modern Day Slavery.
We periodically send letters to all of our supply chain to answer the following question:
The Modern Day Slavery Act 2015 requires organisations with a turnover of £36 million or more to produce a Slavery and Human trafficking statement each financial year.
Is your turnover over £36million YES/NO if yes:
Do you have a policy/statement that sets out the steps your organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of your supply chains or in any part of your own business. YES/NO if yes please provide details
The above will be monitored and any areas of concern will be addressed and if required the supplier will be suspended for use until we are satisfied with their commitment. We will take the appropriate action against any suppliers who have been suspended; we will try to help those suppliers get re-instated or as a last resort they may be removed from the site and no further order received.
Specific training has been undertaken on a risk-based approach, in which those employees most likely to encounter issues are trained as priority. Information covered includes how to spot likely signs of ‘modern slavery’ and how to escalate concerns. Gentoo also has a revised ‘Whistleblowing’ policy which allows concerns to be reported on a confidential basis and without fear of recrimination. We will encourage our staff, suppliers and contractors to use the Whistleblowing process to report any incidents of concern regarding potential modern slavery.
All Staff will be briefed annually on the issue of slavery and human trafficking, including how to recognise and deal with it.