Here at Twenty11 Homes, we're committed to an ethical approach to all our work, and expect our suppliers, partners and contractors to meet our standards. As a community-based housing company, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
This statement summarises the steps we are taking to minimise the risk of slavery or human trafficking in our business or our direct supply chains.
Organisational structure and supply chains
We're a community-based housing company in the Wycombe district area of Buckinghamshire, England. We work with a range of contractors and suppliers to manage our homes. As a local housing provider with robust policies, we do not consider any areas of our business to be at high risk of slavery or human trafficking. However, we still take this very seriously and are working with our suppliers to reduce this risk even further.
Responsibility
Policies
- Our Board is responsible for ensuring relevant policies are regularly reviewed.
Investigations/due diligence
- Our People Team ensure we comply with legislation in recruitment
- Our Procurement Team ensure suppliers meet our contractor code of conduct requirements
- Our Governance Team ensures relevant policies are adhered to.
Training
- Our People Team ensures all our staff are appropriately trained
Relevant policies and documents
We have a range of documents and processes to minimise the risk of slavery and human trafficking in our operations:
- Whistleblowing policy: We encourage all our staff, customers and business partners to report any concerns about our activities or our supply chains. This includes risk of slavery or human trafficking.
- Behaviour charter: Our charter makes it clear to our employees the actions and behaviour expected of them. We strive to maintain the highest standards of employee conduct and ethical behaviour in everything we do.
- Contractor code of conduct: We are committed to ensuring our suppliers meet the requirements of the Modern Slavery Act 2015. We work with our suppliers to ensure that they meet the standards of the code. Serious violations of our Code of Conduct will lead to the termination of the contract.
- Temporary workers: We only use reputable employment agencies to source temporary staff, and we verify the practices of any new agency we intend to use.
Due diligence
We'll undertake due diligence when taking on any new suppliers and regularly review our existing suppliers. We expect our suppliers to carry out their own due diligence of their suppliers/contractors. Our due diligence and reviews include:
- Evaluating the modern slavery risks of each new supplier
- Conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking, where specific risks are identified.
Performance measurements
We will:
- Review all relevant policies and processes
- Train all staff on modern slavery
- Complete a system for supply chain verification for new contractors
- Review our existing direct supply chain.
Training
- New staff receive an overview of our approach to combating and identifying modern slavery
- All staff will receive an annual update on the Modern Slavery Act
- Our safeguarding training is mandatory for all staff and includes how to identify modern slavery
- We require all procurement and contract management staff to complete awareness training on modern slavery.
Our modern slavery training covers:
Our procurement process
- How we identify the signs of slavery and human trafficking
- What initial steps should be taken if slavery or human trafficking is suspected
- How to escalate potential issues to the relevant parties
- What external help is available
- What steps we will take if suppliers do not meet our Contractor Code of Conduct.
Awareness-raising programme
As well as training our staff, we'll be including briefings on modern slavery in our staff communications in order to raise awareness.
Board approval
This statement has been approved by our Board, who will review and update it annually.
