Modern slavery and human trafficking

07 June 2017

In March 2018, Liverty was created through the amalgamation of two housing associations – DCH and Knightstone Housing Group. For the purposes of this statement, “Liverty” refers to the activities of DCH, Knightstone Housing Group, and Liverty during the period 2017/18.

Liverty develops affordable housing for rent and sale in the south west of England and provides landlord, individual support and community services. We own or manage circa 35,000 properties and provide services to over 70,000 residents. We aim to promote the highest standards in how we run our business and in our employment and procurement practices. We support the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

This statement summaries Liverty’s approach and the action we have taken this year in our own company and in our supply chain.

Liverty has an extensive supply chain and we procure goods and services in excess of £150 million per year. Procurement activities take place in England and our contractors and suppliers are predominantly UK based.

We work with a wide range of different contractors, suppliers, and partners. Some of our suppliers subcontract work or rely on recruitment agencies to supply temporary or permanent staff.

By the nature of their businesses, some of our suppliers are potentially at higher risk than others, for example, maintenance, repairs and construction companies, cleaning and grounds maintenance contractors, security firms and specialist managing agents providing support and/or care.

We expect all of these and any other companies we engage with to ensure that their goods, materials and labour-related supply chains fully comply with the Modern Slavery Act 2015 are transparent, accountable and auditable and are free from ethical ambiguities.

Within Liverty, our recruitment and people management systems are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment. They include:

carrying out pre-employment checks: work permits, DBS (where applicable), references

paying at least the national living wage

ensuring that overtime working is voluntary and recompensed, either as pay or time off

implementing appropriate grievance procedures and a comprehensive Whistleblowing Policy

having a robust framework of health and safety policies and procedures.

During 2017/18, we have:

(i) continued to make our staff aware of the Modern Slavery Act through the use of an e-learning training module, including its definitions of slavery and human trafficking and potential risk areas

(ii) carried out ongoing due diligence to support procurement and contract management, reviewing expenditure with contractors and suppliers, identifying potential sector risks and focusing on recognised low-pay sectors. Suppliers identified in the potential risk sectors have been asked at contract review meetings to provide assurance of their compliance with The Act.

(iii) reviewed our procurement guidelines to ensure reference to modern slavery and human trafficking is adequate.

(iv) the terms and conditions used for Liverty’s purchase orders and contracts include the requirement for compliance by suppliers with the Modern Slavery Act 2015.

(v) ensured that tender documentation includes the mandatory exclusion of any bidder who has been convicted of an offence under Part 1 Section 1, 2 or 4 of the Modern Slavery Act 2015.

(vi) reviewed our Whistleblowing Policy and communicated it to staff to ensure that it includes an appropriate framework within which they or any other parties may report suspected modern slavery or human trafficking or any other related practices.

Paul Crawford
Chief Executive