Modern slavery act compliance statement
This statement sets out Livv Housing Group’s (the Group) actions to understand all potential modern slavery risks related to the business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business or supply chains.
We are pleased to state that during the reporting period there have been no recorded incidents of modern slavery.
The statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and Livv Housing Group’s slavery and human trafficking statement for the financial year 2020 – 2021.
Structure and supply chains
As of the 1st April 2020, Livv Housing Group changed its business model and continues to provide a range of services and life changing opportunities to our customers.
Our prime objective is to work alongside our customers and local, regional and national partners to be the provider of choice for great homes and much more. This means being willing and able to help people tackle tough issues, we aim to do this through our new structure which is outlined below.
In order to achieve our aims and objectives, we procure a vast amount of different goods and services. As a result, we have a diverse supply chain including:
- Property contractors (repairs and maintenance)
- Marketing and Communications
- Office supplies
- Corporate goods (IT, recruitment services and training)
As a Group, we are aware that we have a responsibility to take a robust and zero tolerance approach to slavery and human trafficking. We are also committed to ensuring there is transparency in our own business and our approach to tackling modern slavery is consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect our contractors, suppliers and business partners to share the same high standards.
Policies on modern slavery
The Group operates the following strategy and policies that describes its approach to the identification of modern slavery risks, as well as the steps to be taken to prevent slavery and human trafficking in its operations:
- Procurement Strategy – The Group ensures that its procurement and financial processes follow best practice. This supports mitigating/eradicating procurement risks and a controlled environment is developed and constantly maintained.
- Whistleblowing Policy – The Group encourages all employees, customers and other business partners to report any concerns related to any direct activities or the supply chains of the Group. The Group’s whistleblowing procedure is designed to make it easy for employees to make disclosures without fear of retaliation.
- Employee Code of Conduct – The Group’s code makes clear to employees the actions and behaviour expected of them when representing the Group. It strives to maintain the highest standards of employee conduct and ethical behaviour when managing its supply chain.
- Recruitment and Selection Policy and Agency Worker Policy – The Group uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Safeguarding Policy – The Group works in partnership to protect adults and children from abuse. Employees, partners, contractors and volunteers are aware of the Group’s approach and the necessary steps they must take.
During the year we have also carried out a review of our Policy & Strategy Framework, actions to streamline our policies and further strengthen our approach to modern slavery with them is currently underway. The changes will be reflected in next year’s statement.
Due Diligence processes
The Group undertakes due diligence when considering taking on new suppliers. Our standard tender documentation for all businesses requires organisations to declare whether they comply with the Modern Slavery Act 2015.
As part of the Group’s commitment to eradicating Modern Slavery, we will only trade with suppliers who fully comply with the Act or are taking the necessary steps towards compliance. As part of our procurement process, bidders are required to indicate whether they comply with the Act. If bidders are currently non-compliant, they are required to state what reasonable measures they intend to implement in order to achieve compliance. Any bids which state they are non-compliant and have failed to provide sufficient detail of their proposed reasonable measures, will be rejected.
The Group is a Living Wage employer. As part of this commitment, the Group requires all current and potential suppliers (above the UK threshold) to pay employees the Living Wage rate. As part of the Group’s tender documentation organisations are also required to declare whether they pay employees the Living Wage, or whether they are prepared to work with the Group to increase pay to the correct Living Wage levels.
To ensure compliance with Living Wage requirements, suppliers are contacted on an annual basis to which they must state whether they continue to pay Living Wage. If not, the Group will work with the supplier and take the relevant actions.
As part of our attempts to build long term relationships with our suppliers, we seek to work with companies who share our values and who are prepared to commit themselves to meeting the requirements as set out above. As a result, the Group will assess any instances of non-compliance with the Act on a case-by-case basis and take the necessary course of action suitable to the individual case.
We play an active role in tackling modern slavery in our communities. During the course of their time with customers, employees can document suspected cases of modern slavery which are then reported through our partnership work with other community agencies and investigated further with the necessary action taken. Customers are also able to report any suspicions they may have regarding potential instances of modern slavery, these suspicions are also reported to partner agencies to investigate.
Work has been undertaken to build upon and enhance our central contracts register and framework, which ensures consistency across Livv and allows contracts to be managed and actioned accordingly. Controls, assurance activity and agreed actions are owned by the Executive Directors Team and are subject to Board and Audit and Risk Committee scrutiny.
A risk assessment has been completed which has considered the Group’s exposure to modern slavery as low risk. This is based on an assessment of; a range of controls and assurances in place to manage the risks; an assessment of the country and sector in which the Group operates and the transaction and business partnership arrangements the Group has in place. Controls include (but are not limited to):
- A comprehensive, principles-based procurement framework and underpinning policies and procedures.
- Identification of our supply chains and robust due diligence procedures.
- Awareness raising events held across the business.
- Compulsory training for all employees.
The Group has a Risk and Assurance Framework in place. The aim of the Framework is to achieve an optimum response to risk, prioritised in accordance with the evaluation of those risks. This includes how the extent and application of internal control frameworks support the effective management and mitigation of those risks and how assurance on the operation and effectiveness of internal control is obtained and reported at Management, Executive and Board level.
Training for employees
The Group raises awareness of modern slavery by incorporating a mandatory training course for all employees and Board members to complete as part of their induction, as well as continuing to raise awareness of modern slavery with employees through Livv’s Equality, Diversity & Inclusion (EDI) agenda.
We are currently reviewing our training and awareness raising provision, to ensure that this remains innovative and ensures that employees are well versed in identifying, recording and reporting any potential incidents of modern slavery.
Our procurement partners have facilitated a number of training sessions with contract owners across the business, in order to reaffirm and ensure a consistent approach when managing contracts throughout Livv.
Working with suppliers and contractors
The Group has a central register of contracts and a framework in place to rive consistency across all areas of the Group. As such, controls, assurance activity and agreed actions are owned by the Executive Directors Team and are subject to Board and Audit and Risk Committee scrutiny.
The Group will continue to work and communicate with its suppliers, partners and employees to ensure the robust processes in place are maintained and where possible enhanced. This is with the aim of ensuring that there are no instances of modern slavery or human trafficking that go unreported in our business, local community or the supply chain.
Over the next 12 months Livv will be undertaking a fundamental review of our training provision and approach to awareness raising.
This statement was approved by the Common Board on 22 July 2021.