Slavery and human trafficking statement

 

Our commitment to combatting slavery and human trafficking is rooted in our deeply held values and core social purpose. We play our part by managing our residents’ homes and services, our business and suppliers and working with our partners in a way which helps to expose and eliminate this abhorrent and unlawful practice.

 

Introduction

We are fully committed to combatting slavery and human trafficking and are committed to ensuring transparency of our supply chains.

In this document,  we outline the steps we have taken to target Modern Slavery for the 2018/19 financial year ending 31 March 2019, which covers the period 01 April 2018 to 31 March 2019, and the further actions we will take in the new financial year. We will continue to examine the effectiveness of our approach, to ensure continuous improvement.

We have a responsibility to be alert to the risks of slavery and human trafficking in our business and in the wider supply chain and staff are expected to report concerns and management are expected to act upon them.

 

Organisational structure

Origin Housing Ltd is an exempt charity, a Registered Provider of Social Housing (registered in England), principally involved in the provision of quality affordable homes and effective management services to meet the needs of residents and build sustainable communities.

The Origin Group consists of two registered providers (Origin Housing Limited and Origin Housing 2 Limited) and four active companies (Origin Properties Limited, Origin Housing Developments Limited, Origin Finance Limited and Origin Finance 2 plc). Origin Housing Limited is the parent company of the Group and a charitable registered provider regulated by the Regulator of Social Housing (RSH).

Origin Housing Ltd was formed in April 2010. It is an amalgamation of companies whose origins go back to the 1920s. St Pancras Housing Association merged with Humanist Housing Association in 1999 to form St Pancras and Humanist Housing Association Ltd (SPH). In 2004, Origin Housing Group was set up when Griffin Homes joined. 

Origin is a diverse and dynamic business that own and manages over 6,600 homes in London and Hertfordshire.

 

Provision of Housing

As a major housing provider, we have vetting processes in place which monitor the people we house, as well as ensuring, through our tenancy audits, that our properties are not used for the purposes of trafficking or allowing modern slavery.

 

Our supply chains

Our supply chains include goods and services for the construction, repair and maintenance of residential homes.

We also purchase goods and services to facilitate the running of our business and our office premises. As we are based in and operate solely within the UK, we have identified that our overall exposure to the risk of slavery and human trafficking is quite low. However, within our business, particular attention is paid to construction contracts and the use of sub-contracted labour.

We already take action to ensure that we are compliant with employment law, and many of our contractors and suppliers are in the UK, and are also required to follow UK employment law.

We are committed to ensuring that there is no modern slavery in our supply chains or in any part of our organisation and as part of our initiative to identify and mitigate risk, we have reviewed our systems and controls and will be making improvements. These include:

  • Referring to our Code of Conduct for Partner Organisations which includes a section on modern slavery activities. By tendering, potential contractors and suppliers are agreeing to adhere to the Code.
  • Reviewing the terms and conditions of new contracts to make more explicit reference to modern slavery.

We expect those in our supply chain and contractors to comply with our values and legislation. The executive team and senior management group are responsible for compliance in their respective departments and for their supplier relationships.

During 2019/20 we will ensure that all reviews of contract management and performance include consideration of the Modern Slavery Act as well as provide refresher training.

 

Training

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and in our business, we provide training to relevant members of staff.

 

Our effectiveness in combatting slavery and human trafficking

We use the following methods to demonstrate that we are checking slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Completion of tenancy and estate audits;
  • Use of labour monitoring and payroll systems;
  • Ensure all suppliers comply to our supplier code of conduct;
  • Good level of communication and personal contact with next link in the supply chain and their understanding of, and compliance with, our expectations.

Non compliance

We only trade with those who comply with our policy on Modern Slavery. We will assess any instances of non-compliance, take appropriate action and report these to the Board. However, in this financial year, there were no instances of non-compliance.

We have a whistleblowing policy in place, which ensures full protection (and anonymity) of staff, should  they raise a concern.

 

This Statement is made under section 54(1) of the Modern Slavery Act 2015. It was approved by Origin's Board on 04 September 2019 and applies to all companies within the Origin Group.

 

Last updated: 30 September 2019