Introduction
The Modern Slavery Act 2015 requires large companies with a turnover of over £36m, which supply goods, or services, to publish information each financial year to reflect the steps taken to ensure there is no slavery or human trafficking in their business or supply chains. We are committed to this and agree we all have a responsibility to be alert to the risks of slavery and human trafficking, however large or small, in our business or in our supply chains.
Organisation aims and structure
Lewisham Homes is an enterprising, not-for-profit organisation, set up to improve housing in the London Borough of Lewisham. As well as managing 18,000 homes on behalf of Lewisham Council, we operate our own maintenance company, build new homes and find valuable ways to invest in the local community.
Our Executive Management team is made up of our Chief Executive, Director of Resources, Director of Development and Investment, Director of Operations, Head of Corporate Services and Head of Governance.
Our Chief Executive reports to the Lewisham Homes Board. The Board sets our strategic direction and uses its expertise to assist in guidance and decision making. The Board takes a close interest in performance, finance and service improvement data.
We employ nearly 600 staff with a head office in Catford, south-east London.
Our mission is to deliver great housing services for thriving neighbourhoods. This mission is underpinned by four strategic objectives:
- Providing Excellent Services
- Developing Thriving Neighbourhoods
- Planning for a Sustainable Future
- Being an Employer of Choice
Due diligence processes for slavery and human trafficking
For Lewisham Homes
We require recruiting managers to use reputable employment agencies to source labour and verify the practices of any new agency we are using before accepting workers from that agency. This is reflected in our Recruitment Policy.
We are an accredited Living Wage employer, meaning that everyone working for us, or one of our contractors, is paid a minimum hourly wage of £10.20. This is the London allowance, and is significantly higher than the national minimum per hour for over 25s. We regularly review our terms of employment to ensure that they are fair, competitive and comply with relevant legislation.
Employees are provided with clear and transparent information about rates of pay, hours worked and legal deductions. We expect all employees to adhere to the Lewisham Homes’ Code of Conduct.
We ensure that we have systems in place and a whistle-blowing policy to encourage the reporting of concerns and the protection of whistle blowers.
Our safeguarding and anti-tenancy fraud policies and procedures enable us to take appropriate action if slavery or human trafficking is identified within our homes by us or by our customers. There is information and a link on our website and staff intranet for concerns to be reported.
Staff who are in contact with our residents and service users are trained to identify any safeguarding issues, which includes signs of exploitation, and to comply with the referral process to ensure that incidents of this nature are reported. We have a dedicated member of staff who then makes referrals and works with relevant agencies such as Local Authority Social Services and the Police.
Our supply chains
Our supply chains include the sourcing of products and services related to the development, maintenance and management of housing.
Our procurement activities take place in England and our contractors and suppliers are UK-based. We follow The European Union Procurement Directives which govern good practice in procurement.
Our robust tendering process is overseen by a dedicated procurement team who monitor compliance with our Contract Standing Orders and our Procurement Strategy and guidelines. This helps ensure we engage with reputable contractors who adhere to all appropriate legislation, regulation and practices. Our contract management arrangements help us ensure they maintain the standards required.
Our policies are reviewed periodically to ensure that they reflect best practice and to mitigate against risks.
Staff awareness
To ensure a high level of understanding of the risks in our supply chains and our business, we have reviewed our safeguarding and whistle-blowing policies to include reference to modern slavery issues. We are refreshing our safeguarding training so all relevant staff are aware of requirements, how to identify issues and where to report these. This is programmed for delivery in 2018.
Monitoring and review
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2018. It was approved by our board and will be reviewed annually as part of our statement of internal controls. The statement of internal controls is considered by the Audit Committee and approved by the Board annually.