Modern Slavery and Human Trafficking Statement

Salvation Army Homes Modern Slavery and Human Trafficking Statement

Salvation Army Homes is proud of the steps it takes to tackle modern slavery and human trafficking both in supply chains, and in the support we provide to people who have experienced or are at risk of homelessness. We are committed to improving our practices and procedures each year.

Salvation Army Homes understands it has a responsibility to take a robust approach to slavery and human trafficking and as such takes a zero-tolerance approach to slavery and human trafficking and expects all those in its supply chain and contractors to comply with its values.

In addition to its own Modern Slavery and Human Trafficking Statement, Salvation Army Homes also adheres to its parent company, The Salvation Army’s Modern Slavery Statement and relevant policies and practices.

Our Business and Organisational Structure

Salvation Army Housing Association (trading as Salvation Army Homes) is a Registered Provider founded in 1959 to provide supported housing. Originally established by The Salvation Army, the Association is an independent organisation that has grown into a diverse specialist provider of accommodation and support services across England.  

The Association is registered as a Community Benefit Society with charitable status under the Co-operative and Community Benefit Societies Act 2014 (registration no. 15210R) and is also registered with The Regulator of Social Housing(registration no. LH2429). It operates nationally in 79 local authorities across England and has four main business areas of operation; General Needs Accommodation, Older People’s services, Directly Managed Supported Housing services and Agency Managed services.  

Responsibilities

Salvation Army Homes is constantly identifying how modern slavery and human trafficking may affect our suppliers, contractors and customers. We work with a wide range of people who reflect a diverse variety of backgrounds and needs. Salvation Army Homes recognises that some individuals may be particularly vulnerable or at risk. Salvation Army Homes has an extensive and robust framework of policies, procedures and contractual requirements in place which contribute towards the prevention of slavery or human trafficking within our organisation and our supply chains. Effective implementation of these policies and procedures ensures we conduct business in an ethical and transparent manner. All policies are reviewed by the Executive and Senior Management Team and key policies are approved by the Board/Committee on a rolling basis in response to audit, statutory or regulatory changes and feedback from customers and partners.  

Procurement and Supply Chain

Salvation Army Homes is committed to ensuring there is no modern slavery or human trafficking in its supply chains or in any part of its business.  We manage projects and procurements where services and products are sourced from suppliers. Most of products are not sourced by us directly but are sourced by our contracted suppliers of services, goods and works. As an organisation that does not wish to work with any business knowingly involved in slavery or human trafficking in any part of its operations, we take the following steps:

· Require new suppliers to sign a declaration that they are not involved in slavery or human trafficking and have not been subject to any investigation in connection with any offence involving slavery or human trafficking

· Incorporate provisions in our contract and sub-contract documentation requiring suppliers to take appropriate steps to ensure there is no slavery or human trafficking in their supply chains

· Include within all tender documentation instructions that we expect all suppliers to comply with the Modern Slavery Act

· Work collaboratively with suppliers, identifying those procured goods/services which may carry the highest risk of modern slavery within their supply chain and confirming the steps taken to ensure there is no slavery or human trafficking in their supply chains

· A whistleblowing policy for all employees

Salvation Army Homes has robust procurement processes in place meaning it only engages with reputable suppliers and contractors who adhere to appropriate legislation, regulation and practices.

Recruitment

As an equal opportunities employer, Salvation Army Homes has clear recruitment procedures and processes including Right to Work checks for all permanent and interim employees. We ensure where agency workers are used, these are only sourced from reputable employment agencies. Using this approach, we seek to avoid inadvertently engaging those who present as looking for work for themselves, but who are ‘controlled’ by others. We also ensure that these partners apply good practices and processes including Right to Work checks. Salvation Army Homes has access to these records and carries out regular audits to ensure they are up-to-date and accurate.

· All new Salvation Army Homes employees receive induction training on equality and diversity which seeks to recognise and work with vulnerable people and children in our communities.

· Specialist training is provided for all front-line employees in safeguarding, domestic abuse and criminal and sexual exploitation, including identifying potential cases of modern slavery and human trafficking and how to report them.

· All hiring managers are required to complete the Safer Recruitment e-learning module.

Code of Conduct

All Salvation Army Homes managers and employees must adhere to a Code of Conduct which clearly sets out expected standards of behaviour. The Code requires employees to act with honesty, integrity, report misconduct and take responsibility for safeguarding.

Safeguarding

All employees are expected as a minimum to complete our mandatory safeguarding e-learning modules within the required timeframe. Further safeguarding training, including a detailed reflective practice workbook, is mandatory for all client-facing employees. We monitor training compliance via our People Services Team.

Investigations/Due Diligence

Members of the Senior Management Team are responsible for investigations and due diligence in relation to known or suspected instances of slavery or human trafficking.

Future Action

Salvation Army Homes will continue to take improve its procedures in relation to modern slavery to mitigate risk. We will continue to raise awareness and deliver training to new and existing employees and extend this to suppliers and contractors, where appropriate.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and sets out the steps that Salvation Army Homes has taken and continues to take to ensure that slavery and human trafficking is not taking place within the Association or its supply chain.

This statement has been approved by the Association’s Group Board.

Lynne Shea

Chief Executive

September 2024

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