Introduction
Modern Slavery is the illegal exploitation of people for personal or commercial gain. This serious criminal activity includes human trafficking, slavery, servitude, and forced or compulsory labour.
The Modern Slavery Act 2015, requires every business with a total of £36 million or more to publish a ‘slavery and human trafficking statement’ for each and every financial year of the organisation. This must outline what the organisation is doing to prevent and tackle modern slavery in its operations and supply chain.
Whilst Housing Rights falls outside the scope of the Act we believe as an employer, a service provider and a purchaser of goods and services that may use global supply chains, we have a role to play in tackling modern slavery and protecting vulnerable workers from exploitation. Therefore we want to ensure we follow good practice and provide this Modern Slavery Statement reflecting the steps Housing Rights will take to protect workers from exploitation and how to report on modern slavery incidents.
Housing Rights’ structure
The purpose of Housing Rights is to improve lives by tackling homelessness and housing problems in Northern Ireland. We do this through the provision of our free advice, advocacy and legal services; and in delivering a range of training courses on housing and welfare related issues.
Our expert advice and services are accessible via our website, telephone helpline and face-to-face offices in Belfast. This, in turn, informs the work of our policy team in trying to improve standards and practices in housing in Northern Ireland by making people aware of our client’s experiences. A good home is more than just somewhere to live. Having a good home improves relationships, increases feelings of health and wellbeing and helps to develop children’s educational opportunities. Good decent homes help to decrease crime rates and to develop communities and the economy.
Income generation:
- We aim to ensure sufficient levels of income are raised to deliver our charity’s purpose; and that
- Housing Rights appropriately manages both restricted and unrestricted income. Our income comes through diverse sources – government funding, contracts, and fundraising activity which has multiple channels.
Our policies and procedures are designed to ensure that ethical behaviour forms the basis of our ways of working. As part of our review of policies and procedures, we will update all relevant policies to include appropriate references to the risk of modern slavery. We also operate numerous risk controls to protect staff and clients’ personal information, and to ensure that our systems and services are not used to perpetrate or facilitate crime, including modern slavery.
We have around 50 staff and benefit from the time and dedication of volunteers. Housing Rights carries out appropriate pre-employment checks prior to commencement and staff complete mandatory training to ensure they understand and comply with our values along with our policies and procedures.
Steps to reduce modern slavery in our business and supply chain
Housing Rights will ensure the following key actions are taken in its’ attempt to eliminate the exploitation of people for personal or commercial gain within its business and supply chain:-
- Highlight our commitment: we will publish a Modern Slavery Statement on our website to demonstrate the steps we are taking to prevent modern slavery;
- Review our policies: Review our policies to adapt and ensure, where relevant, these address the elimination of modern slavery, and are clear on how to report on modern slavery incidents;
- Supplier conduct: we will share our Modern Slavery Statement with suppliers seeking assurances they also avoid labour exploitation and where such an assurance cannot be given we would not engage this supplier;
- Establish clear guidelines and procedures for all staff: we will communicate to staff on how they can report their concerns and whistleblow on modern slavery;
- Staff training: we will incorporate into our staff safeguarding training awareness of modern slavery and what to do if suspicion arises;
- Raise awareness of Modern Slavery: we will share our new Modern Slavery Statement with staff, volunteers and clients to raise awareness of modern slavery and what action to take if staff has concerns.
How to identify modern slavery and human trafficking
The nature of Housing Rights work may mean we come across individuals and/or clients who we suspect are being trafficked or enslaved for labour exploitation. The signs may vary from situation to situation, however, the following may indicate cases of modern slavery or human trafficking:-
General signs – individual being trafficked or enslaved may believe that they must work against their will, receive little or no payment and be unable to leave their work environment. Victims may show fear or anxiety and carry injuries that appear to be the result of an assault. They may not know their home or work address. They may not be in possession of their passport or other documents or they might always be accompanied by somebody else and not allowed to speak for themselves;
Children – children who have been trafficked may have no access to their parents or guardians, look intimidated and behave in a way that does not correspond with behaviour typical of a child their age. They will typically be engaged in work that is not suitable for children and travel unaccompanied by adults.
Labour exploitation – People who have been trafficked or enslaved for labour exploitation may live in groups in the same place where they work. They may leave those premises infrequently, if at all. They might not be dressed adequately for the work they do, have no labour contract, work excessively long hours, or lack basic training and professional licences. They might be subject to insults, abuse, threats or violence.
How to report a suspected modern slavery or human trafficking incident
Checking out
There may need to be some initial listening, expressing concern and “checking out” with a person who has disclosed information which may indicate labour exploitation.
It is important however that staff/volunteers understand the clear distinction between ‘checking out’ and an investigation. They should not begin to investigate alleged or suspected person/s who are being trafficked or enslaved for labour exploitation by asking questions that relate to the detail, or circumstances of the alleged incident.
There may be emergency situations where it is appropriate to contact the police immediately. But whatever the circumstances of the concern, disclosure, allegation or suspicion, it is vital that the staff member/volunteer records the details and reports to the Designated Officer (or a senior manager in absence of designated officer) without delay. All concerns, disclosures, allegations and suspicions must be recorded on “Modern Slavery: Record of Concerns Report Form” (see Appendix 1) within 24 hours. All records and information must be kept confidential and only disclosed to the Designated Officer.
Designated officers
To deal appropriately with modern slavery issues and to ensure that the confidentiality of all parties involved is maintained, 3 staff members from within Housing Rights have been assigned as Designated Officers (Head of Services & Support, and the Advice Services Managers).
Everyone in Housing Rights has responsibility to be aware of modern slavery issues however designated officers have additional responsibilities for monitoring any modern slavery incidents and for reporting any allegations of modern slavery (see below).
Staff members or volunteers that cannot reach any of the Designated Officers should speak directly to another available manager. In exceptional cases and where there is immediate risk to a person or persons, staff should contact the PSNI directly.
Where the Designated Officer (or staff member in an emergency situation) suspects that someone has been trafficked or enslaved:-
- call 999 in case of an emergency
- call 101 about the general situation
- call 0800 0121 700 for the Modern Day Slavery Helpline or report modern day slavery online at www.modernslaveryhelpline.org/report
Development and Review of Policies
Housing Rights have a comprehensive set of policies and procedures which are accessible to all staff and volunteers via the organisation’s intranet (Teams). These policies include:-
- recruitment
- safeguarding
- finance (Procurement)
- whistleblowing
- code of conduct
We shall ensure the policies include:-
- how safeguarding incidents are reported to the relevant authority and to the Housing Rights Audit & Risk Committee, including any incidents of modern slavery;
- ensuring all suppliers are made aware of our Modern Slavery Statement and that we will seek assurances they also avoid labour exploitation;
- pre-employment checking.