This statement on slavery and human trafficking is made pursuant to Section 54 of the Modern Slavery Act 2015.
It is made on behalf of Wheatley Group and its subsidiaries, The Glasgow Housing Association Limited and Dunedin Canmore Housing Limited, both of which had an annual turnover in excess of £36m at the end of their last financial year.
It will be updated on an annual basis and approved by the Board of Wheatley Housing Group Limited.
Information about Wheatley Group
Wheatley is Scotland's leading housing, care and property-management group and employ over 2,000 people.
Dunedin Canmore Housing Limited and Glasgow Housing Association Limited are both subsidiaries of the Wheatley Housing Group Limited, Registered Social Landlords and registered charities. Their principal business is housing.
We are committed to the highest ethical standards of business and ensuring there is no slavery or human trafficking in any part of our business or supply chain. Each entity in our group complies with applicable human resources legislation and the national minimum wage.
Our supply chain, due diligence and risk
We are committed to developing the economies of the areas we work in and building strong relationships with local suppliers.
We operate solely within Scotland and do not have a large global supply chain. Our procurement is subject undertaken within the context of a wide range of legislative and regulatory requirements, including procurement the Public Contracts (Scotland) Regulations 2015, The Procurement (Scotland) Regulations 2016, Procurement Reform (Scotland) Act 2014 and the Housing (Scotland) Act 2001.
A contracts register is published on the Wheatley website which contains details of our main suppliers.
We have a specialist procurement function that has primary responsibility for procuring goods and services on a group-wide basis in accordance with the aforementioned legislation and regulation. High value contracts require approval by the Board. We encourage our suppliers to sign up to our Wheatley Pledge.
We have assessed our risk of exposure to slavery and human trafficking as low.
Some of the recent measures that we have taken, or are in the process of taking, include:
- review of our standard contract terms and introduction of a provision that requires suppliers to comply with the Modern Slavery Act 2015;
- review of our procurement policy and strategy;
- refresh our Fraud, Corruption and Bribery Policy;
- refreshing training for staff; and
- requiring a formal declaration from suppliers that they comply with the Modern Slavery Act 2015.
We will ensure relevant sections of our workforce understand the risk to our business from slavery and human trafficking and are equipped to identify and respond in situations where they suspect bad practice. We have a policy framework in place to support our staff identifying vulnerable people.
We will assess any evidence of non-compliance within any part of the Group or by one of our suppliers and take appropriate action.
We operate the following policies, each of which is designed to support legal compliance and best practice:
- Recruitment Policy
- Employee Code of Conduct
- Procurement Policy
- Whistleblowing Policy
- Anti-fraud, Bribery and Corruption Policy
- Scheme of Financial Delegation
- Group Protecting People Policy Framework.
The statement was approved by the Board of Wheatley Housing Group on 27 February 2019.