Anti-slavery and human trafficking statement

Watford Community Housing is a charitable, registered housing provider and parent of the Watford Community Housing Group. As well as being a charitable housing provider, Watford Community Housing  is a ‘community gateway’ association, whose 6,000-plus tenants have an active role in the organisation’s affairs. The Group has approximately 200 employees and operates in the UK. Watford Community Housing  has an annual turnover of £33.5m (as at March 2020).

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business and operate a zero-tolerance policy on these practices. We procure goods and services in accordance with EU and UK legislation. This Policy reflects our commitment to acting ethically and with integrity in all our business relationships and implementing and enforcing effective systems and controls to ensure slavery or human trafficking is not taking place anywhere in our supply chains.

We expect our contractors and suppliers to mirror our zero-tolerance approach to modern slavery and human trafficking, complying with all applicable law and legislation in this area to protect the rights and freedoms of people. This includes prohibitions on slavery, people trafficking, forced labour, employment rights, health and safety protections and environmental legislation.

We will carry out due diligence on new contractors and suppliers to assess their awareness of and compliance with the Modern Slavery Act. We will annually review the position of the Group’s largest suppliers to ensure they have a clear, published modern slavery and human trafficking statement. They will also be asked to confirm that they comply with relevant legislation in this area including but not limited to slavery, forced labour, human trafficking, immigration, health and safety and the environment.

We may ask contractors to carry out, or agree to, audits of their own key suppliers where we have suspicions that there may be non-compliance with the above legislation within any part of the supply chain. We may also remove contractors from our supply chain in these circumstances.

Watford Community Housing requires all new contractors and suppliers to confirm to Watford Community Housing in writing as part of any new competitive tender / procurement process or non-competitive selection process that they comply with these provisions.

All staff were required to undergo a mandatory e-Learning training course on modern slavery between January and March 2019 which will be repeated regularly.

We have additional policies to support the identification of modern slavery risks, as follows : -

1. Whistleblowing policy: for staff to raise any concerns about our supply chain without fear of reprisals;
2. Recruitment and selection policy: contains controls around applicant background and right to work checks; and
3. Procurement - as part of our annual contract register/supplier monitoring we ask suppliers to confirm their adherence to the Modern Slavery Act 2015.

The statement at this section 4 is made pursuant to s54(1) of the Modern Slavery Act 2015 and constitutes our Group slavery and human trafficking statement for the financial year ending 2019/20.