1 The Modern Slavery Act 2015 includes a provision for transparency in supply chains that requires all businesses with a turnover in excess of £36m to provide disclosure concerning their efforts, if any, to address the issues of slavery and human trafficking. The disclosures are intended to provide TCH’s stakeholders with information to make informed choices about their dealings with the Company.
2 TCH and its Subsidiaries are committed to maintaining and improving systems and processes to avoid complicity in human rights violations related to its own operations and that of its supply chain. TCH recognises that slavery and human trafficking can occur in many forms. Therefore, throughout this disclosure we use the terms “slavery and human trafficking” to encompass various forms of coerced labour.
3 TCH verifies, evaluates and addresses any risks of slavery and human trafficking in its supply chain, if identified. The first step is to set clear expectations for our suppliers. Our Contractor Code of Conduct has been updated and states, “We do not tolerate forced, debt bonded, indentured labour practices or human trafficking. TCH does not allow harsh or inhumane treatment, including corporal punishment or the threat of corporal punishment. We expect our suppliers and others to meet these expectations”. Our Code on Conduct also provides that “forced, bonded (including debt bondage) or indentured labour, involuntary prison labour, slavery or trafficking of persons shall not be used”.
4 We are committed to implementing our updated Code of Conduct across our supply chain and contractors are advised of our requirement for them to comply with TCH’s position. TCH’s Statement is included in our tendering documentation and potential contractors are obliged to confirm that they adhere to TCH’s position regarding slavery and human trafficking. TCH uses this information to determine the risk profile of suppliers for environmental, safety, human rights (including slavery and human trafficking).
5 We do not knowingly support or deal with any business involved in slavery or human trafficking.
6 Recruitment, communication and training
6.1 TCH’s Board and Executive Management Team (EMT) set the tone of our ethical culture for the organisation. The Board holds management accountable for communicating ethics and compliance expectations. Each year EMT communicates to employees and senior managers regarding the importance of ethics and legal compliance. We believe that this “message from the top”, along with ethics and compliance training and other communication throughout the year, helps to create an ethical and legally compliant culture within the business.
6.2 Our recruitment processes are transparent and reviewed regularly. We communicate directly with candidates to discuss job opportunities and to confirm details of any offer made. We have robust procedures in place for vetting new employees and ensure that we are able to confirm their identities. All of our employees are treated fairly and equally.
6.3 Our training emphasises that through our Staff and Board Member Codes of Conduct (which contain specific information on TCH’s position against slavery and human trafficking), we seek to promote honest and ethical conduct, deter wrongdoing and support compliance with applicable laws and regulations. The principles embodied in our Staff and Board Member Codes of Conduct reflect our stance relating to, but not limited to, slavery, human trafficking, conflicts of interest, non-discrimination, anti-trust, anti-bribery, and anti-corruption and protecting our company’s reputation.
6.4 Our policies and guidance are clearly defined and communicated to all of our employees.
6.5 TCH also has zero tolerance of any threat of physical or sexual violence, harassment and intimidation against employees and Board Members and their families, or close associates.
7 We encourage anyone (including Board Members, employees, sub-contractors, suppliers and clients) to report in good faith any issues or concerns about potential ethics, human rights, legal or regulatory violations, including improper or unethical business practices such as fraud or bribery. Any person making such reports would be covered by TCH’s Whistleblowing Policy.
This statement, which has been approved by our Board, is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes TCH’s slavery and human trafficking statement for 2020.
Date: 28 January 2021
On behalf of the Board of Town and Country Housing
Related Website Pages and Policies:
• Equality and Diversity
• Safeguarding for Adults at Risk and Children
• Health & Safety
• Contractors’ Charter
• Supplier Terms and Conditions