This statement is made pursuant to s.54 (1) of the Modern Slavery Act 2015 and constitutes Cross Keys Homes (CKH) Slavery and Human Trafficking Statement for the financial year ending 31 March 2023. This statement sets out steps CKH and its subsidiaries have taken, and continue to take, to ensure that modern slavery and/or human trafficking is not taking place within our business or supply chain.

 

Organisational Structure

Cross Keys Homes Limited is a private registered provider, established in 2004 when tenants voted in favour of a proposal to transfer homes previously owned by Peterborough City Council (PCC).  Despite selling stock to tenants through Right to Buy and Right to Acquire, CKH has continued to develop new homes with a target of 500 for 2022/23.  CKH owns and manages over 12,000 homes in 11 local authority areas in the east of England.  Cross Keys Homes Limited is a registered charitable Community Benefit Society Parent, with four subsidiaries: CKH Developments Ltd, Cambridgeshire Homes LLP, Cross Keys Properties Ltd and Cambridgeshire Housing Capital Plc.

CKH provides general needs homes, retirement living and housing, and extra care homes, community care and short stay/temporary housing, as well as affordable and shared ownership housing. CKH provides leaseholder services, rents community-based shops, emergency alarm service (LifeLine) for our residents and private clients. CKH reinvests surplus income into our communities, services and business growth. 

 

Compliance

Responsibility for compliance with the Modern Slavery Act 2015, rests with the CKH Group Board. CKH seeks to ensure compliance through a range of due diligence processes to meet our obligations ensuring homes and properties are let to bona fide individuals and companies and no activities, which may be connected with modern slavery, is undertaken within our properties.

Our supply chain consists mainly of services rather than goods, with the highest risk areas identified as being associated with our building and rental activities.  We are committed to ensuring that there are no modern slavery or human trafficking in our supply chains, or in any part of our business, and where possible actively seek government approved suppliers. Our corporate policies reflect our commitment to ethical business practices, and all employees performing their business with integrity. We are proactive in investigating all reports of suspected activity, which may involve modern slavery. All homes where illegal activity or fraudulent tenancies are suspected are investigated. CKH works closely with other agencies to ensure that it has intelligence on criminal activities or potential abuse.

 

Procurement

We are committed to Value for Money principles that do not compromise our legal compliance or ethical standards, and we have zero tolerance to slavery and human trafficking.

CKH uses a wide range of firms within our supply chain. CKH currently requires all suppliers to make a declaration that they comply with our Equality and Diversity Strategy, which includes non-discrimination in employment, and we are proactive in seeking clarification of the controls in place with higher risk suppliers, such as contractors and sub-contractors, to mitigate the risk of modern slavery or people trafficking within our supply chains.

We also require each supplier to make a declaration that they have systems in place to detect and prevent human trafficking or slavery in their business and/or we use government-approved suppliers.  Our standard terms and conditions of purchase and contract templates include modern slavery clauses. Our supply chain is overwhelmingly based in the UK.

An assessment of our current supply chain saw all aged suppliers contacted and confirmation obtained that they have their own modern slavery/human trafficking policies in place and/or they were prepared to adopt and uphold the policies of CKH as their own.  The contracts register was reviewed within the year and a programme to update all contracts due for review has begun.

 

Risk Assessment

We have undertaken risk assessments to identify key areas of risk and have procedures in place to mitigate these risks:

• All employees, whether permanent or temporary, are subject to appropriate checks on recruitment, including DBS checks, as necessary, and proof of eligibility to work in the United Kingdom.
• Specific training is given to front-line staff who may identify evidence of modern slavery or human trafficking in the community.
• All staff are regularly kept up to date through the corporate intranet and appropriate briefing notes.
• Screening suppliers and contractors to ensure they comply with legal requirements and have their own Modern Slavery Statement in place.

 

Reporting

CKH has robust internal procedures and guidance (through our Whistleblowing Policy) for employees, Resident Board and Group Board members to report any suspected breaches of the Modern Slavery Act 2015.

Members of the public can report suspected breaches by contacting CKH customer services and/or report and get advice and guidance from Modern Slavery Helpline: 0800 0121 700 / The Modern Slavery Website – or go to the National Crime Agency Website (NCA)