Anti-slavery declaration

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 2026. 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 1000 by 2027. CKH owns and manages over 13,000 homes in 12 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 schemes, 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, are carried out within our properties.

We are committed to preventing modern slavery and human trafficking within our organisation and across our supply chains, in line with the Modern Slavery Act 2015. Our supply chain consists predominantly of service providers rather than goods, with the highest risk areas identified in connection with our building, maintenance and rental activities. We are committed to ensuring that modern slavery and human trafficking do not occur within our supply chains or any part of our business and, where possible, we seek to appoint government-approved suppliers.

Our corporate policies reflect our commitment to ethical business practices, and all employees are expected to conduct their work with integrity. We take a proactive approach to investigating all reports of suspected activity that may be linked to modern slavery. All homes where illegal activity or fraudulent tenancies are suspected are investigated, and CKH works closely with partner agencies to ensure effective intelligence-sharing on criminal activity and potential abuse.

Procurement

We are committed to Value for Money principles that do not compromise our legal compliance or ethical standards. Value for money is not defined solely by cost, but by achieving the optimal balance of quality, whole-life cost, risk, sustainability and social value, in line with applicable public procurement legislation and CKH's internal governance framework.

 All procurement activity is conducted in accordance with the Public Contracts Regulations 2015 and the Procurement Act 2023, where applicable, and is supported by clear internal policies, procedures and approval controls. These ensure transparency, proportionality, equal treatment of suppliers and robust audit trails, while preventing inappropriate cost-driven decision-making that could increase ethical or legal risk.

 

CKH maintains a zero-tolerance approach to modern slavery and human trafficking. Ethical considerations are embedded throughout the procurement lifecycle, from pre-procurement planning and supplier selection through to contract award and ongoing contract management. Suppliers are required to demonstrate compliance with the Modern Slavery Act 2015, confirm the steps they take to prevent slavery and human trafficking within their own operations and supply chains, and adhere to CKH's contractual and ethical standards.

 

Procurement processes include proportionate due diligence, risk assessment and supplier checks, particularly for higher-risk sectors and services. Contracts include appropriate terms and conditions allowing CKH to monitor compliance, address concerns, and act where standards are not met.

 

By integrating value for money principles with strong governance, ethical due diligence and ongoing contract oversight, CKH ensures that commercial decisions support lawful, responsible and socially responsible outcomes, while safeguarding against modern slavery and human trafficking across its supply chains.

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 Equity, Diversity and Inclusion 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 existing 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. A contracts management software package has been purchased during the year to help improve the monitoring and review of contracts.

Risk Assessment

We have carried out risk assessments to identify key areas of risk and have procedures in place to mitigate any that emerge:

• 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 about the policy through the corporate intranet and appropriate briefing notes.
•  Screening of all 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, including its Whistleblowing Policy, which enable employees, Resident Experience Panel members and Group Board members to report any suspected breaches of the Modern Slavery Act 2015. 

Employees who enter residents' properties, such as Project Surveyors and Neighbourhood Managers, are required to complete Human Trafficking Awareness Training and Certification (ACAMS). This training covers the different types of exploitation, factors that increase vulnerability to victimisation, the local context, available support networks, and the key indicators to identify, together with guidance on how to respond appropriately.

All employees are supported by comprehensive internal guidance designed to help them identify and respond to potential concerns that may arise in the course of their work. This guidance outlines expected standards of conduct and the appropriate steps to take where issues are identified or suspected. Employees are required to familiarise themselves with this guidance and to report any concerns promptly in line with internal policies and procedures.

All concerns are treated seriously and investigated appropriately. Individuals are encouraged to raise concerns in good faith and may do so without fear of retaliation.

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). 

Approval 

This statement was approved by the Board on 23 March 2026 and signed on its behalf by Chair, Shelagh Grant.