Anti-Slavery Declaration 2019/20

This statement is made pursuant to S54 of the Modern Slavery Act 2015, and sets out steps Cross Keys Homes (CKH) and its subsidiaries have taken, and continue to take, to ensure that modern slavery 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 grow and develop new homes and had completed 248 new homes in the year to December 2018.  CKH now owns and manages 11,346 homes in eleven local authority areas.  The CKH consists of Cross Keys Homes Limited, as the registered Community Benefit Society Parent, and four subsidiaries.

CKH provides general needs homes, sheltered, and extra care homes, as well as shared ownership housing. CKH provides leaseholder services, rents community based shops, emergency alarm service, LifeLine, for our residents and private clients and provides community care. 

 

Compliance

Responsibility for compliance with the Modern Slavery Act rests at the highest level within the business. CKH seeks to ensure compliance through due diligence processes to meet the obligations under the Modern Slavery Act 2015 by ensuring that its homes and properties are let to bona fide individuals and companies, and that no activities which may be connected with modern slavery are undertaken within our properties.

Our supply chain consists mainly of services rather than goods, with the highest risk areas 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. Our corporate policies reflect our commitment to ethical business practices, and all employees performing their business with integrity.

 

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 protect against modern slavery or people trafficking.

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.  We do not have any supply chains outside of the United Kingdom.

During 2018/19 CKH actively contacted all aged suppliers and obtained confirmation that they have their own modern slavery policies in place and/or they were prepared to adopt the policies of CKH as their own. 

 

Risk Assessment

We have undertaken risk assessments to identify key areas or 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 contact CKH customer services and/or report and get advice and guidance from Modern Slavery Helpline 0800 0121 700.

The Modern Slavery Helpline 

National Crime Agency (NCA)