Modern Slavery Act Transparency Statement 2021

Structure and Supply Chains

Magenta Living is a housing association and is the largest provider of affordable housing in Wirral with around 13,000 homes.  Magenta Living is a socially responsible, not-for-profit registered charity and is registered with the Regulator of Social Housing.

Magenta Living’s Vision is Vibrant … homes, lives, neighbourhoods.

 

Board structure

 

We have a diverse supply chain providing a range of goods and services including property contractors, office supplies and corporate services.  We expect our contractors, suppliers and business partners to share the same high standards regarding our zero-tolerance commitment to tackling modern slavery and human trafficking.  We will not knowingly trade with, support or work with organisations involved in slavery or human trafficking in any way.


Policies relating to Modern Slavery

Our policies set out our approach to identifying and tackling modern slavery activity:

  • Procurement Policy - procurement-related activity must comply with applicable legislation, including UK law, legal precedents, and relevant industry regulations
  • Probity Policy – high standards of probity and ethical behaviour are clearly set out for Board Directors and colleagues
  • Whistleblowing Policy - confidential arrangements to encourage staff to report concerns / wrongdoing
  • Recruitment and Selection Policy – we use reputable employment agencies and review agency practices prior to working with companies. There are transparent procedures in place and checks to ensure compliance with legislation and guidance for both permanent staff and temporary agency workers.


Due Diligence

Magenta Living has due diligence processes in place across our employment and procurement processes.

Our employment practices include:

  • requiring new employees to produce original document evidence of a right to work in the UK on commencement of employment
  • recognising two trade unions and supporting their involvement in respect of employee rights
  • compliance with both national minimum and national living wage requirements

In line with requirements of the Crown Commercial Services and Public Contract Regulations 2015, our tender documentation includes criteria requiring potential suppliers to:

  • confirm that they comply with the Act (if they meet the statutory thresholds) and where applicable are compliant with the annual reporting requirements contained within Section 54 of the Act. We ask for the URL link to where their modern slavery statement is located, so this can be verified. If they are currently non-compliant, they must set out what reasonable measures they intend to implement in order to achieve compliance
  • confirm that they / their organisation / subcontractors / members of their supply chain have not been convicted of any offence involving slavery or human trafficking; if they do not provide this confirmation, we reserve the right to reject the tender

In addition to the above, where possible, we tackle modern slavery in our communities – customers are able to report any suspicions they may have 24/7 regarding a potential instance of modern slavery. Reports would be directed to the police for investigation where appropriate.

We will assess any instances of non-compliance with the Act on a case by case basis and take an appropriate course of action.


Risk Assessment

In terms of the services procured by us, our exposure to risk is relatively low risk.  Potential risks are mitigated by our procurement framework, risk and assurance framework, policies and procedures, due diligence processes, business operation controls and skills and behaviours of suitably trained staff.


Measuring Effectiveness

Training

Colleagues and Board Directors receive an induction on appointment and sign up to a Code of Conduct, all of which includes references to key policies and procedures.  There is a mandatory procurement induction for all colleagues which specifically covers the procurement policy and procedures.

Business Operations

The Internal Audit Plan includes a wide range of operations across the business which are scrutinised by the Group Audit and Risk Committee and reviewed by the Board.

Future Plans

During the next financial year, we will:

  • conduct a review of the procurement framework and management of contractors via our internal audit programme
  • conduct a review of Construction (Design and Management) Regulations 2015 compliance framework via our internal audit programme
  • conduct a review of the regulatory compliance framework via our internal audit programme
  • Policies coming up for renewal / new policies will be reviewed to ensure they reflect our commitment to the Modern Slaver Act 2015
  • The Board / Senior Managers will continue to take responsibility for implementation of this Statement and its objectives and ensure there are adequate resources to ensure slavery / human trafficking is not taking place within the organisation or its supply chains
  • We will continue to work with colleagues, suppliers and partners to ensure we maintain risk mitigations currently in place

This Statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes Magenta Living’s Modern Slavery Act Statement for the financial year ending 31 March 2021.

It was approved by the Board on 25 May 2021