Modern Slavery Act Transparency Statement 2023
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.
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 relevant to Modern Slavery
Our relevant policies set out our approach to identifying and tackling modern slavery activity, these include:
- Procurement Policy - procurement-related activity must comply with applicable legislation, including UK law, legal precedents, and relevant industry regulations.
- Employee & Director Codes of Conduct - high standards of probity and ethical behaviour are clearly set out for Board Directors and colleagues.
Confidential Reporting (Whistleblowing) Policy - confidential communication and reporting arrangements are in place 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 and checks in place to ensure compliance with legislation and guidance for both permanent staff and temporary agency workers.
Safeguarding policy - we ensure colleagues are aware of how to identify and report potential instances of slavery and human trafficking within our housing stock and local communities.
Due Diligence Relevant to Modern Slavery
Magenta Living has due diligence processes in place across our employment and procurement processes.
Our employment practices include:
Requiring new employees to produce original documentation evidencing their right to work in the UK prior to commencement of employment. In addition, internal quality checks are completed twice per year.
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 Modern Slavery Act 2015 (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 to achieve compliance.
- Confirm that they, their organisation, subcontractors, and 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 reject the tender.
We ensure that, should it be necessary, we will terminate contracts if a provider or subcontractor is found to have committed an offence of slavery or human trafficking and reserve the right to terminate contracts should they breach relevant environmental, social or labour Laws.
Where possible, we tackle modern slavery in our communities – customers can 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 appropriate action.
The nature of services procured by Magenta mean our exposure to risk of slavery is low within the organisation. However, we are confident that the processes and actions we currently have in place including our procurement framework, risk and assurance framework, policies and procedures, due diligence processes, business operation controls and skills and behaviours of suitably trained staff ensure we can reduce the opportunities for slavery to arise and identify and appropriately address instances of actual slavery, particularly with our properties and the communities in which we operate.
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.
Our Internal Audit and Business Assurance Plans provide operational oversight across the business, the results are scrutinised by Magenta’s Audit and Risk Committee.
- Our procurement framework and management of contractors procedures were reviewed by Magenta’s internal audit in September 2021. No negative findings or additional
- recommendations were identified in respect of Magenta’s modern slavery and human trafficking processes.
- Our internal audit team reviewed our regulatory compliance framework in February 2022. There were no significant findings relevant to Modern Slavery and Human Trafficking.
During the next financial year, we will:
- Review policies coming up for renewal to ensure they reflect our commitment to the Modern Slavery Act 2015.
- Ensure the Magenta Board and Senior Managers continue to take responsibility for implementation of this Statement and its objectives and ensure there are adequate resources to ensure modern slavery and 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 appropriate risk mitigations.
- Our Internal Audit function will identify appropriate opportunities to scrutinise how Magenta addresses its Modern Slavery obligations throughout the progression of our annual internal audit plan.
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 2023.
It was approved by the Magenta Living Board on 18 May 2023.