Coastal Housing Group Limited – Modern Slavery Statement
Coastal Housing Group is a charitable Community Benefit Society, registered as a social landlord with the Welsh Government. The Group comprises Coastal Housing Group Limited and its subsidiary Pennant Housing Association Limited.
The Group’s main activity is the provision of good quality, well managed social rented housing. We also have a number of properties let at intermediate rents. In addition, we build and acquire new housing for social rent and for sale and carry out regeneration activities.
We manage over 6,000 properties in the Swansea, Neath Port Talbot, Carmarthenshire and Bridgend local authority areas. We also specialise in urban housing-led regeneration projects, which includes provision of commercial space that helps the local economy prosper in the areas in which we operate.
We recognise that our operations could be susceptible to the risks of modern slavery and human trafficking, and we are committed to doing what we can to combat this. Our Modern Slavery Statement reflects our commitment to acting ethically and with integrity and having controls in place that seek to ensure that slavery is not taking place within our business or our supply chain.
We have assessed the risks in relation to modern slavery and human trafficking which fall into the following areas.
We have strict policies in place to ensure that all prospective employees prove their right to work in the UK before commencing employment. We also take up references in all cases. These checks apply to all forms of employment, whether temporary or permanent. Our compliance in this area is subject to routine internal audit.
Any agency workers are employed through reputable verified employment agencies.
In addition, where required, employment is also subject to satisfactory checks from the Disclosure and Barring Service.
The terms on which we employ staff are fair, and Coastal is committed to promoting equality, diversity, inclusion and dignity at work and in the services we provide.
We have a full suite of relevant people policies and a system for ensuring that policies are regularly reviewed and kept up to date. Policies are made available to all staff on our intranet site and attention is drawn to new or updated policies.
Our Safeguarding Policy specially refers (among other things) all forms of exploitation including modern slavery and human trafficking.
Our Whistleblowing Policy states that reporting circumstances that may give rise to enhanced risk of slavery or human trafficking is a protected disclosure.
Other relevant policies include Code of Conduct, Equality & Diversity, Commercial Management Policy, Anti-Money Laundering Policy and Anti-Fraud, Bribery & Corruption.
A number of our commercial lets are to large organisations including household names who will be bound by the requirement to produce a Modern Slavery Statement. We carry out credit checks on prospective commercial tenants and make other enquiries as required for smaller and newer businesses.
Our commercial properties are let under formal leases and we use external lawyers for the associated documentation. Our leases follow best practice and require the tenant to comply with all applicable legislation and (among other things) not to use the property for illegal or immoral purposes. The lease also requires our consent before it can be assigned or the property can be sublet to a third party.
The form of lease is based on the Law Society template and we will investigate the addition of specific reference to modern slavery and human trafficking. We will also share this Modern Slavery Statement with commercial tenants.
We understand the importance of ensuring that our supply chain is also committed to the same high standards that we are. Many of our suppliers are of a size where they are bound by the requirement to produce a Modern Slavery Statement.
Much of our maintenance work is carried out by our own in-house teams, subject to the same employment checks and requirements referred to above. Our development Employer Requirements refer to the Considerate Construction Scheme Modern Slavery and Human Trafficking Statement. We and our suppliers source materials from local reputable companies.
We undertake due diligence when considering new suppliers and will include a requirement to comply with the Modern Slavery Act in future tenders.
We provide specific training as appropriate to each team. We have recently rolled out our e-learning Learning Management System which allows us to track completion by individuals and includes built-in tests to ensure that the module has been properly understood. The Learning Management System will continue to be developed to include new material and cover more areas.
This statement has been approved by the Board and is made under section 54 (1) of the Modern Slavery Act 2015. It constitutes our slavery and human trafficking statement for the financial year ending 31 March 2023.
Debbie Green, Group Chief Executive
9 November 2023
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