This statement on slavery and human trafficking is made pursuant to section 54 of the Modern Slavery Act 2015.
It is made on behalf of Wheatley Group and its subsidiary, The Glasgow Housing Association Limited, both of which have an annual turnover in excess of £36million.
Information about Wheatley Group
Our Group has a turnover in excess of £36million and employs over 2,000 people.
For further information about Wheatley, click on Group structure.
We are committed to the highest ethical standards of business and ensuring there is no slavery or human trafficking in any part of our business or supply chain. Each entity in our Group complies with applicable human resources legislation and the national minimum wage.
Our supply chain, due diligence and risk
We are committed to developing the economies of the areas we work in and build strong relationships with local suppliers.
We operate solely within Scotland and do not have a large global supply chain.
A contracts register is maintained on the Wheatley Group website which contains details of our main suppliers.
We have a specialist procurement function that has primary responsibility for procuring goods and services on a Group-wide basis.
Our procurement is carried out in accordance with applicable procurement regulations and is overseen by the Group Audit Committee. High value contracts require approval by the Board.
We encourage our suppliers to sign up to the Wheatley Pledge as well as, where appropriate, incorporate community benefits clauses into our contracts.
We have assessed our risk of exposure to slavery and human trafficking as low.
Some of the recent measures that we have taken, or are in the process of taking, include:
- a review of our Group Procurement Policy and Strategy
- a review of our standard contract terms and introduction of a provision that requires suppliers to comply with the Modern Slavery Act 2015.
- Updating our Whistleblowing and Anti-fraud, Bribery and Corruption Policies to specifically include slavery and human trafficking.
We will ensure that relevant sections of our workforce understand the risk to our business from slavery and human trafficking and are equipped to identify and respond in situations where they suspect bad practice.
We operate the following policies, each of which is designed to support legal compliance and best practice:
- Recruitment Policy
- Employee Code of Conduct
- Group Procurement Policy
- Group Whistleblowing Policy
- Group Anti-fraud, Bribery and Corruption Policy
- Group Scheme of Financial Delegation.
This statement was approved by the Board of Wheatley Housing Group on 31 August 2016.