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Modern Slavery Act 2015: Anti-Slavery & Human Trafficking Transparency Statement

This document constitutes Circle Housing Group’s statement on slavery and human trafficking under section 54 of the Modern Slavery Act 2015 for the financial year ending 31 March 2016 and has been prepared in line with guidance issued by the Home Office under the Act on preparation of such statements. This statement has been approved by the Board of Circle Anglia Limited and, where appropriate, adopted by the Boards of other companies within the Group.

The turnover of Circle Anglia Limited (the parent company of the Circle Housing Group) exceeds the £36 million turnover threshold set by the Act and the Modern Slavery Act (Transparency in Supply Chains) Regulations 2015 for the relevant financial year. Where a subsidiary organisation within the Group has met or exceeded the turnover threshold or may do so, this statement has been formally adopted by all such organisations and acts as their own statement for the purposes of section 54. For other organisations within the Group, this statement will be treated by them as a statement of best practice.

Our organisation, ethos and supply chain

Circle Housing Group is one of the United Kingdom’s largest providers of social and affordable housing. Our team of over 3,000 staff, supported by our contractors and suppliers, manage 70,000 homes and provide services for around 300,000 people across the UK, including general needs, sheltered and supported housing.

By operating with a business head and social heart, we help people in need and enhance their life chances by providing opportunities for affordable, independent and secure living; creating and supporting sustainable communities; and providing training, volunteering and other opportunities to our customers to help them develop their skills, abilities and resilience.

Circle Anglia Limited is the parent organisation within the Circle Housing Group which includes a range of partner organisations including nine Registered Providers and a number of commercial providers (more information is available here). We actively work with a supply chain which comprises a number of contractors who supply us with services, goods and works. In turn our contractors may and do source services, goods and works from sub-contractors subject to specific requirements and due diligence. Many of the services, goods and works we receive are therefore not directly sourced by us and we acknowledge the potential risks that this presents.

We are an ethical organisation and corporate responsibility is an integral part of our culture and vision. We actively work to ensure that we comply with all legal and regulatory requirements and in establishing and following best practice. We are also committed to treating those who work for us fairly – for example Circle Housing has been accredited by the Living Wage Foundation and we have committed to ensure that everyone working for Circle Housing, regardless of whether they are permanent employees or third-party contractors, will receive the Living Wage within the next three years. Many of our existing activities and initiatives also reflect our long-standing commitment to helping vulnerable people, including our core activity of providing affordable housing and our charity Alone in London which has been running since 1972 and supports 16-25 year olds in London who are homeless or at risk of homelessness.

Our approach

We therefore wholeheartedly welcome the introduction of the Modern Slavery Act 2015. This legislation is a crucially important development in combating and preventing the dreadful practices of slavery and human trafficking. We have no wish to trade with, support or work with any business or organisation which is involved in slavery or human trafficking in any way, however remotely or indirectly.

We have an extensive and robust framework of policies, procedures and contractual requirements in place which should already contribute towards the prevention of slavery or human trafficking within our organisations or our supply chains. These include, but are not limited to, areas such as housing management, risk management, safeguarding, health and safety, recruitment, whistleblowing, procurement, terms and conditions and codes of conduct for staff, suppliers and contractors, as well as stringent and extensive due diligence and checks when recruiting staff or engaging suppliers or contractors.

We have robust policies and procedures in place to prevent both the inappropriate allocation of its homes and the use of its premises by those engaging in Human Trafficking and Modern Slavery activities. Our local authority partners have a statutory duty to validate the rights of applicants to access social housing prior to nominating prospective tenants to us. Where we operate a housing register on behalf of the local authority, this duty is conveyed upon us and we take appropriate action to ensure we are compliant. Our allocations procedures seek to further reduce the opportunity for fraudulent occupation of our premises, by requiring photographic evidence of identity prior to entering into a tenancy contract.

Once a tenancy agreement is entered into, we carry out periodic reviews of all new lifetime tenancies and all fixed term tenancies and apply a risk based approach to reviewing other tenancies to ensure that our homes are used appropriately and lawfully. Our tenancy management policies provide staff with the guidance and means for investigating and instigating legal procedures for tenancy breach, including unlawful activity. We use all statutory powers available to us, in addition to working with appropriate statutory, voluntary and support agencies, to both minimise the opportunity for human trafficking and modern slavery in our homes and to address any incidence of such activity.

In terms of additional steps, we are already in the process of conducting a full scale review of our Human Resources policies and we will ensure that this review properly considers further specific steps which could be taken to prevent slavery and human trafficking.

We have also amended our standard terms and conditions to place a general obligation on suppliers of goods, works and services to comply with the Modern Slavery Act 2015 and this Statement. Failure to comply with the provisions will mean that the Circle Housing Group will be entitled to terminate a contract. In addition there is a contractual obligation on the supplier to self-audit, which is supported by a reserved right for Circle Housing Group to conduct its own audit. If any audit identifies any issues or failures that may increase the risk of slavery or human trafficking there is an obligation on suppliers to take appropriate actions to address these risks and issues. In order to manage the risk of slavery and human trafficking occurring in our supply chain we have added a flow down obligation that all sub-contractors comply with the Modern Slavery Act 2015 and added a requirement for suppliers to report on steps they have taken to ensure slavery and human trafficking is not taking place in any of their supply chains. For contracts including this obligation, the report must be supplied to Circle Housing Group by 1 February each year to ensure the detail is reflected in our annual transparency statement.

We are currently reviewing our procurement policy, process and procedures to incorporate the relevant due diligence checks we will conduct with suppliers before entering into the contract.

As part of the Group’s ongoing change programme we may also review or reconsider additional policies, procedures or requirements if appropriate to ensure there is no slavery or human trafficking taking place in our Group or in our supply chains.

This statement will be reviewed and updated as appropriate and at least annually.


Signature of Chair of Circle Housing Group



List of Organisations within Circle Housing Group who have adopted the above statement: