HIGHTOWN HOUSING ASSOCIATION LIMITED modern slavery statement summary (2022)

Organisation address

Hightown House, Maylands Avenue,
Hemel Hempstead,
Hertfordshire,
United Kingdom,
HP2 4XH

We asked the organisation a series of questions about its modern slavery statement. Its answers are published on this page as a statement summary.

This statement provides information for 5 of 6 recommended areas

What is a modern slavery statement?

UK law requires certain organisations to publish an annual modern slavery statement on their website, setting out the steps they are taking to address modern slavery risks in their operations and supply chains. Read more in the government guidance on publishing modern slavery statements.

Link to full statement

Go to full modern slavery statement on organisation’s website

PDF version of the statement (optional)

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Hightown Housing Association Modern Slavery Statement 2022.pdf

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About this statement summary

All answers relate to the financial year covered by the statement. The organisation is responsible for all the information it provided. Some of our questions are optional, so organisations may not have answered all of them. The statement summary does not replace the full modern slavery statement – below we provide a link to the full statement on the organisation’s website.

Contents

Legal requirement to publish
Statement period and sign-off details
Recommended areas covered by the statement
The organisation’s sectors and turnover
Number of years producing statements
Policies
Training
Monitoring working conditions
Modern slavery risks
Finding indicators of modern slavery
Demonstrating progress

Legal requirement to publish

HIGHTOWN HOUSING ASSOCIATION LIMITED has confirmed it is required to publish a 2022 statement by law.

Statement period and sign-off details

The statement covers the following period:
1 April 2021 to 31 March 2022

The statement was signed off by:
David Bogle (Chief Executive)

It was approved by the board (or equivalent management body) on:
21 July 2022

Recommended areas covered by the statement

Government guidance encourages organisations to cover a range of areas in their modern slavery statements, setting out the steps they’re taking to address modern slavery risks in their operations and supply chains. Read about the recommended areas in the statutory guidance.

We asked the organisation to tell us which areas its statement covers.

Areas recommended by government guidance	Organisation’s response
The organisation’s structure, business and supply chains	Covered
Policies	Covered
Risk assessment	Covered
Due diligence (steps to address risk)	Covered
Training about modern slavery	Covered
Goals and key performance indicators (KPIs) to measure the effectiveness of the organisation's actions and progress over time	Not covered This will be addressed in the 2023 statement

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

Charitable / not-for-profit activities

Turnover

Its turnover in the financial accounting year of this statement was:

£100 million to £500 million

If the organisation is a public body, this amount is based on the organisation’s budget for the year of the statement.

What does 'turnover' refer to in group statements?

If this is a group statement, this includes the total turnover for all the organisations covered by the statement.

Number of years producing statements

The organisation has been producing modern slavery statements for the following number of years:

More than 5 years

How does this work for group statements?

If the statement is for a group of organisations, this answer applies to the organisation with the longest history of producing statements.

Policies (optional)

We asked the organisation whether its policies include the following provisions in relation to its domestic and international supply chains, as well as its own operations.

Policy provisions we asked about	Organisation’s response
Freedom of workers to terminate employment	Included
Freedom of movement	Included
Freedom of association	Included
Prohibits any threat of violence, harassment and intimidation	Included
Prohibits the use of worker-paid recruitment fees	Included
Prohibits compulsory overtime	Included
Prohibits child labour	Included
Prohibits discrimination	Included
Prohibits confiscation of workers' original identification documents	Included
Provides access to remedy, compensation and justice for victims of modern slavery	Included
Other	Not included

Training (optional)

We asked the organisation whether it provided training on modern slavery, and who it was for.

What counts as training?

We explained that by ‘training’ we meant anything designed to increase knowledge and skills around identifying, addressing or preventing modern slavery risks. This could range from formal training courses to broader awareness-raising activities such as workshops or webinars.

We asked who the training was for	Organisation’s response
Your whole organisation	Yes
Your front line staff	No
Human resources	No
Executive-level staff	No
Procurement staff	No
Your suppliers	No
The wider community	No
Other	No

Monitoring working conditions (optional)

Engaging with others

We asked the organisation to tell us who it engaged with to help monitor working conditions across its operations and supply chains.

We asked who the organisation engaged with	Organisation’s response
Your suppliers	Yes
Trade unions or worker representative groups	Yes
Civil society organisations	No
Professional auditors	Yes
Workers within your organisation	Yes
Workers within your supply chain	No
Central or local government	Yes
Law enforcement, such as police, GLAA and other local labour market inspectorates	No
Businesses in your industry or sector	No

Social audits

We asked the organisation to tell us about any social audits it used to look for signs of modern slavery.

What are social audits?

A social audit is a review of an organisation’s working practices from the point of view of social responsibility, and should include an evaluation of working conditions in the organisation’s operations and supply chains. By their nature, audits of supplier workplaces represent a snapshot in time.

Organisation’s response

The organisation told us it did not carry out any social audits during the period of the statement.

Grievance mechanisms

We asked the organisation how workers in its operations or supply chains could raise concerns or make complaints.

We asked if workers could raise concerns this way	Organisation’s response
Using anonymous whistleblowing services, such as a helpline or mobile phone app	Yes
Through trade unions or other worker representative groups	Yes

Other ways of monitoring working conditions

We asked the organisation whether it had any other ways of monitoring working conditions across its operations and supply chains:

We revised the remit of the Remuneration & Nominations Committee to include a focus on our People and EDI in order to increase the scrutiny of the Association's working practices.

Modern slavery risks (optional)

Warning Identifying modern slavery risks is a vital step towards eradicating it. The government encourages organisations to be as open and transparent as possible, to improve understanding, collaboration and best practice around tackling this worldwide problem.

We asked the organisation to describe up to 3 priority risks it focused on during the period of the statement, including details of the affected workers, the activity involved, and the location.

Priority risks for this organisation (1 of 3)

In our supply chains, particularly construction and maintenance contractors who may sub-contract areas of work to other companies. However, no instances have been identified to date.

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your supply chains. Tier 1 suppliers Provide their products and services directly to your organisation. Tier 2 suppliers Provide products and services to your organisation via your Tier 1 suppliers. Tier 3 suppliers and below Provide products and services to your organisation via your Tier 2 suppliers or the next higher level in the chain.
Who was it most likely to affect	Organisation’s response: Migrants Refugees
In which country	Organisation’s response: No details provided
Actions or plans to address this risk	Organisation’s response: We have clear due diligence processes and conditions with our primary contractors to ensure proper recruitment practices.

Priority risks for this organisation (2 of 3)

We are aware of sector examples of modern slavery taking place in social housing homes including the exploitation of vulnerable residents. We have robust safeguarding practices as mitigation.

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your own operations.
Who was it most likely to affect	Organisation’s response: Women Migrants Refugees Children Residents who have learning difficulties, mental health problems etc
In which country	Organisation’s response: No details provided
Actions or plans to address this risk	Organisation’s response: We have very robust safeguarding policies and practices, and our Care & Support Schemes are highly regulated and inspected by local authority commissioners and in some cases, the CQC.

Priority risks for this organisation (3 of 3)

Through our recruitment practices, especially where we use agencies to provide temporary staff within our care and support services. We conduct full due diligence for all agencies that we use.

Questions we asked about this risk	Organisation’s response
Where it was most likely to occur	Organisation’s response: Within your supply chains. Tier 1 suppliers Provide their products and services directly to your organisation. Tier 2 suppliers Provide products and services to your organisation via your Tier 1 suppliers.
Who was it most likely to affect	Organisation’s response: Women Migrants
In which country	Organisation’s response: No details provided
Actions or plans to address this risk	Organisation’s response: We conduct robust due diligence in relation to the recruitment agencies that we use.

Indicators of forced labour (optional)

We asked the organisation whether its statement refers to finding any International Labour Organization (ILO) indicators of forced labour.

What are ILO indicators of forced labour?

The International Labour Organization (ILO) has produced a list of the most common signs of forced labour. They’re based on the definition of forced labour as ‘all work or service which is extracted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.’ More details and guidance are available on the ILO website, and in their publication ILO indicators of forced labour