HIGHTOWN HOUSING ASSOCIATION LIMITED modern slavery statement summary (2026)

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 all 6 recommended topics

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

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Modern Slavery Statement 2025-26.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

Statement period and sign-off details

The statement covers the following period:
1 April 2025 to 31 March 2026

The statement was signed off by:
Qadeer Kiani (Chair of the Board)

It was approved by the board (or equivalent management body) on:
16 July 2026

Recommended topics covered by the statement

Government guidance encourages organisations to cover a range of topics 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 topics in the statutory guidance.

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

Topics 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 Covered

The organisation’s sectors and turnover

Sectors

The organisation operates in the following sectors:

  • Charitable / not-for-profit activities
  • Construction, civil engineering and building products
  • Consumer services, including accommodation, hospitality, tourism and leisure

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 Not included
Prohibits any threat of violence, harassment and intimidation Included
Prohibits the use of worker-paid recruitment fees Not 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 Not 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
Compliance Manager

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 No
Workers within your organisation Yes
Workers within your supply chain No
Central or local government No
Law enforcement, such as police, GLAA and other local labour market inspectorates No
Businesses in your industry or sector Yes

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.
Social audits we asked about Organisation’s response
Audit conducted by your staff Yes
Third party audit arranged by your organisation No
Audit conducted by your supplier’s staff No
Third party audit arranged by your supplier No
Announced audit No
Unannounced audit No

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:
No other ways other than the ones stated

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)

Due to the nature of our business, we procure goods and services across multiple sectors with inherently high modern slavery risks, including construction, social care, and operational maintenance.
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:
  • Women
  • Migrants
  • Refugees
In which country Organisation’s response:
  • Albania
  • Bulgaria
  • India
  • Romania
  • Ukraine
Actions or plans to address this risk Organisation’s response: We are committed to continuously reviewing and strengthening our modern slavery framework to ensure our controls and assurance activities remain effective, proportionate, and responsive to inherent and emerging risks, regulatory developments, and evolving best practice.

Priority risks for this organisation (2 of 3)

While Hightown has a good understanding of its direct suppliers, visibility beyond Tier 1 remains limited.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Within your supply chains.
  • 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:
  • Workers within lower-tier supply chains
In which country Organisation’s response:
  • Albania
  • Bulgaria
  • India
  • Romania
  • Ukraine
Actions or plans to address this risk Organisation’s response: The MSAT risk assessment of high-risk Tier 1 suppliers showed that, of the 16 respondents, two reported high-risk locations within their operations or supply chains outside the UK, while none reported mapping their supply chains beyond Tier 1. We will strengthen our approach to the MSAT risk assessment and re-engage in-scope strategic and high-spend suppliers, aiming to increase response rates while maintaining the breadth of assessment coverage.

Priority risks for this organisation (3 of 3)

Hightown provides affordable and supported housing and some of our customers may be at increased risk county lines activity, cuckooing and human trafficking.
Questions we asked about this risk Organisation’s response
Where it was most likely to occur Organisation’s response: Organisation selected ‘Other’ and wrote:
Within the accommodation we provide.
Who was it most likely to affect Organisation’s response:
  • Vulnerable customers, including those experiencing homelessness, displacement, substance misuse, mental ill health, financial hardship, or other circumstances that may increase their susceptibility to criminal, labour, or other forms of exploitation.
In which country Organisation’s response: United Kingdom
Actions or plans to address this risk Organisation’s response: We will continue providing modern slavery awareness training to colleagues and strengthing partnerships with other housing providers and external agencies to improve the identification, referral and escalation of potential modern slavery risks within our services and neighbourhoods.

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
ILO indicators we asked about Organisation’s response
Abuse of vulnerability Yes
Deception No
Restriction of movement No
Isolation No
Physical and sexual violence No
Intimidation and threats No
Retention of identity documents Yes
Withholding of wages No
Debt bondage No
Abusive working and living conditions No
Excessive overtime Yes
Other
-

Actions taken in response to finding ILO indicators

We asked the organisation to tell us whether its statement refers to any actions it took after finding indicators of forced labour
Organisation’s response
The organisation told us its statement does not refer to actions it took after finding indicators of forced labour.

Demonstrating progress (optional)

We asked the organisation how its statement demonstrates progress over time in addressing modern slavery risks. They provided the following answer:
The Modern Slavery Statement was revised to align more closely with the structure of the Transparency in Supply Chains (TISC) guidance. Insights from the MSAT risk assessment of high-risk Tier 1 suppliers were reviewed with colleagues to refine supplier response expectations and inform future surveys and KPIs. Modern slavery due diligence requirements were enhanced within the New Supplier Form, improving information capture and supplier risk assessment during the onboarding.