Modern Slavery Statement 2018
Our business and organisational structure
Sovereign is a social business and one of the largest housing associations in the country. We provide over 55,000 homes for around 130,000 people in housing need across the south and south west of England and the Isle of Wight. Sovereign Housing Association is a Registered Provider of Social Housing registered as a society under Cooperative and Community Benefit Societies Act 2014 with the FCA (7448) and with the social housing regulator, the HCA (4837).
This statement covers Sovereign and its subsidiary companies as listed below:
- Doubloon Developments Limited (Company Number: 06195779)
- Florin Homes Limited (Company Number: 07233624)
- Sovereign Advances Limited (Company Number: 06927929)
- Sovereign Housing Capital plc (Company Number: 06992513)
- Sovereign Living Limited (FCA Registration Number: 26400R)
- Sovereign Westinghouse Development Limited (Company Number: 07174978)
- Spectrum Premier Homes Limited (Company Number: 2914932)
- Spectrum Property Care Limited (Company Number: 8758536)
- Spectrum Property Ventures Limited (Company Number: 7954841)
- Accountable - We take personal responsibility and are trusted to do the right thing
- Together - We collaborate with colleagues and partners so everybody benefits
- Drive to deliver - We work with energy, enthusiasm and passion to get things done and we do what we say we will
- Adaptable - We embrace change, think ahead and find new ways of delivering a better customer experience
Procurement and supply chains
Sovereign has an annual expenditure on goods, works and services of circa £150m. The way we manage our procurement and supply chain is increasingly important to our financial viability, reputation and corporate social responsibility objectives. We recognise that good procurement practice can directly enhance our business performance by securing best value goods and services against favourable commercial and contractual terms.
Sovereign is committed to ensuring that there is no modern· slavery or human trafficking in our supply chains or in any part of our business. Our supply chains include sourcing of goods, services and works for the delivery and maintenance of quality homes.
To reflect recent changes in Government guidance on the pre-qualification of suppliers in a tender process, we have updated our tender questionnaires to the Standard Selection Questionnaire, aligned with the UK Public Contract Regulations 2015.
Parts 1 and Part 2 of the Standard Selection Questionnaire list the exclusion grounds that apply to public procurements above EU thresholds, and the statutory guidance states that the selection questions in Part 3 should be adopted across all procurement procedures and embedded as needed into procurement processes. As such Sovereign has adopted the standard Selection Questionnaire structure as a starting point to develop questions in the tender documents for lower value procurements.
Part 3 (Selection Questions) includes a section specifically on the Modern Slavery Act 2015 and a declaration to be completed by potential suppliers.
The standardised pre-qualification questionnaire developed by the BSI for construction tendering (PAS91 PQQ) is used in works contracts above the relevant OJEU threshold. The BSI are updating PAS91 to reflect the 2015 Regulations so until the new version is published, as part of Sovereign's due diligence processes into slavery and human trafficking, specific questions will be included in all tenders to confirm bidders' commitments to ensuring that there is no modern slavery or human trafficking in Sovereign's supply chain. This will include a Bidder declaration and potentially the submittal of associated policy/ statement depending on the suppliers' annual turnover.
Policy statement on slavery and human trafficking
Sovereign is committed to social and environmental responsibility and has zero tolerance for slavery and human trafficking. We hold ourselves and our supply chain accountable and we fully comply with the provisions of the Modern Slavery Act 2015.
We recognise that modern slavery can exist in a complex supply chain issue, and we work in partnership with our Customers, Suppliers, with local and national Government Organisations and agencies as well as other organisations to help develop long-term solutions to this issue.
We have rigorous Human Resources procedures in place to ensure that all employees have a legal right to work in the UK, are paid a fair and legal wage, and are under no duress.
Our social purpose and commitment to preventing slavery and human trafficking are also reflected in our Safeguarding and Procurement Policies, to underscore the seriousness of slavery and human trafficking and ensure that staff are aware of and responsive to the issues. We have an open accountable culture and if slavery and safeguarding issues emerge, these are reported through standard management processes, the Safeguarding Reporting process or through our Whistleblowing process.
Sovereign Housing Association and its subsidiaries will not support or deal with any business knowingly involved in slavery or human trafficking. The Board of Directors and all senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chains.
In terms of oversight, procurement and compliance are reviewed by the Audit and Risk Committee of the Board regularly. This policy statement will be reviewed by the Board annually and published.
Supplier adherence to our values
Sovereign has zero tolerance to slavery and human trafficking and we expect all those in our supply chain and contractors to comply with our values.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our procurement and supply chains within our business, we continue to aim to provide training to relevant members of staff.
We also continue to provide training to our frontline staff to help them identify potential cases of slavery and human trafficking and how to report them.
During this financial year Sovereign Housing intends to further expand the steps it takes to combat modern slavery and human trafficking as follows:
We continue to request a declaration of compliancy in line with the requirements under Modern Slavery Act 2015 from all bidders in our OJEU tendering activity. These declarations are mirrored in our Supplier On-boarding process for new suppliers and we are currently undertaking a review of incumbent suppliers on boarding Modern Slavery declaration in line with the current Procure to Pay P2P implementation project. We have also set up a distinct reporting category to capture modern slavery and human trafficking from April 2018.
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes our group's slavery and human trafficking statement for the current financial year ending 31st March 2018.
Date of Board Approval: 17 May 2018