As of January 2016 the Modern Slavery Act (MSA) is in force. The MSA aims to combat crimes of slavery and human trafficking by creating criminal offences and powers of enforcement.
The MSA says that businesses have a role to play in reducing slavery, and has imposed obligations on large organisations, including housing associations, to publish a statement at the end of each financial year that proves they have no involvement with slavery or human trafficking.
While the obligation falls only on large housing associations (those who turnover £36m), smaller housing associations can publish a statement if they wish, and it would be considered best practice for this to be the case.
The obligation on a housing association to consider whether such crimes exist within their business extends to its supply chains which includes anything which enables the organisation to provide services to its end user.
By outsourcing or sub-contracting, housing associations need to consider how to carry out the necessary checks and standard terms should be introduced with contractors to ensure that they are aware of the housing associations stance on modern slavery.
As reputation is key for housing associations, for the impact on customers and stakeholders, it’s vital that housing associations take the MSA seriously and make an effort to adhere to the obligation. With reputation in mind, here is how you can ensure that your social housing contractors are compliant:
This step should take place at the beginning of the on-boarding process – it includes checking that a contractor’s standards and industry certifications are in order before any work begins.
Typically, this can involve you and your team working to verify insurance, certifications and other claims a contractor might make when pitching for work – you should never rely on a contractors claims alone.
At this point you can ask your contractor to provide you with documentation to show that they abide by the MSA.
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Authorisation is the process of approving a contractor to deliver work for your company – this means authorising contractors to do specific jobs. Once you are satisfied that your social housing contractors have met your assessment requirements, you need to ensure that they have the relevant information and documentation so that they can begin work.
Once a contractor is authorised, it’s time to put them on your ‘approved contractor’ list – this is often underrated, but it’s important. You don’t want a non-approved contractor to slip through the cracks and carry out work for your housing association, especially if they aren’t biding by the rules of the MSA.
Create policies and rules that clearly explain to your contractors what you expect and want to see from them, this includes requiring them to abide by the MSA laws.
Make sure that you’re using a good IT system to disseminate the information and get acknowledgements back that your policies and rules have been received and understood by the contractor – this will cover you and the housing association, should the worst happen.
As explained in another of our blogs, Health and safety manager’s guide to monitoring social housing contractors, you need a process in place where you can monitor the progress of your contractors against the targets and contractual specifications that you have set for them.
This can be in the form of an audit, which can assist your housing association in identifying areas for improvement and assess the performance of your social housing contractors in accordance with your KPIs, which is crucial to maintaining your high standards and reputation.
In this blog, we have only touched on the surface of best practice for managing your social housing contractors. If you’d like to learn more about how you can implement measures to ensure that your social housing contractors are compliant, you should download our eBook, the Best practice guide to social housing contractor compliance, where you will learn tips about how you can achieve contractor compliance.