Modern Slavery Transparency Statement
As a business, we’re committed to upholding the highest standards of probity, openness and transparency so we can provide the best service to our customers, protect our assets and reputation and safeguard public funds.
In compliance with the Modern Slavery Act 2015, Merlin has a zero-tolerance approach to slavery, human trafficking, exploitation or corruption of any kind in the work we do, in the work our partners do and in our wider supply chains.
We expect those we work with to have the same zero-tolerance attitude and approach and we would never knowingly seek to work with any organisation whose approach or practices were found to be incompatible with our own.
This Statement is made for and on behalf of Merlin Housing Society Limited for the financial year ending 31 March 2018. It is published on our intranet (‘Mint’) and on the Merlin website.
This Statement is supported by the following policies, guidance and training:
- Probity Policy;
- Procurement Policy;
- Colleague code of conduct;
- Grievance, disciplinary and whistleblowing procedures;
- Safeguarding training; and
- Health and safety policies and procedures.
Our recruitment and people management procedures ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment. They include
- Pre-employment checks: work permits, DBS, references
- Paying the living wage foundation rate
- Overtime working is voluntary and recompensed, either as pay or time off
Organisations with significant resources and purchasing power are in a unique and very strong position to influence global supply chains. It is simply not acceptable for any organisation to say, in the twenty-first century, that they did not know about modern slavery risks. That is why the transparency in supply chains provision in the Modern Slavery Act 2015 is so vital in the fight against these crimes. This measure requires businesses to be transparent about what they are doing and is increasing competition to drive up standards.
At Merlin we also think it is not acceptable for organisations to ignore this issue because it is difficult or complex. As we increase our supply chain accountability we can have greater confidence in the goods and services we buy. That is why the transparency in supply chains provision we are working with is world leading and will bring about the change that is so vitally needed.
Our statement is designed to increase transparency by ensuring the public, consumers, employees and stakeholders know what steps we are taking to tackle modern slavery.
We have made all staff aware of the Modern Slavery Helpline on 0800 0121 700. This will allow anyone who thinks they may have come across an instance of modern slavery to call for more information and guidance on what to do next. In any case where you may be concerned about the welfare of a customer or member of the public you should also inform your line manager, following the safeguarding procedure.
We have also included further advice about these requirements for our contractors and suppliers in our procurement handbook.
UK Modern Slavery Adult Victim support providers:
- England and Wales The Salvation Army - 0300 303 8151
- UK Government Modern Slavery Helpline - 0800 0121 700
Our Modern Slavery Transparency Statement 2018
This statement is made on behalf of the Board of Merlin with regards to the Modern Slavery Act 2015 which requires large employers (with a turnover of more than £36 million) to be transparent about their efforts to eradicate Slavery and Human Trafficking in their supply chain.
1 Organisational structure
Merlin develops affordable housing for rent and sale across the West of England and provides landlord and repairs and maintenance services. We own or manage over 8,000 properties and provide services to more than 18,000 customers. We aim to be world class in setting the highest standards in how we run our business and in our employment and procurement practices.
Merlin does not trade for profit and nothing is paid or transferred by way of profit to shareholders. Any surplus generated from our activities is re-invested back into the organisation, to further improve our services to customers and communities. In 2016/17 this amounted to an accounting surplus of £13m and a cash surplus of £21m against a turnover of £43.7m.
We support the principles of the Modern Slavery Act and the abolition of modern slavery and human trafficking.
2 Our supply chains
We buy mainly construction-related supplies, services and works and our procurement is subject to the Public Contracts Regulations 2015.
Our suppliers range from sole traders to large organisations and can be appointed for ad hoc requirements or for term contracts for requirements of a similar nature which recur over time. We adopt a proportionate approach relevant to the value and risk of each procurement.
3 Our policies in relation to Slavery and Human Trafficking
We are committed to ensuring that there is no modern slavery in our supply chains or in any part of our organisation. Our policies in relation to probity, procurement, code of conduct, whistle blowing, safeguarding and health & safety and recruitment, all reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place in our supply chains.
Copies of our policies are available to all our colleagues on our intranet, Mint and where applicable published on our website.
4 Due diligence processes
As part of our initiative to identify and mitigate the risk of slavery and human trafficking, we have in place systems and processes which:
- identify and assess potential risk areas in our supply chains;
- mitigate the risk of slavery and human trafficking occurring in our supply chains; and
- protect those who wish to raise concerns in confidence.
5 Our risks and how we manage them
We have identified the following areas of risk in relation to modern slavery and human trafficking:
Colleague awareness – Colleagues are unaware of the stance set out in this Statement and do not report concerns when they have reason to do so.
- To address this risk, we will ensure that this Statement, and the associated policies, are communicated to colleagues.
Individual procurements above £100,000 – There is a greater risk of slavery and human trafficking entering our supply chains when we are working with larger suppliers/contractors or on higher-value contracts.
- To address this risk, a risk analysis is undertaken on all contracts above £100,000. Risks are managed through supplier sourcing & selection and during contract management. We will end supply contracts where we find suppliers are non-compliant.
6 Supplier adherence to our values
We are committed to tackling modern slavery and human trafficking – we have a zero-tolerance approach and want to work with suppliers who share our values.
To make sure our contractors and all those in our supply chain are aware of, and comply with, our values, we use a number of approaches including:
- supplier self-certification;
- pre-qualification questions to determine suitability of potential suppliers; and
- standard clauses in conditions of contract that specifically require legal compliance by suppliers.
As an organisation active in the community, Merlin is well placed to identify signs of slavery and human trafficking, and as such we provide ongoing safeguarding training to colleagues to help them to spot issues when going into homes and meeting customers.
Colleagues in the recruitment team are all trained on legislative requirements, to ensure that all candidates have the right to work in the UK before offered a position in Merlin.
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Slavery and Human Trafficking Statement for the financial year ending 31 March 2017.
Approved by the Board of Merlin Housing Society Limited at their Board meeting on 27 February 2018
Vivienne Horton (Chair)
Robert Nettleton (Chief Executive)