Modern Slavery Transparency Statement


It is a terribly sad fact that slavery still that affects communities and individuals across the globe in this so called modern age. 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.

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.

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.

The Government introduced a provision in the Modern Slavery Act 2015 which requires businesses (including Merlin) to produce a statement setting out the steps they have taken to ensure there is no modern slavery in their own business and their supply chains.

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 will build on what we are doing year on year. Our first statement shows how we are starting to act on the issue and sets out planned actions to effect change.
One of the first things we are doing is to identify where our current policies and procedures can be aligned to the Modern Slavery Act 2015 expectations. For example our safeguarding and whistle-blowing training will include how to identify the signs of modern slavery and to flag up potential issues.

We are making 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 out new procurement handbook.

UK Modern Slavery Adult Victim support providers:
England and Wales The Salvation Army 0300 303 8151
Modern Slavery Helpline The UK Government also provides a 24-hour modern slavery helpline that victims, employers and members of the public who may encounter modern slavery can call for expert support and advice. 0800 0121 700

Our Modern Slavery Transparency Statement

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.

Merlin develops affordable housing for rent and sale in the South West of England and provides landlord and repairs and maintenance services.  We own or manage nearly 8,000 properties and provide services to over 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.  We support the principles of the Modern Slavery Act and the abolition of modern slavery and human trafficking.

What does Merlin already do?
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:

  • employee code of conduct
  • 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
  • grievance, disciplinary and whistleblowing procedures
  • health and safety policies and procedures.

Our internal contractor Property Solutions provides a range of services which if out-sourced could potentially be at a higher risk – repairs and maintenance, grounds maintenance and cleaning contractors. By managing these services in-house some of this risk is mitigated. We still have an extensive supply chain and we procure goods and services in excess of £20 million per year.  We work with a wide range of different suppliers and partners.  We sometimes rely on recruitment agencies to supply temporary or permanent staff which can also increase a modern slavery risk.

We will continue to work with our staff, partners and contractors to ensure we meet the expectations of the Modern Slavery Act.

What changes have we made?

  • We have raised our staff awareness of the Modern Slavery Act, including its definitions of slavery and human trafficking and training on how to respond if a case is suspected.
  • We have revised our procurement guidelines to include reference to the Act.
  • We have amended our Whistleblowing Policy.
  • An Executive Director has ownership for actions arising from this statement.
  • We have contacted suppliers and partners in potentially higher risk categories to check what assurance arrangements they have in place.
  • We have adapted existing policies and procedures to reference the Modern Slavery Act 2015 / Modern Slavery Transparency Statement

What will we do in 2017/18?

  • We will refresh a modern slavery risk assessment by September 2017.
  • We will continue to learn from cases which may arise in other similar organisations and amend our policies and procedures accordingly.
  • We will complete our Safeguarding training following a review of our policy in 2016 to support staff to understand the impact of Modern Slavery and work towards its eradication by proportionate and relevant action.

Vivienne Horton
1 April 2017

Robert Nettleton
Chief Executive
1 April 2017