Modern Slavery and Human Trafficking Statement 2019/2020

LiveWest develops affordable housing for rent and sale in the south west of England and provides landlord, individual support and community services. We own or manage over 37,000 properties and provide services to over 70,000 residents. We promote the highest standards in how we operate our business to ensure that we fully comply with the principles of the Modern Slavery Act 2015.

This statement summarises LiveWest’s approach and the action we have taken this year in our own company and supply chain.  

Within LiveWest, our recruitment and people management systems 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:

  • carrying out pre-employment checks including work permits, references and where role appropriate DBS;
  • paying at least the national living wage;
  • ensuring that overtime working is voluntary and recompensed, either as pay or time off;
  • implementing appropriate grievance procedures and a comprehensive Whistleblowing Policy; and
  • having a robust framework of health and safety policies and procedures.

LiveWest has an annual expenditure on new property developments, maintenance works and services in excess of £260m. Procurement activities take place in England and our contractors and suppliers are predominantly UK based.

LiveWest is committed to social and environmental responsibility and has a zero tolerance for 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 as well as corporate service requirements.

In line with government guidance on the pre-qualification of suppliers in a tender process, our tender questionnaires use the Standard Selection Questionnaire, aligned with the UK Public Contract Regulations 2015.
Part 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. 

Part 3 (Selection Questions) includes a section specifically on the Modern Slavery Act 2015 and a declaration to be completed by potential suppliers.
We work with a wide range of different contractors, suppliers and partners and some of our supplier’s subcontract work or rely on recruitment agencies to supply temporary or permanent staff.  In order to ensure they comply with the Act we have incorporated the requirement in our suppliers’ terms and condition and will be part of our regular supplier meetings in 2020/21.  Additionally, our key suppliers have been contacted to confirm they are compliant with the Act.  
By the nature of their businesses, some of our suppliers are potentially at higher risk than others, for example: maintenance, repairs and construction companies, cleaning and grounds maintenance contractors and security firms as they are generally low pay and low skill jobs. 

We expect all of these and any other companies we engage with to ensure that their goods, materials and labour-related supply chains fully comply with the Modern Slavery Act 2015, are transparent, accountable and auditable and are free from ethical ambiguities and that they hold relevant and necessary accreditations. 

During 2019/20, we have:

  • continued to make our staff aware of the Modern Slavery Act, including its definitions of slavery and human trafficking and potential risk areas using online training; 
  • carried out a risk analysis to support procurement and contract management, reviewing expenditure with contractors and suppliers, identifying potential sector risks and focussing on recognised low-pay sectors; 
  • reviewed our procurement guidelines to ensure they reference and embed best practice to modern slavery and human trafficking;
  • reviewed the terms and conditions used for LiveWest’s purchase orders and contracts include the requirement for compliance by suppliers with the Modern Slavery Act 2015;
  • ensured that tender documentation includes the mandatory exclusion of any bidder who has been convicted of an offence under section 1, 2 or 4 of the Modern Slavery Act 2015; and
  • reviewed our Whistleblowing Policy and communicated it to staff to ensure that it includes an appropriate framework within which they or any other parties may report suspected modern slavery or human trafficking or any other related practices.

In the 2020/21 financial year LiveWest will further expand the steps it takes to combat modern slavery and human trafficking by surveying key suppliers in the potential risk sectors to provide assurance of their understanding and compliance with The Act.  Additionally, as part of the procurement team’s professional qualifications they are required to undertake annual ethical procurement and supply training which including an element for modern slavery.  Looking further ahead, we will provide refresher training to the wider business and use our network of housing associations to identify best practice and improvements to our current processes.  We will also engage with Advantage South West, a procurement consortium jointly owned by LiveWest, Abri, North Devon Homes and Ocean Housing to ensure appropriate processes are also adopted.   

In addition, we have a Safeguarding Policy in place to ensure that all suspected cases of neglect or abuse including suspected modern slavery or human trafficking are investigated and reported.  We visit all our tenants on a rolling basis as part of our tenancy audit programme. During these visits, we check for signs of modern slavery and human trafficking, as well as any other welfare concerns which the tenants or members of their households may have.
When signing up new tenants we undertake a robust process to ensure that they are who they say they are which includes background and identification checks.  We work closely with local partners and external agencies to identify and tackle tenancy fraud.  Our Neighbourhood Team will always investigate any allegations from customers or the wider community regarding potential tenancy fraud.  

For the purposes of this statement, “LiveWest” refers to the activities of LiveWest Homes Limited a charitable community benefit society, company number: 7724 (Parent) and includes: 

  • Arc Developments South West Limited, company number: 05716836;
  • LiveWest Properties Limited, company number: 10110021; 
  • LiveWest Treasury plc, company number: 06392963;
  • Great Western Assured Growth Limited, company number: 02525892;
  • LiveWest Capital plc, company number: 08691017;
  • LiveWest Charitable Housing Limited, company number: 19165R; and 
  • Westco Properties Limited, company number: 02677745.

All companies are registered in England & Wales, trading as "LiveWest", with a registered office at: 1 Wellington Way, Skypark, Clyst Honiton, Exeter, EX5 2FZ.

…………………………….

Paul Crawford
Chief Executive
17 December 2020