Slavery and Human Trafficking Statement

Slavery and Human Trafficking Statement


This statement is made pursuant to s54 Modern Day Slavery Act 2015 and is Gentoo’s Slavery and Human Trafficking Statement for the financial year ending March 2016.  This statement applies to Gentoo Group and its subsidiaries as set out below.

Our Structure and Business  

Gentoo Group comprises the parent Gentoo Group Limited and its subsidiaries.

Gentoo is a housing association that owns and manages more than 28,000 homes.We believe that by putting people first we can build great homes and create strong communities. We are focused on delivering an outstanding service to our customers and as a responsible business we pride ourselves on inspiring people to make a difference. We collaborate with key partners and other housing associations to influence things that affect our colleagues, customers and society. We are one of the largest employers in Sunderland and landlords in the North East.

Our policies in relation to slavery and human trafficking

Housing management policies

We take a zero tolerance approach to human trafficking and slavery, in our supply chains or any other part of our business.

Our Safeguarding Policies highlight that modern slavery, which encompasses slavery, human trafficking, forced labour and domestic servitude, are a form of abuse and must be dealt with as a Category 1, which is our highest priority. These policies give staff guidance as to how recognise such signs of abuse, and how to deal with it with our partners.

As part of our Tenancy Management policy, Gentoo staff complete regular Tenancy Surveys, which aim to ensure that the legal tenant and their household are living in the property, and that it is not used for illegal purposes, which includes human trafficking and slavery.

Employee policies

Gentoo also recognises the potential for slavery and human trafficking to affect employees working within its business.

To ensure its employees are not subject to undue influence and are treated with dignity and respect, Gentoo has robust HR policies and procedures in place across all its operations. These are regularly audited to ensure compliance with employment legislation and prevent unethical working practices. Gentoo is committed to ensuring that all staff receive fair remuneration for the job they perform and undertakes regular reviews of terms and conditions across the work place.

Our supply chains

Gentoo Group procures a wide range of goods and services via a diverse and varied supply chain, including but not limited to the following:

  • Property related services and materials (construction and maintenance)
  • Facilities management services
  • Communications and IT equipment services
  • Temporary/Agency staff
  • Various professional services
  • Office equipment and supplies
  • Plant Hire
  • Lease Cars
  • Commercial Fleet
  • Utilities

Supply chain policies on slavery and human trafficking

Our policies as detailed above are shared with our Supply Chain and it is requested that they read and commit to these policies.

As part of our initiative to identify and mitigate risk we now require our Supply Chain, as part of our tender procedures, to answer questions targeted at slavery and human trafficking risk.

Supplier adherence to our values and ethics

We require all of our Contractors to register with Constructionline who also capture information in relation to the Modern Day Slavery Act.  As part of their registration, the company is asked if they have a policy/statement that sets out the steps their organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of their supply chains or in any part of their own business and to provide any relevant information.

We are currently developing a Supplier Portal which will be launched this year where we will require our Supply Chain to answer the following question:

The Modern Day Slavery Act 2015 requires organisations with a turnover of £36 million or more to produce a Slavery and Human trafficking statement each financial year.

Is your turnover over £36million YES/NO if yes:

Do you have a policy/statement that sets out the steps your organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of your supply chains or in any part of your own business. YES/NO if yes please provide details

The above will be monitored and any areas of concern will be addressed and if required the Supplier will be suspended for use until we are satisfied of their commitment. The portal is also linked to Constructionline and will be updated daily with our Supply Chains’ current registration status. We will take the appropriate action against any suppliers who have been suspended; we will try to help those suppliers get re-instated or as a last resort they may be removed from the site and no further order received.

Further work will continue with our existing suppliers, to review high risk areas such as offices supplies, building materials, ICT equipment, cleaning etc. and be included in the Supplier Portal process for identifying and monitoring these suppliers.


All staff have been briefed on the issue of slavery and human trafficking, including how to recognise and deal with it.


Date: 13th July 2016

Signed by:                       

John Craggs

Chief Executive Officer

Gentoo Group Limited