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 2021.  This statement applies to Gentoo Group, its subsidiaries, contractors and supply chains.

Our Structure and Business

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

Gentoo is a housing association that owns or manages more than 28,000 properties. 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.

Gentoo Homes is a subsidiary of Gentoo Group Ltd and is one of the North East's most successful housing developers. They have experience and expertise in property related activity ranging from regeneration and modernisation to new build schemes. Gentoo Homes are a profit for purpose business and reinvest back into Gentoo. 

Our policies in relation to slavery and human trafficking

Housing management policies

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

The Group’s 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 to help recognise such signs of abuse, and how to deal with it with our partners.  All colleagues who visit tenants are encouraged to remain vigilant and be aware of the potential signs and are trained in how to report such concerns, utilizing the Group’s Something Not Quite Right process.

As part of our Tenancy Management policy, Gentoo staff complete regular Customer 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

As Gentoo employs approximately 1044 employee’s we recognise 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 workplace. As stated in our Equality, diversity and Inclusion Policy, when using agencies and other bodies associated with the employment of the Group, the Group will ensure that steps are put in place to ensure that no slavery or human trafficking is in these supply chains and that thorough checks and procedures are in place to work with such bodies.  Our Code of Conduct, which staff, contractors and suppliers must sign up to, requires adherence to all relevant legislation. This includes the Modern Slavery Act.

Our supply chains

We procure a wide range of goods and services through a diverse supply chain, including:

  • Property related services and materials, including construction, maintenance and new home development
  • Facilities management including cleaning
  • Information Technology
  • Professional Services including recruitment agencies
  • Office equipment and supplies
  • Utilities

Supplier Due Diligence

The Group’s zero-tolerance approach to modern slavery will be communicated to all suppliers and contractors at the outset of our business relationship with them and we endeavour to have meaningful conversations with our suppliers throughout the contract to ensure appropriate compliance.  Our standardised contract and supplier management processes, implemented in September 2021, address all aspects of a supplier’s due diligence, including Modern Day Slavery.  This is reviewed formally on an annual basis and discussed in regular supplier management meetings.

For our contractors, our expectation is that they are Chas Premium Plus accredited, which ensures that Modern Day Slavery has been assessed.  We will ensure through robust contractor management, that Modern Day Slavery is discussed throughout the duration of our contracts.


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 with their commitment.  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.


Specific training has been undertaken on a risk-based approach, in which those employees most likely to encounter issues are trained as priority. Information covered includes how to spot likely signs of ‘modern slavery’ and how to escalate concerns. Gentoo also has a ‘Whistleblowing’ policy which allows concerns to be reported on a confidential basis and without fear of recrimination. We have also undertaken supplier management training with staff who have a responsibility for supplier management.  We will encourage our staff, suppliers and contractors to use the Whistleblowing process to report any incidents of concern regarding potential modern slavery.

Training on slavery and human trafficking is included as part of our Safeguarding training to all staff and is refreshed on a regular basis.