Modern Slavery and Human Trafficking Statement

Overview

Modern slavery is when someone is exploited and cannot freely leave their situation. It can include slavery, human trafficking, forced labour and domestic servitude. 
This statement explains the steps we took during the financial year ending 31 March 2026 to help prevent modern slavery and human trafficking. It has been prepared in line with section 54 of the Modern Slavery Act 2015.

In this statement, “Gentoo” means Gentoo Group Limited and its subsidiaries, including Gentoo Homes, unless stated otherwise. It also applies to the contractors, suppliers and business partners who help us deliver our services.

This statement has been approved by the Gentoo Group Board. 

Our commitment

We do not accept modern slavery in any part of our organisation or supply chains. 

We have policies, training and checks in place to help us:

• prevent modern slavery
• identify concerns
• report risks
• take action when needed

We expect our contractors, suppliers and business partners to meet the same standards. 

Any concerns relating to modern slavery are treated seriously and investigated appropriately. 

About Gentoo

Gentoo Group Limited is the parent organisation of Gentoo Homes. Gentoo Homes is a business that reinvests its profits back into Gentoo to support our social purpose. 

We own or manage more than 29,500 homes and are one of the largest employers in Sunderland and one of the largest housing providers in the North East. 

We put people first so we can:

• build great homes
• create strong communities
• inspire people
• provide outstanding services for our customers

We work with a range of partners to support our customers, colleagues and communities.

Where risks may arise

We recognise that modern slavery can affect people in different ways. 

Risks may arise:

• within our homes and communities through exploitation, trafficking or abuse
• through temporary labour, agency workers and recruitment activities
• within parts of our supply chain
• in labour-intensive sectors such as construction, repairs, maintenance and facilities management

We use safeguarding, recruitment, purchasing and contract management arrangements to reduce these risks. We focus our checks on areas where the risk may be higher.

Training our colleagues

All colleagues complete safeguarding awareness training every year. This helps them recognise concerns, respond appropriately and report anything that does not seem right. 

All colleagues also complete Code of Conduct training when they join Gentoo and whenever the Code is updated. This helps them understand the standards we expect everyone to follow, including

• acting with integrity
• behaving professionally
• treating people with dignity and respect
• supporting our social purpose
• protecting themselves, others and the environment

Colleagues who work closely with customers receive training to help them:

• recognise signs of modern slavery and abuse
• identify safeguarding concerns
• report concerns appropriately
• remain vigilant

This includes neighbourhood co-ordinators, support co-ordinators, tradespeople, inspectors and surveyors. 

We also train colleagues who manage contractors and suppliers so they can identify and reduce risks within our supply chain.

Safeguarding and supporting our customers

Our safeguarding and housing policies help colleagues recognise potential signs of modern slavery and abuse and understand how to respond to concerns. 
As a housing association, our colleagues and contractors regularly visit customers in their homes. This places us in an important position to identify possible signs of exploitation, abuse or modern slavery and take appropriate action. 

When a customer moves into a Gentoo property, we confirm who the legal tenants and household members are. Neighbourhood Co-ordinators get to know their customers and remain alert to signs that a property may be being used for illegal activities, including human trafficking.

Looking after our colleagues

We recognise that modern slavery can affect people who work for Gentoo as well as those who use our services. 

Our employment policies, procedures and terms and conditions help protect colleagues, contractors and suppliers by ensuring:

• people are treated fairly and with respect
• employment laws are followed
• unethical working practices are prevented
• right-to-work and pre-employment checks are completed
• colleagues receive fair pay
• recruitment agencies have measures in place to prevent modern slavery

These arrangements are regularly reviewed as part of our people governance processes.

Codes of conduct

All Gentoo colleagues are expected to follow our Code of Conduct. 

Contractors and suppliers are expected to follow our Supplier Code of Conduct, which includes meeting the requirements of legislation such as the Modern Slavery Act 2015. 

The Supplier Code of Conduct is based on the principles contained within our wider organisational Code of Conduct and reflects the standards we expect from those working on our behalf. 

Speaking up about concerns

We encourage colleagues, customers, suppliers, contractors and other partners to report any concerns about potentially unethical behaviour, including fraud, bribery, slavery or human trafficking. 

Concerns can be reported confidentially through our independent whistleblowing service, Safecall, or through the routes set out in our Whistleblowing Policy. 

If something does not feel right, we encourage people to speak up. They do not need proof before raising a concern. 

Colleagues can contact Safecall on 0800 915 1571 or gentoo@safecall.co.uk

Our supply chains

We buy goods and services from a wide range of suppliers and contractors, including:

• construction, repairs and maintenance services
• facilities management services
• information technology equipment and services
• recruitment services
• office equipment and supplies

We communicate our zero-tolerance approach to modern slavery throughout our relationships with suppliers and contractors.

Working with contractors and suppliers

We carry out checks before appointing suppliers and throughout our contracts to help reduce the risk of modern slavery. The level of checking reflects the type of work being carried out and the level of risk involved. 

We discuss modern slavery as part of our supplier and contract management arrangements. We review suppliers’ commitments to preventing modern slavery and expect them to maintain appropriate standards. 

Where relevant, we work with contractors who hold Advanced or Elite accreditation under the Contractors Health and Safety Assessment Scheme. 
If a supplier or contractor does not meet our standards, we may require improvement action or, where necessary, end our contractual relationship.

How we monitor our approach

We monitor the effectiveness of our approach through:

• safeguarding training completion
• contractor and supplier reviews
• whistleblowing reports
• safeguarding concerns and referrals
• ongoing contract management arrangements

These checks help us understand whether our controls are working effectively and where improvements may be needed. 

If concerns are identified, we take action to address them and strengthen our arrangements where appropriate. We will stop working with contractors or suppliers if we cannot obtain sufficient confidence that our standards are being met.

Annual review

We review this statement every year. 

We continue to monitor changes in legislation, government guidance and housing-sector good practice. We use this information to strengthen our approach where opportunities for improvement are identified.

Approval

This statement was approved by the Gentoo Group Board on 30 September 2026.