Modern Slavery Statement

This statement follows section 54 of the Modern Slavery Act 2015 and is for the financial year ending March 2024.  It applies to Gentoo Group Limited, our subsidiaries, contractors and supply chains.

Overview

We have a zero-tolerance approach to modern slavery and do not tolerate it in any part of our business, including our supply chains. We have policies and procedures in place to reduce the risk of modern slavery in all parts of our business.

We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains and we expect the same high standards from all of our contractors, suppliers and other business partners.

Modern slavery includes:

• slavery
• human trafficking
• forced labour
• domestic servitude

We deal with any form of modern slavery as a high priority.

Our structure and business

Gentoo Group is the parent of Gentoo Group Limited and its subsidiaries.

Gentoo Homes is a subsidiary of Gentoo Group Limited and is a profit-for-purpose business. Profit is reinvested back into Gentoo.

We are a housing association and own or manage more than 29,500 properties. We are one of the largest employers in Sunderland and landlords in the North East.

We put people first so we can:

• build great homes
• create strong communities
• inspire people
• focus on giving our customers an outstanding service

We work with important partners to make a difference for our colleagues and customers.

Our colleague  training

All our colleagues  complete safeguarding awareness training every year so they can recognise, respond and record anything that does not seem right. This helps us to protect adults and children.

All our colleagues  also complete Code of Conduct training when they start working for us and whenever the code is updated. This is so they know,  understand and apply our standards and expectations, which include:

• completing our roles in line with our social purpose
• behaving with integrity
• being professional and treating others well
• protecting ourselves, others and the environment

To reduce the risk of modern slavery among our customers, we train colleagues  who work with and visit customers to:

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

This includes:

• neighbourhood co-ordinators and support co-ordinators
• tradespeople
• inspectors and surveyors

We also train colleagues  who manage our relationships with contractors and suppliers to reduce the risk of modern slavery in our supply chain.

Modern slavery is part of our regularly updated safeguarding training that is mandatory for all colleagues. .

Our housing and safeguarding policies

These policies work alongside our training to reduce the risk of modern slavery among our customers. They help colleagues recognise signs of modern slavery and abuse and how to report it.

When a new customers  rents a property from us, we confirm who are the legal tenants and the members of their household. Neighbourhood Co-ordinators interact with and get to know their customers and make sure the property is not used for illegal activities, like human trafficking.

Our employee policies and code of conduct

We recognise modern slavery may affect people who work for Gentoo.

Employee policies

Our regularly audited human resources terms and conditions, policies and procedures help to reduce the risk of modern slavery among employees, contractors and suppliers. The terms and conditions, policies and procedures make sure:

• colleagues are treated with dignity and respect
• we follow employment legislation
• we prevent unethical working
• we ensure right to work and pre-employment checks are completed for all colleagues
• everybody receives fair pay
• all agencies and other bodies we use as part of our recruitment process have procedures to prevent modern slavery

Code of conduct

Everyone who works for Gentoo, including contractors and suppliers, sign and agree to follow our supplier code of conduct. This includes following relevant legislation like the Modern Slavery Act 2015.

The supplier code of conduct is adapted from our general code of conduct, which is based on the National Housing Federation code of conduct.

Whistleblowing Policy

We encourage anyone, including colleagues, subcontractors, suppliers and customers to report in good faith any issue or concerns about potential unethical business practices, such as fraud and bribery or slavery and human trafficking through our confidential external whistle-blowing hotline.

Reporting any suspected wrongdoing can be done via

our SafeCall process and Whilstleblowing Policy. For more information, read our Whistleblowing Policy (PDF, 294KB).

Our supply chains

We buy goods and services through a diverse supply chain, including:

• property-related services and materials, like developing, constructing and maintaining new and existing homes
• facilities management, like cleaning services
• information technology, like laptops and mobile phones
• recruitment agencies
• office equipment and supplies, like stationery

Contractor and supplier due diligence

We communicate our zero-tolerance approach to modern slavery with all contractors and suppliers. We do this from the beginning to the end of our contract with them. This helps to reduce the risk of modern slavery within our supply chains and people we do not directly employ.

Our Supplier Management Framework addresses all aspects of our suppliers’ due diligence. This includes their commitment to prevent modern slavery, which we review once a year and discuss in regular meetings.

We work with contractors who have Advanced or Elite accreditation under the Contractors Health and Safety Assessment Scheme. This makes sure that their commitment to preventing modern slavery has been assessed. Should contactors and suppliers fail to meet these standards then this could mean contract termination.

Effectiveness

We review our contractors’ and suppliers’ commitment to preventing modern slavery. We will either address any areas of concern or stop working with them.

Before we work with them again, we need to satisfy ourselves that their commitment to preventing modern slavery meets our zero-tolerance approach.