Preventing Modern Slavery
Modern Slavery Statement
Our Company Values reinforce our commitment to preventing modern slavery. Particularly, the “We care” and “We make it happen together” values describe how we interact with each other and by extension, our supply chain.
The statement below is made pursuant to Section 54 of the Modern Slavery Act 2015 and explains the steps that Efficiency North Holdings Limited (ENHL) Group have undertaken to ensure that there is no slavery or human trafficking within our organisation, our contractors, partners, operating companies and supply chains.
ENHL is committed to identifying and mitigating all potential modern slavery risks and will continue to take a robust approach and regular reviews of all relevant policies and practices when it comes to employees, suppliers and contractors.
ENHL structure and business and supply chains
ENHL is a group of companies that work to deliver on the vision of bringing together social housing providers and the construction industry to achieve the best value for communities in Northern England by providing futures, building homes and buying smarter to save time and money.
The ENHL Group comprises EN Procure Ltd, EN:Able Futures CIC, EN:Able Build Ltd and EN:Able Communities CIO.
ENHL is a not-for-profit organisation owned by its members. Its members are social housing providers based in the North of England – registered social landlords and local authorities. We provide frameworks and DPSs for the building and maintenance of properties and flexi-job apprenticeships mainly within the construction sector.
The organisation operates wholly in the United Kingdom.
ENHL procures a wide range of goods and services including and not limited to:
- Property development
- Repairs and maintenance
- Various professional services
- Agency staff
At ENHL we recognise the responsibility that we share with our suppliers, to buy materials and deliver our services in an ethical manner. As part of this commitment, we acknowledge our responsibility towards the Modern Slavery Act 2015 and will ensure transparency within the organisation and with our suppliers of goods and services to ENHL and its members. The standards outlined are applicable across the whole of the ENHL Group.
We want our members to be confident that our business partners treat their employees fairly, with respect for human rights and are not exposed to unsafe working conditions or in any way forced to work under slavery. We believe that when ethical standards are in place, this can improve worker well-being, productivity and quality, which benefits both our suppliers and our customers. Only contractors and suppliers who share our standards and values will be considered appropriate to trade with ENHL and its members and we seek to develop long-term trading relationships with our suppliers and contractors based on the principle of fair, open and honest dealings at all times.
Due diligence processes in relation to slavery and human trafficking in business and supply chains
Our procurement appraisal process will incorporate a review of the controls undertaken by our suppliers and will also require, from all suppliers, an annual statement of their commitment and actions taken to eliminate modern slavery.
Imported products sourced from outside the UK or EU are potentially more at risk of slavery or human trafficking issues. If products have to be sourced from such locations, we look to work in partnership with companies who possess certifications which have independently assessed standards that reinforce their commitment to human rights, working conditions and the provision of a living wage.
Suppliers are risk assessed on a timely basis, taking account of market/environmental changes to establish what further information and/or due diligence may be required to provide assurance that slavery or human trafficking is not taking place within the business or supply chains.
Our formal procurement process requires all prospective suppliers to confirm whether they comply with the Act. Where their turnover is above £36 million, they are asked to provide their annual statement together with evidence of compliance. Information on supplier subcontractors and overseas supplies in the supply chain is also obtained to help inform ENHL’s risk assessment.
ENHL Group will not work with any organisation that either has or is found to be knowingly involved within either human trafficking or modern slavery.
Identification of risks together with steps taken to prevent and manage that risk.
ENHL are committed to ensuring all employees receive fair remuneration for the work they perform and have job evaluated all its roles. ENHL is a Living Wage employer and have harmonised pay terms and conditions across the entire workforce.
Policies in relation to slavery and human trafficking
ENHL takes a zero-tolerance approach to human trafficking and slavery, in our supply chains or any other part of our business.
We have robust policies and procedures to ensure that its employees are not subject to undue influence and are treated with dignity and respect. Policies and procedures are regularly reviewed to ensure we are compliant with the most up to date employment legislation to prevent unethical working practices.
Policies and procedures include:
Whistleblowing Policy - The Confidential reporting procedure (whistleblowing procedure) - applies to all employees engaged by the Group. ENHL is committed to the highest possible standards of openness, probity and accountability. We encourage employees or others with serious concerns about any aspect of our work to come forward and express those concerns. It is recognised that most cases will have to proceed on a confidential basis. This policy makes it clear that you can do so without fear of victimisation, subsequent discrimination or disadvantage. This policy is intended to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace.
Safeguarding Policy/Procedure - The ENHL Safeguarding Procedure sets out our responsibilities procedure for raising a concern and referring. This procedure identifies the signs, advises you on how cases should be reported and recorded, acting promptly, proportionally and effectively.
Equality, Diversity and Inclusion Policy - The Equality, Diversity and Inclusion Policy recognises the responsibility that we share with our suppliers, to ensure actions to improve equality and diversity in their workforces and in allowing access to their services and goods.
Procurement – ENHLs approach to our procurement frameworks and DPS will continue to drive forward the key objectives of delivering economic, social and environmental benefits through procurement. It includes ethical standards as a core principle for procurement and acknowledges the important role that procurement plays in sourcing in a manner that ensures ethical standards are met, minimises the risk of social exploitation and rewards good employment practices.
Training and capacity building about slavery and human trafficking
All our employees are required to undertake mandatory learning to help recognise signs of slavery, human trafficking, forced labour and domestic servitude.
Tailored safeguarding training is delivered in line with our Safeguarding procedure which is supported by senior managers who are able to support further on this specific topic.
All training is produced and delivered in line with the basic principles of the Modern Slavery Act 2015:
- How employees and partners can identify slavery including warning signs and Indicators
- What employees and partners can do to raise awareness about potential slavery
- What external help is available and details of the National Referral Mechanism (NRM)
- What is the referral path and what local support is available.
Concerns may include:
- Safeguarding - where you feel a young person or vulnerable adult is being abused or is at risk of harm, neglect or exploitation
- Modern slavery and human trafficking.
The directors and senior management shall be responsible for the application of this policy and ensure all activity complies with the Modern Slavery Act 2015. ENHL will continue to utilise national and local resources, training and investment to ensure its successful application throughout the next financial year.
To seek advice or report suspicion of modern day slavery call the modern slavery helpline on 0800 0121 700 or visit www.modernslavery.gov.uk/start to report online.