Modern Slavery

Modern Slavery and Human Trafficking Statement

Elm Tree Housing is committed to ensuring our practices combat slavery and human trafficking. This statement for the financial year ended 31 March 2024 sets out the steps that Elm Tree Housing and its wholly owned subsidiary companies have taken in the last year to ensure modern slavery is not taking place in our business or supply chains and is made pursuant to Section 54 of the Modern Slavery Act 2015.

This statement covers Elm Tree Housing and its wholly owned subsidiaries (the “Group”) as set out below:

Elm Tree Housing, a Community Benefit Society and a Registered Provider of housing regulated by the Regulator of Social Housing.
Elm Tree Development Homes Limited, a wholly owned subsidiary of Elm Tree Housing concerned with the construction of new homes for outright sale.
Elm Tree Repairs Limited, a wholly owned subsidiary of Elm Tree Housing. Elm Tree Renewables is a trading name of Elm Tree Repairs Limited and is an installer of renewable energy technologies which would otherwise be ultra vires for Elm Tree Housing.
Elm Tree Devco Limited, a wholly owned subsidiary of Elm Tree Housing that provides development services to Elm Tree Housing.

The Group operates within the social, affordable, private sale, and market rent housing sectors and provides some commercial services. Elm Tree Housing develops, owns, and manages properties within London and Surrey, and, as a Registered Social Landlord, is a contracting authority subject to the Public Contract Regulations 2015.

The information below describes the systems and controls that have been put in place in the last year to minimise modern slavery and human trafficking from occurring in our operations, supply chains, and communities.

Due Diligence Measures
Elm Tree Housing’s tendering processes follow best practice and, when seeking new suppliers, bidders are required to provide details of their own modern slavery statement or confirm adherence to ours if their turnover is below the relevant threshold. We provide a factsheet for below-threshold suppliers to help them proactively take steps to avoid modern slavery practices. This factsheet explains what modern slavery is, their obligations as suppliers, and operating categories considered to be particularly high risk.

We only engage with suppliers and contractors who confirm compliance with the Modern Slavery Act 2015 (the “Act”). All new contracts include a clause requiring our suppliers and their subcontractors to comply with the Act. If a supplier breaches this obligation, Elm Tree Housing reserves the right to terminate the contract.

We also require any new works contractors to confirm their commitment to our Contractors’ Code of Conduct and carry out checks of third-party suppliers. To date, no issues have been brought to the attention of the Procurement Team.

Elm Tree Housing uses only specified, reputable employment agencies to source labour and always verifies the practices of new agencies before accepting workers from them. These agencies are managed centrally by the People Team to ensure appropriate controls are maintained. We also carry out checks of all new employees’ Right to Work in the UK.

Training and Awareness
Every new member of staff undertakes mandatory training on the Safeguarding Policy, and there is a Modern Slavery Course available on the iLearn portal. The Safeguarding training includes awareness of specific safeguarding risks that may occur in social housing. Refresher training will take place annually for all staff.

This document constitutes our current Modern Slavery & Human Trafficking Statement and has been approved by the Board, who will review and update the statement annually.