Modern slavery statement
C&C is committed to fostering and ensuring an ethical approach in all our work, and expect our suppliers, partners and contractors to meet our standards. As a provider of social housing and care, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking.
This statement summarises the steps we are taking to minimise the risk of slavery or human trafficking in our business or our direct supply chains.
We are a registered provider of social housing and care for people over 55 in London. We work with a range of contractors and suppliers to manage our homes. As a housing provider with robust policies, we do not consider any areas of our business to be at high risk of slavery or human trafficking. However, we still take this very seriously and are working with our suppliers to reduce this risk even further.
- Our Board is responsible for ensuring relevant policies are regularly reviewed.
- Our People Team ensure we comply with legislation in recruitment
- Our Procurement Team ensure our suppliers have a robust approach to tackling modern slavery through our new supplier process
- Our Governance Team ensures relevant policies are adhered to.
- Our People Team ensures all our colleagues are appropriately trained.
We have a range of documents and processes to minimise the risk of slavery and human trafficking in our operations:
Whistleblowing policy: We encourage all our colleagues, customers and business partners to report any concerns about our activities or our supply chains. This includes risk of slavery or human trafficking.
Living our Values: Our values makes it clear to our employees the actions and behaviour expected of them. We strive to maintain the highest standards of employee conduct and ethical behaviour in everything we do.
New supplier process: This ensures all providers, where appropriate, have a modern slavery policy that outlines their approach to combatting this
Contractor code of conduct: We are committed to ensuring our suppliers meet the requirements of the Modern Slavery Act 2015. We work with our suppliers and we are developing a contractor code of conduct that will make clear our expectations. Serious violations of our Code of Conduct will lead to the termination of the contract.
Temporary workers: We only use reputable employment agencies to source temporary staff, and we verify the practices of any new agency we intend to use.
We undertake due diligence when taking on any new suppliers and regularly review our existing suppliers. We expect our suppliers to carry out their own due diligence of their suppliers / contractors.
Our due diligence and reviews include:
- Evaluating the modern slavery risks of each new supplier
- Conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking, where specific risks are identified
- We will report to Board if any cases of modern slavery are identified
- We will report to Board annually on our due diligence and contractor reviews
- We will review all relevant policies and processes
- Colleagues will be trained to identify and raise concerns about modern slavery
- New colleagues will receive induction training for combating modern slavery
- All colleagues will receive an annual update on the Modern Slavery Act 2015
- We require all procurement and contract management staff to complete awareness training on modern slavery
Our modern slavery training covers:
- How we identify the signs of slavery and human trafficking
- What initial steps should be taken if slavery or human trafficking is suspected
- How to escalate potential issues to the relevant parties
- What external help is available
- What steps we will take if suppliers do not meet our Contractor Code of Conduct.
As well as training our colleagues, we'll be including briefings on modern slavery in our internal communications in order to raise awareness.
This statement was approved by our Board on 22nd April 2021
They will review and update this annually.