Modern Slavery & Human Trafficking Statement 2024/25
Modern Slavery & Human Trafficking Statement 2024/25
Settle provides services to more than 24,000 residents in over 10,000 homes in neighbourhoods across Hertfordshire, Bedfordshire, Buckinghamshire and South Cambridgeshire. Our purpose is to give residents a firm foundation on which to build their lives, with our 2030 vision to provide a safe, comfortable and affordable home for every household.
We are a Co-operative & Community Benefit Society, with charitable objectives, set up to serve the broader interests of the community. As an organisation whose purpose is to improve the lives of our residents, we are committed to taking all reasonable steps to prevent slavery and human trafficking as required by the
Modern Slavery Act 2015 (“the Act”).
This statement sets out how we deliver against that commitment.
Strategies, Policies and Procedures
As an equal opportunities employer, we are committed to creating and ensuring a non-discriminatory and respectful working environment for our colleagues. We want all our colleagues to feel confident that they can expose any wrongdoing without any risk to themselves.
Settle has a number of strategies, policies and procedures in place that help detect and prevent slavery and human trafficking:
- Recruitment and people management procedures, which are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
- An Equality, Diversity and Inclusion Policy to ensure we are a diverse and inclusive business where customers and colleagues are treated with respect, fairness and empathy.
- Strategies, policies and procedures covering Settle’s approach to adult and children’s safeguarding;
- Settle’s Code of Conduct, which all colleagues are required to adhere to. This includes sections against bribery and corruption as well as expectations around general workplace behaviour;
- A Speak Up Policy that protects colleagues and contractors from any issues arising from making a
- report in good faith; and
- A Procurement Policy, and clear procurement processes that require assurances from third party partners are not, and never have been, in breach of the Modern Slavery Act.
Supply Chain
We do not knowingly support or deal with any business involved in slavery or human trafficking.
In our selection of service providers, we request they confirm whether they are a relevant commercial organisation as defined by section 54 (“Transparency in supply chains etc.”) of the Act and if so, that they are compliant with the associated annual reporting requirements.
In our procurement contracts, we explicitly ask that service providers confirm that current and former directors, officers and colleagues have not and shall not engage in activity which would amount to a breach of the Act or place Settle in breach of the Act. We seek confirmation that they maintain and implement procedures to ensure compliance with Modern Slavery Legislation.
Training our colleagues
Our learning and development programme includes a focus on strategies like adult and children’s safeguarding; recognising our commitment to ensuring all colleagues can identify the potential signs of slavery or human trafficking. Onboarding of new colleagues includes a focus on our recruitment practises and a Code of Conduct that emphasises the importance of ethical conduct and compliance with applicable laws and regulations.
Measuring effectiveness
- We ask all colleagues to review and sign the Code of Conduct on an annual basis or as part of the new starter process.
- We ensure we obtain right to work documentation; no offer is sent until we have confirmation of this.
- We are committed to building robust supplier relationships and through effective supplier management.
- We will ensure, where possible, that our supply chains are completely ethical and sustainable.
- We have mandatory training for safeguarding; this is either e-learning or classroom attendance. We review compliance on an annual basis.
- Key Performance Indicators (KPIs) are set for each contract, and supplier performance is measured against these KPIs to ensure effectiveness and highlight the need to intervene where appropriate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group Modern Slavery and Human Trafficking Statement for the 2024/25 financial year.
This statement is approved by the Settle Board and also applies to subsidiaries within the Group. It will continue to be reviewed and updated as necessary or, as a minimum, on an annual basis.
Sally Veitch
Settle Board Chair