Section 54 of the Modern Slavery Act 2015 requires larger employers, those with a minimum turnover of £36 million, to produce a modern slavery statement for each financial year.
The Jigsaw Homes Group (’the Group’) has a turnover of £190m, employs over c1,300 staff and manages more than 36,000 homes located in the North West of England and the East Midlands. The Group’s business is primarily the provision of social housing and associated services:
- Management and letting of properties
- Development of new homes
- Repair and maintenance of housing stock and estates
- Revenue collection
- Money and welfare advice
- Charitable donations to individuals and groups
- Supporting victims of domestic abuse
- Supporting vulnerable and/or client groups from disadvantaged backgrounds.
The Group and its subsidiaries trade only in the UK and not in any countries where the Group considers there to be a high risk of trafficking and modern slavery.
Following the closing of the accounting period April 2022 to March 2023 the Group’s Modern Slavery Statement is set out below.
The Group is absolutely committed to preventing modern slavery and human trafficking in its activities and to ensuring that our supply chains are free from modern slavery and human trafficking, and we will put in place arrangements to ensure there is no modern slavery or human trafficking in our own services or in our supply chains.
This statement is approved by the Group Board.
The Executive Management Team (EMT) is responsible for overseeing anti-slavery initiatives, led by the Deputy Chief Executive & Group Company Secretary.
The Group’s managers have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them are given adequate and regular training on the issue of modern slavery.
The prevention, detection and reporting of modern slavery in any part of the Group’s business or supply chains is the responsibility of all those working for the Group or under its control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains at the earliest possible stage.
The Group’s zero-tolerance approach to modern slavery will be communicated to all suppliers, contractors and business partners at the outset of the business relationship and reinforced as appropriate thereafter.
The Group may terminate its relationship with individuals and organisations working on our behalf if they breach this policy.
The Group actively manages risk in line with its Risk Management Policy. The Group has determined that there are no areas of its business that are considered to be at high risk of slavery or human trafficking.
We maintain a comprehensive risk management framework and work closely with our Internal Auditors (TIAA).
Complementary policies are:
- Safeguarding
- Health and Wellbeing
- Financial Regulations
- Terms of Reference and Scheme of Delegation
- Recruitment and Selection
- Equality and Diversity
- Probity, Anti Fraud and Whistleblowing
- Employee Handbook
- Governance Handbook
The Group will require new employees to produce original document evidence of their right to work in the UK prior to the commencement of their employment.
The Group uses employment agencies only by exception and when it does will only use specified, reputable employment agencies.
The Group has a Probity, Anti Fraud and Whistleblowing Policy to ensure that employees may raise concerns without fear of reprisal.
The nature of our work means we engage with a diverse range of private and public sector organisations from local authorities, NHS trusts and the police to local and national businesses and tradespeople. The Group will mandatorily exclude working with any organisation or individual that has been convicted of an offence under the Modern Slavery Act 2015.
The Group’s approach to procurement is documented in its Financial Regulations. The Group is committed to ensuring that those who work with it adhere to the highest standards of ethics. Contractors and suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, act ethically and within the law in their use of labour and supply chains. Where appropriate our internal auditors will work with contractors and suppliers to ensure that we are only operating with those who fully comply with this statement.
Jigsaw Homes Group will undertake due diligence when considering the appointment of a new contractor or supplier, and regularly reviews its existing approved contractor list. This due diligence and review process evaluates the modern slavery and human trafficking risks of each contractor or supplier, and conducts assessments that focus on the contractor or supplier’s financial stability, insurance cover arrangements and compliance with various employment policies. A greater degree of focus is applied on modern slavery and human trafficking where general risks are identified.
The Group will invoke sanctions, including the termination of any business relationship, to contractors or suppliers who, within a timescale specified by the Group, fail to satisfactorily address any modern slavery concerns. Where the Group is of the opinion that working or supply chain practices significantly contravene this policy then it will terminate a business relationship immediately.
By the nature of its work the Group recognises that its employees and contractor operatives will play a fundamental role in identifying any suspicions of human trafficking or modern slavery. All employees receive mandatory annual training on modern slavery and the Group operates a ‘concern card’ procedure to enable the reporting of suspicions.
This procedure brings to the attention of the relevant Neighbourhood Safety Managers in the Group any modern slavery or safeguarding concerns. The Neighbourhood Safety Manager will determine an appropriate course of action in response to the ‘concern card’. The Group has strong links with other agencies through its participation in multi-agency community safety partnerships and safeguarding arrangements with the relevant local authorities where it has housing stock.
Employees or contractor operatives may also contact the police directly regarding any suspicions regarding those who are committing such crimes, or where victims are at an immediate risk. Suspicions may also be reported to the Modern Slavery Helpline on 08000 121 700, Crimestoppers on 0800 555 111 or the Group’s Deputy Chief Executive & Group Company Secretary.
There were no reports of human trafficking or modern slavery concerns were received in the financial year 2022-23.
Our aims for 2023-24 are to:
- Issue annual E-learning to all employees;
- Continue to raise awareness through participation in national campaigns;
- Continue to raise awareness of ‘concern card’ processes for contractor operatives;
- Respond and adapt policy to updates issued from the Modern Slavery Contact Database.
This policy and statement will be reviewed annually by the Group Board and published on the Group’s website and the Government modern slavery registry.
This policy and statement will be reviewed annually (September) by the Group Board and published on the Group’s website and the Government modern slavery registry. The responsible officer is Brian Moran, Deputy Chief Executive & Group Company Secretary.
- Jigsaw Homes Group Limited. Registered as a Community Benefit Society with FCA. Registration number: 29433R. Housing Regulator registration number: LH4345
- Jigsaw Homes North. Registered as a Community Benefit Society with FCA. Registration number: 16668R. Housing Regulator registration number: LH0131
- Jigsaw Homes Midlands. Registered as a Community Benefit Society with FCA. Registration number: 8378. Housing Regulator registration number: L4532
- Jigsaw Support. Registered as a Community Benefit Society with FCA. Registration number: 8241.
- Jigsaw Homes Tameside. Company number 3807022. Charity Commission number 1146435. Housing Regulator registration number: LH4266
- Cavendish Property Developments Limited. Company Number: 8166437
- Jigsaw Treasury Limited. Company Number: 12535831
- Jigsaw Funding PLC. Company Number: 13888642
- Palatine Contracts Limited. Company Number: 4056290
- Snugg Properties Limited. Company Number: 11052396
- The registered office address for the above companies is Cavendish 249, Cavendish Street, Ashton-under-Lyne, OL6 7AT.
