Introduction
This statement is made pursuant to s.54 of the Modern Slavery Act 2015. St John and St Anne’s (SJSA) is committed to acting ethically, with integrity and transparency in all professional dealings, and to having effective systems, processes, and controls in place to safeguard against any form of modern slavery taking place within our charity or our supply chain.
We are committed to identifying any potential modern slavery risks related to our charity and to put in place steps aimed at minimising the risks of modern slavery or human trafficking in our charity and supply chains.
As a Registered Housing Provider, SJSA recognises our duty to help combat modern slavery and human trafficking.
SJSA has raised awareness of this Policy by:
- Circulating to all staff, governors and also our suppliers and contractors.
- Including modern slavery and human trafficking awareness into our induction and training procedure
- Highlight modern slavery and human trafficking issues in our staff meetings
- Publishing our annual statement internally as well as externally
Modern slavery is defined as the recruitment, movement, harbouring or receiving of people using force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation.
Slavery and forced labour (as defined by Article 4 of the Convention on Human Rights) are treated as offences and we recognise, in determining whether ‘slavery’ or ‘forced labour’ situations exist, that account must be taken of all the circumstances of the case including the vulnerability of the individual.
Human trafficking is a form of modern slavery and is the movement of people by means such as force, fraud, coercion, or deception, with the aim of exploiting them. Human trafficking does not always involve international transportation, and includes commercial, sexual, and bonded labour.
Criminal exploitation is a lesser-known type of modern slavery and human trafficking that encompasses acquisitive crimes such as forced begging, forced theft (including shoplifting and pickpocketing), as well as cannabis cultivation and financial exploitation.
We are aware that slavery, servitude, forced labour and human trafficking (modern slavery) is a growing issue globally, existing in all economies from developing to fully industrialised and in all sectors.
No sector or industry can be considered immune or untainted and we have a moral, as well as legal, duty to do what we can to ensure that we are not complicit, as far as we can reasonably do so.
We recognise the responsibility to be alert to the risks within our Charity and within our
supply chain – our contractors, sub-contractors, and other suppliers. We have a zerotolerance approach to modern slavery within the supply chain.
We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our supply chains or in our charity. Staff are expected to report concerns, using the appropriate reporting channels, and management are expected to act upon them.
Policies: We have relevant policies in place, such as safeguarding, whistleblowing, health & safety and procurement. Policies are reviewed on a rolling basis in response to longevity, audit, statutory or regulatory change.
Risk assessments: We assess business risks, including those associated with modern slavery and human trafficking, with the Chief Executive assuming overall responsibility.
Investigations/due diligence: The Chief Executive is responsible for investigating any suspected instances of modern slavery and human trafficking. To date, no instances have been highlighted which require investigation.
We will continue to review our supply chain and ensure our procurement processes are managed appropriately. We understand that modern slavery risk is not static, and we will aim to align our policies and procedures on modern slavery and human trafficking with best practices and changes in legislation.
This policy will be reviewed annually or sooner is legislation changes.
Next review date: 2026
