Modern Slavery Policy

Policy Purpose

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human
trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Derby Homes Limited has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Derby Homes are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.

We expect the same high standard from all our contractors, suppliers and other business partners. Employees carrying out procurement activities on behalf of Derby Homes are required to ensure before engaging any service provider that the company being employed has rigorous policies and procedures in place to prevent any form of modern slavery within any part of its own organisation and any other organisation they employ on behalf of Derby Homes.

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, Board Members, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee's contract of employment and we may amend it at any time.

Responsibility for the Policy

• The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. 
• The Managing Director has 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 understand and comply with this policy.
• Derby Homes will arrange adequate training on the issue of modern slavery in supply chains. 
• You must ensure that you read, understand and comply with this policy. 
• The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
• You must notify your line manager, the Company Secretary or report it in accordance with our Whistleblowing Policy as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future or a breach of this policy has occurred.
• You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.
• You should note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains.
• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your line manager or Head of Service.
• We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
• We are committed to ensuring no one suffers any detrimental treatment as a
  result of reporting in good faith their suspicion that modern slavery of
  whatever form is or may be taking place in any part of our own business or in
  any of our supply chains. Detrimental treatment includes dismissal,
  disciplinary action, threats or other unfavourable treatment connected with
  raising a concern.
• If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the current employee handbook.

Communication and Awareness of this Policy

Training on this policy, and on the risk our business faces from modern slavery in its supply chains will form part of the induction process for all individuals who work for us, and updates will be provided using established methods of communication between the business and you. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. 

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.