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This statement on slavery and human trafficking is made pursuant to section 54 of the Modern Slavery Act 2015 (UK).
This statement is made on behalf of Hillcrest Homes (Scotland) Limited and its subsidiary companies. It is reviewed and updated on an annual basis and approved by the Governing body. It is published on our website.
Hillcrest recognises it has a responsibility to take a robust approach to slavery and human trafficking and is committed to preventing this in all its activities.
This statement was approved on 28 March 2023.
We have zero tolerance to slavery and human trafficking. To identify and mitigate risk, Hillcrest carry out due diligence on new suppliers as part of the procurement process.
Procurement activity includes the completion of the Standard Procurement Document (SPD) issued by the Scottish Government. The SPD (Scotland) is a standard questionnaire that allows buyers to identify suitably qualified and experienced bidders. It contains questions on both exclusion and selection criteria.
Bidders will use their SPD response to indicate whether their organisation meet the requirements of the procurement exercise. The form is a self-declaration form and suppliers do not need to provide any evidence in advance unless there are clear reasons for doing so. Once selection has taken place, evidence is obtained to ensure compliance with the Modern Slavery Act 2015. Any suppliers who declare that they do not comply with the legislation will be excluded from the procurement process. When procuring goods and services, we apply Hillcrest terms and conditions which requires suppliers to comply with legislation.
Hillcrest will assess any evidence of non-compliance with any part of the organisation by one of our suppliers and take appropriate action.
Hillcrest follows a robust approach in recruiting its workforce. We communicate directly with all candidates to confirm details of any offer made. Procedures are in place to confirm identities to ensure the right to work in the UK. Any employee or worker with a work permit or visa, regular audits and management of these documents is undertaken to ensure they remain valid.
An accredited living wage employer, all employees are paid the Scottish living wage or above.
When using employment agencies, we use specific reputable companies to source workers and verify their practices in the first instance.
We will ensure that relevant sections of our workforce understand the risk to the business from slavery and human trafficking and are equipped to identify and respond in situations where they have concerns.
All new employees are required to complete an induction which includes information and training on company policies.
A new E-learning module was designed in respect of Fraud Training in 2021
The organisation’s Code of Conduct specifies the behaviours and actions required of employees when representing any of the Hillcrest companies. We strive to maintain the highest standards of employee conduct and ethical behaviour at all time. This is supported by the Scottish Federation of Housing Associations Code of Conduct for employees and board members, and also the Scottish Social Services Council code of practice for health and social care workers.
Hillcrest Homes is committed to fair working practices, which are underpinned by our accreditation as a Gold Investor in People, Investor in Young People and Investor in Wellbeing. Ongoing assessment is a requirement of these accreditations which ensures best practice is progressive, relevant and proportionate.
As well as adopting policies and statements which support the development of a positive and inclusive working environment, we have the following in place to meet each of the Fair Working Practices criteria: