Modern Slavery Act Transparency Statement – FY2022
This is the Modern Slavery and Human Trafficking Statement for Keepmoat Homes Limited (“Keepmoat”) for the period 1st November 2021 – 31st October 2022 published in compliance with the Modern Slavery Act 2015 (the ‘Act’) within six months of our year end.
At Keepmoat, we are committed to improving our practices to eradicate the risk of slavery and human trafficking in our business and supply chain. We will uphold all laws relevant to the Modern Slavery Act 2015.
Scope
This statement has been produced in line with the Modern Slavery Act 2015. It describes the steps taken by Keepmoat against modern slavery.
The Chief Executive Officer is responsible for this statement. It was formally approved by the Executive Board on Monday 24th April 2023. The Supply Chain Director has operational responsibility in relation to Modern Slavery.
Organisation structure and supply chains
Keepmoat is a large, established house builder with a track-record of delivering quality homes across the UK. However, bricks and mortar are only one side of our corporate story. We’re also a business that is committed to helping communities thrive, improving local people’s lives and job prospects and protecting the natural world.
We achieve this through a partnership house building model that brings together local authorities, landowners, registered providers and local communities.
Keepmoat is made up of nine regional offices. These operate on a regional empowerment model, with key systems being set centrally.
We have appropriate policies in place that underpin our commitment to take steps to manage the risk of modern slavery or human trafficking in our supply chains or in any part of our business. We continuously review and update all our policies. Our Anti-slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.
We understand that the following areas give rise to the highest modern slavery risks, especially in construction:
- Little visibility over lower tier suppliers who are not regulated.
- Reliance on a workforce to carry out jobs that are considered low skilled labour
- Potential for materials to come from high-risk countries
As part of our initiative to identify and mitigate risk we implement due-diligence processes for our Employees, Subcontractors, Temporary Works and Material Supply Chain.
We also have in place systems to:
- Identify and assess potential risk areas in our supply chains.
- Mitigate the risk of slavery and human trafficking occurring in our supply chains.
- Monitor potential risk areas in our supply chains.
- Protect whistle blowers.
We have a dedicated working group that supports compliance with our Modern Slavery obligations and policies, which consists of the following representatives:
- General Counsel & Company Secretary
- Director of Audit
- Compliance Manager
- Supply Chain Director
- Head of Sustainability
- Commercial Development Director
Policies and guidance
Keepmoat has a Modern Slavery Policy in place. All staff are required to read the policy and act in accordance with it. Modern Slavery posters are available to download by site managers across all Keepmoat sites. These inform staff how they can spot Modern Slavery red flags and how to report these.
We ask all members of staff to be vigilant of signs of Modern Slavery both within our business and in our supply chain. Keepmoat’s Whistleblowing Policy requires staff to report any suspicion that Modern Slavery is occurring in our business or within our supply chain. We have refreshed the whistleblowing posters to encourage reports and have identified modern slavery as a relevant area on these. Anonymous reports are accepted. Safecall, our independent Whistleblowing service, is available 24 hours a day, seven days a week. We have had no instances of whistleblowing regarding Modern Slavery in the reporting year.
Keepmoat wishes to work with partners who share our commitment to preventing Modern Slavery. To make sure this happens, anti-Modern Slavery clauses are included in our sub-contractor and supplier contracts. We also survey members of our supply chain to verify their knowledge of and adherence to the requirements of the Modern Slavery legislation.
Due diligence processes
Keepmoat undertakes due diligence for the key Modern Slavery risk areas identified by our assessment.
The key controls in each of these areas are:
Employees:
- Modern Slavery policy
- Right to work checks
- Whistleblowing policy
- Modern slavery training
Temporary Workers:
- Right to work checks (by Retinue)
- Modern slavery clause in agency contract
Subcontractors:
- Requirement to establish a suitable Modern Slavery Policy (or adopt Keepmoat’s)
- CHAS premium used by subcontractors to upload their Modern Slavery Policies
- Modern slavery clauses in our T&Cs
- GoContractor – identity checks
Materials Supply Chain:
- Requirement to establish a suitable modern slavery policy (or adopt Keepmoat's)
- Desktop audit of suppliers via Achilles
Risk assessment and management
Keepmoat carries out an annual risk assessment of its exposure to Modern Slavery. The latest review in March 2022 looked at the risks through the following lenses:
- Internal
- Indirect
- Materials
- Sub-contractors
- Facilities management
Keepmoat has determined our overall Modern Slavery risk as low on the basis that we have implemented significant steps to promote overall awareness and due diligence in regard to Modern Slavery across the business, including in our supply chains and our contractors. This is supplemented by external service providers providing tools to carry out due diligence and risk assessments on our sub-contractors and supply chain.
Key performance indicators
Keepmoat reviews its performance against preventing modern slavery on an annual basis. We use the following key performance indicators (KPIs) to measure how effective we have been in ensuring that Modern Slavery and human trafficking are not taking place in any part of our business or supply chain:
- Proportion of supplier frameworks with an appropriate Modern Slavery Policy in place;
- Number of key material suppliers audited;
- Number of suspected incidents of Modern Slavery reported; and
- Proportion of staff who have completed the Modern Slavery e-learning programmed assigned to them.
Training and awareness on modern slavery and trafficking
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our staff. Keepmoat offers a suite of e-learning modules dedicated to Modern Slavery. These inform staff of what Modern Slavery is, how to recognise when it might be taking place, and what to do if you suspect Modern Slavery. All staff are required to complete these modules.
Keepmoat has joined the Supply Chain Sustainability School which gives key staff access to a range of training that covers Modern Slavery. These materials have also been made available to other companies in our supply chain.
Signed by:
Tim Beale - Chief Executive
