Modern Slavery Act Transparency Statement – FY2021
Keepmoat aims to conduct all its business in an honest and ethical manner and are committed to preventing modern slavery. 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 Homes Limited against modern slavery.
The Chief Executive Officer is responsible for this statement. It was formally approved by the Executive Board on 9 May 2022. The Supply Chain Director has operational responsibility in relation to modern slavery.
Organisation structure and supply chains
Keepmoat Homes are a top 10 UK 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 unique partnership model that brings together local authorities, landowners, registered providers and local communities.
Keepmoat is made up of nine regional businesses. These operate on a regional empowerment model with key systems being set centrally.
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. This year we have added modern slavery posters to site set-up catalogue. 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 to 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 identified modern slavery as a risk area on these. Anonymous reports are accepted.
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. Of our 88 supplier frameworks, all have their own Modern Slavery policy. None have opted to adopt the Keepmoat Homes policy.
Due diligence processes
Keepmoat undertake due diligence for the key modern slavery risk areas identified by our assessment. The key controls in each of these areas are:
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
- Modern slavery policy
- Right to work checks
- Whistleblowing policy
- Modern slavery training Employees
- Right to work checks - retinue
- Modern slavery clause in agency contract Temporary Workers
- Requirement to establish a suitable modern slavery policy (or adopt Keepmoat's)
- CHAS premium - modern slavery clauses
- GoContractor - identity checks Subcontractors
- Requirement to establish a suitable modern slavery policy (or adopt Keepmoat's)
- Desktop audit of suppliers Materials supply chain
Keepmoat has calculated our overall modern slavery risk as low.
Key performance indicators
Keepmoat will review our performance against preventing modern slavery on an annual basis. We will consider the following metrics:
Training and awareness on modern slavery and trafficking
Keepmoat offer a suite of 3 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 have joined the Supply Chain Sustainability School which gives key staff access to a range of training which covers modern slavery. These materials have also been made available to other companies in our supply chain.
Tim Beale
Chief Executive Officer
Click here to view the Modern Slavery Act Transparency Statement FY20
