Slavery and Human Trafficking Statement 2022
The Slavery and Human Trafficking Statement (“the Statement”) is made in accordance with section 54 (1) of the Modern Slavery Act 2015 by Inland Homes plc and each of its group companies for the financial reporting year to 30 September 2021. Inland Homes plc has a zero- tolerance approach to modern slavery with our business operations and supply chain. In this Statement, we set out our approach to meeting the requirements of the Modern Slavery Act.
2. Our business
Inland Homes is an established brownfield developer, housebuilder and regeneration specialist focused on the South and South East of England. Our land portfolio, which is in excess of 10,000 plots, has an estimated gross development value of £3.0bn and we have more than 1,500 homes under construction.
The Group directly employs approximately 149 people, working primarily in technical, site-based roles but also in support functions.
Our supply chain includes infrastructure and construction contractors, sub-contractors, consultants and professional service advisors. We also work closely with a range of stakeholders including housing associations, housebuilders, funders, local and planning authorities, regulatory bodies, Homes England and joint venture partners.
The activities of the Group and its joint ventures are undertaken solely in the United Kingdom and all the Group’s companies and joint ventures have their registered office in England. Inland Homes plc is an AIM-listed organisation.
3. Our policy
The Group regularly reviews it policies and procedures to ensure they remain appropriate. The following policies support our approach to compliance with the Modern Slavery Act and review is mandatory for all staff.
The Group’s Anti-Slavery and Human Trafficking Policy has been implemented across our supply chain and to staff. This includes training, visual awareness (digital and on site), induction package and Construction Skills Certification Scheme (CSCS) card check, and ongoing monitoring. Further refinement of the Policy will continue through 2022.
Through our sustainable procurement policies, we set out our commitment to specify sustainable materials and work with supply chain partners that demonstrate a high regard for, and promote, social responsibility. Our Sustainable Procurement Strategy is explicit in the requirement for all members of our supply chain regardless of size, to work to ensure modern slavery does not occur in their supply chain.
4. Risk assessment and due diligence process
We are conscious that the risks of modern slavery within any supply chain are significantly increased as a result of the global economic conditions following COVID-19 and as a result of the war in Ukraine.
As part of our continuous improvement approach to operations, we have introduced new software that allows us to analyse our suppliers and subcontractors more effectively to ensure they are not engaged with modern slavery or labour exploitation practices.
We engage with all current and future suppliers to ensure their approach to preventing modern slavery is in line with our expectations and those of the legislation in place. We have secured a digital bridge with Constructionline, who audit our sub-contractors’ compliance with the Modern Slavery Act amongst other legislation on our behalf.
The process is documented within the Standard Operating Procedures which forms part of the Quality Management System (QMS) process. It allows us to understand our supply chain, where it sources its labour from and how that labour is treated.
5. Training and staff awareness
Our employees are aware that Inland operates a zero-tolerance approach to modern slavery in our business and supply chains. Mandatory modern slavery awareness training is provided to all employees, supported by annual refresher training.
The Group’s Whistleblowing Policy sets out a robust approach to reporting concerns about the existence of modern slavery in our business and supply chain and protects staff in that regard.
Inland Homes is a signatory to the Gangmasters & Labour Abuse Authorities Construction Protocol which is a joint agreement aimed at establishing collaboration within the construction industry. The Protocol commits signatories to work in partnership to protect vulnerable workers, share information to help stop or prevent exploitation and commit to raising awareness within the supply chain.
6. 2022 objectives
- The Sustainability Working Group will continue to focus on the risks presented by modern slavery to the Group and our supply chain as part of its work. The Modern Slavery element will continue to ensure a consistent approach to risk assessment and due diligence throughout the organisation. The Group will also ensure that all polices, and procedures are in line with the required legislation and implemented across the Group.
- Continue our engagement with the Gangmasters & Labour Abuse Authorities Construction Protocol.
- Expand our engagement with Stronger2gether, which is a multi-stakeholder initiative set up to support construction companies in tackling modern slavery, providing a safe platform and support network for sharing challenges and good practice with peers and experts. Having built the Stronger2gether resources into a foundation level strategy, we will now expand use of the Stronger2gether resources available and give due consideration to becoming a partner in the group.
- With an increasing property portfolio, we recognise the importance of monitoring “on- site” activity by our employees and our suppliers, to mitigate against the risk of slavery or trafficking taking place on our sites, particularly those which are more remote. Our new visual awareness campaign and induction procedures will be in place across all Inland sites by the end of 2022 and a rolling programme of modern slavery training will be implemented.
7. This Statement and the associated polices remain subject to annual monitoring and review.
CEO and Board Member
Inland Homes 2022