Believing in accessibility for all

Modern slavery statement 2021 - 2022


Wolverhampton Homes (WH) must ensure that all potential modern slavery risks related to its business are understood and that steps are in place that aim to ensure there is no slavery or human trafficking in its own business and, its partners and supply chains. WH is further committed to making sure that properties are not used to accommodate the work of human traffickers or to detain others against their will.

This statement is made under section 54 (1) of the Modern Slavery Act 2015 (MSA) and refers to the financial year ending 31 March 2022 and received approval from the Board in March 2022.

WH acknowledges its duty to notify the Secretary of State of suspected victims of slavery or human trafficking as introduced by section 52 of the Modern Slavery Act 2015.

Structure and supply chain

WH is an Arm's Length Management Organisation (ALMO) responsible for managing the majority of council homes in Wolverhampton.

WH want to help make Wolverhampton a better place to live. WH want to provide great homes in clean, safe neighbourhoods where customers can access training, skills, and job opportunities. 

WH partners and supply chain consist mainly of services rather than goods, with the highest risk areas being associated with our repairs and maintenance activities. WH do not have any supply chain outside of the United Kingdom. All suppliers of our services are obtained through a procurement process (via a service level agreement with the City of Wolverhampton Council) that requires all contractors to comply fully with the Modern Slavery Act 2015.We have an approved list of contractors and suppliers that we work with and our purchase order payment system requires the use of pre-approved suppliers.

Due diligence processes

Chief Executive:

Responsibility for compliance rests at the highest level with our Board, with responsibility delegated to the Chief Executive.

Senior Leadership Team:

The Senior Leadership team are responsible for assessing risks associated with modern slavery and human trafficking within their areas of responsibility.

First Responder:

WH have a statutory ‘Duty to Notify’ the Home Office when they come across potential victims of modern slavery. This duty is discharged by either referring a potential victim into the National Referral Mechanism (NRM) where they are a child, or consenting adult, or by notifying the Home Office where an adult does not consent to enter the NRM.

A First Responder Organisation is (in England and Wales) an authority that is authorised to refer a potential victim of modern slavery into the NRM.

For Wolverhampton Homes, the First Responder Organisation (Adult and / or Children’s Social Care) is at the City of Wolverhampton Council (CWC) through a MARF (children) or SA1 (adults) referral.

Supply Chain:

We expect our partners and suppliers to share our values on modern slavery and carry out their own due diligence on their own supply chains, to limit the risk of modern slavery taking place. All suppliers of our services are obtained through a procurement process (via a service level agreement with CWC) and forms part of the Condition of Contract that requires all contractors to comply fully with the Modern Slavery Act 2015. CWC also proactively vet the supply chain to ensure no instances of modern slavery are taking place.


The tendering of new contracts includes an obligation for suppliers to comply with the Modern Slavery Act. CWC, who are responsible for the procurement of goods and services for WH, is also a signatory to the Charter Against Modern Slavery. This goes further than existing law and guidance, committing councils to proactively vetting their own supply chain to ensure no instances of modern slavery are taking place.

Tenancy Management:

All applications for properties at WH are checked to ensure accuracy of the information supplied by an applicant.

People Services:

We are not exposed to a high risk of recruiting employees who may be subject to human trafficking, however our recruitment process ensures that all potential employees are checked to ensure they are eligible to work in the UK and carrying out the necessary pre-employment checks such as DBS (Disclosure and Barring Service), references and qualifications.

WH safeguarding and modern slavery awareness training will be provided to ensure that all staff have an awareness and understanding of their role.

Employees and Line Managers:

All employees are encouraged to report any concerns about a person or property to their line manager. Any suspected instances or concerns on modern slavery or trafficking will be reported to the First Responder through a Multi-Agency Referral Form (MARF) (children) or SA1 (adults) referral.

Business Services:

WH maintain a risk management register ensuring the effective identification, monitoring and management of risk across Wolverhampton Homes. Modern Slavery is one of the risks identified.


The primary method of monitoring effectiveness within the supply chain will be the

pre-qualification criteria for suppliers, which includes a requirement to have measures in place to minimise the possibility of modern slavery in their business and supply chain.

WH is represented on the Adults and Children's Safeguarding Board so can monitor any referrals that concern WH tenants or their families.

This statement will be reviewed annually in accordance with the Modern Slavery Act 2015 and published on WH’s website. It will also be included on the new government modern slavery statement registry.

Modern slavery policies

Our policies and procedures are reviewed regularly to make sure that they are fit for

purpose and compliant with regulatory and statutory obligations. Where required, new policies are agreed through the relevant governance structure and consultation with Trade Unions.

There are a number of policies and procedures in place that contribute to ensuring

modern slavery does not occur in the business. These include:

  • Employee Code of Conduct - a requirement for all staff to adhere to which
    includes requirements in relation to workplace behaviour and equality and
  • Anti-Fraud and Bribery Policy
  • Recruitment and Selection Policy - which includes the requirement to undertake DBS (Disclosure and Barring Service) and checks for eligibility to work in the UK.
  • Health and Safety Policy
  • Whistleblowing Policy and Procedure - which protects staff should they raise concerns about issues such as modern slavery.
  • Financial Regulations / Standing Orders
  • Tenancy Management policies - which set out the action to be taken where our properties are used for unlawful purposes.
  • Domestic Abuse Policy
  • Safeguarding procedures
  • Statement on Equality and Diversity

Further information on Modern Slavery and associated guidance documents can be found on the Safer Wolverhampton website.