We recognise the detrimental effect modern slavery has on global society and we have adopted a zero-tolerance approach. We are committed to acting ethically and with integrity in all our business dealings and relationships to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
The Cottsway Group is proud of the steps we have taken to combat slavery and human trafficking and we are committed to improving our practices in this area.
This Modern Slavery Statement outlines the steps we have taken to eliminate this, as well as our approach during the 2022/ 2023 financial year, and the steps we will take in the future as far possible. It is made pursuant to section 54(1) of the Modern Slavery Act 2015.
We are a registered provider of social housing in England and we are the largest housing association in West Oxfordshire. We provide more than 5,200 homes for rent and shared ownership homes in the district as well as in Gloucestershire, Wiltshire, and Worcestershire. Our homes range from flats and bungalows to family homes.
We have around 165 employees providing services including:
The ultimate parent of Cottsway Group is Cottsway Housing Association. Cottsway’s subsidiary companies are Cottsway2, Cottsway Treasury Plc (dormant) and West Oxfordshire Housing (dormant).
The Group’s turnover for 2022/23 was £39.5m.
For more information about who we are, our vision and values, as well as our Board and Management Team, see: About us.
As a registered provider we do not operate extensive, worldwide supply chains. Due to this, we are able to build close relationships with suppliers who share our values and our commitment with regards to tackling slavery and human trafficking.
As part of our contracting processes we include specific prohibition against the use of:
We expect our supplies to hold their own suppliers to the same high standards.
All of our contracts are managed by individual contract managers and we believe we have a low risk of exposure to acts of modern slavery because:
We are, however, aware that construction work is more susceptible to modern slavery. To ensure all those in our supply chain comply with our values and our commitment to combatting modern slavery, we have in place a supply chain compliance programme. All our contracts are tendered in line with our Financial Regulations and Procurement Policy. Any suppliers we choose to work with undergo a comprehensive assessment process prior to appointment to ensure they meet our specific procurement criteria.
If we spend more than £1,000 per annum with a supplier, they must:
provide us with a copy of their Modern Slavery declaration (if their turnover exceeds £36m); or
agree to follow our Modern Slavery Statement (if their turnover does not exceed £36m).
If the supplier chooses not to do this, they will be excluded from our tender process and/or any work with us.
Our recruitment and people management processes ensure that all prospective employees are legally entitled to work in the UK and that staff are safeguarded from any abuse or coercion once in our employment.
If we use a recruitment agency, we will:
We are committed to ensuring that there is no modern slavery in our supply chains or in any part of the organisation. As part of this, we have introduced a Modern Slavery and Human Trafficking Policy which reflects our commitment in acting ethically and with integrity in all our business relationships.
Also, to support this we have the following policies in place:
As part of our initiative to identify and mitigate risk we have in place systems to:
We use the following performance indicators (PIs) to measure how effective we have been in ensuring that slavery and human trafficking is not taking place in any part of our organisation or supply chains:
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our organisation and our supply chains, all staff are required to complete the Modern Slavery Act e-training module. This includes:
During 2023-24 we intend to take the following further steps to combat slavery and human trafficking:
Approved by the Cottsway Group Board on 25 July 2023, and signed on its behalf by Andrew Hall, Chairman.