Modern Slavery

We are committed to ensuring we comply with the Modern Slavery Act 2015 and to taking appropriate steps to make sure that slavery does not exist in our business, supply chains, or homes. We regularly raise awareness of modern slavery issues to all of our employees using our intranet.

Each year, our Modern Slavery statement is checked by our solicitors to ensure best practice and a link is displayed on the homepage of our website. Our Modern Slavery statements written before April 2022 are available on request, please contact our Communications Team by email:

Our next statement will be published by the end of September 2022.

In our business

We ensure all our employees are paid the living wage and regularly review our terms of employment to ensure compliance with appropriate legislation. We operate a number of policies that support preventing slavery and human trafficking in our operations including:

  • Whistleblowing

  • Employee Code of Conduct

  • Recruitment / Agency Workers

  • Safeguarding

In our supply chains

When our goods or services are sourced from suppliers, we work closely with them to ensure slavery and human trafficking does not exist in their business or supply chain.  

We require all suppliers to declare that they are not involved in Modern Slavery before contracts are signed, and we commissioned our solicitors to produce a Modern Slavery questionnaire to be completed by all our major suppliers. The questionnaire is sent out yearly to capture changes in the organisation’s own supply chains, and we’re working to increase the list of suppliers it is sent to.

In our homes

As a housing association, we take steps to ensure that Modern Slavery (and any other kind of exploitation) does not exist in our homes. These steps include eLearning for all employees and we are also currently developing some eLearning around County Drug Lines.

We work with the Buckinghamshire Willow Project, who are specialists in cases of Modern Slavery and take referrals of any suspected cases. They’ve delivered training to some of our customer-facing employees to equip them with the skills to spot signs of exploitation. We’re also members of the Bucks anti-slavery and exploitation network and attend quarterly meetings with local partners including Thames Valley Police and Trading Standards.

Reports published before April 2022

Modern Slavery Statement 2021


This statement highlights our (Vale of Aylesbury Housing Trust) approach to understanding all potential modern slavery risks related to our business in compliance with section 54 of the Modern Slavery Act 2015. This approach is aimed at ensuring that there is no slavery or human trafficking in our business and our supply chains. This statement relates to the financial year 1 April 2020 to 31 March 2021.

We operate solely in England and all of our first-tier suppliers are UK based. However, as we commission construction and refurbishment projects for our properties, we effectively operate in a 'high risk' sector. We are aware that the construction industry is more susceptible to modern slavery and human trafficking than many other sectors, even for those companies operating solely within the UK.

We recognise that we have a responsibility to take a robust approach to slavery and human trafficking. We are absolutely committed to preventing slavery and human trafficking in our corporate activities, and to ensuring that our infrastructure is free from slavery and human trafficking.

Supply Chain

We asked our significant construction related suppliers to review their survey responses provided to us in 2020 in order to continue to ensure there is no known modern slavery or human trafficking in the supply chain. Newly appointed suppliers have also been required to complete the same survey. A 100% response rate was received from our 45 suppliers. Of the 45 suppliers received, 15 are required to prepare their own transparency in supply chains statement.

No supplier had any reason to suspect there is slavery or trafficking in their supply chain. All suppliers have been asked to proactively notify us in the event that this situation changes. Many suppliers have specific anti-slavery and anti-trafficking policies in place. 31 of our suppliers are members of a construction industry federation. All suppliers confirmed they pay all their UK staff at least the national minimum wage and all suppliers with overseas branches confirmed they comply with the minimum wage legislation in the countries in which they operate. 41 of the suppliers ensure they check the identity of employees of sub-contractors from high risk countries including Slovakia, Romania, Poland, Lithuania and Hungary.

The responses to the questionnaire, combined with our knowledge and relationships with our suppliers, has satisfied us that there is no reason to believe that there is any slavery or human trafficking in our supply chain during this calendar year. We are further satisfied that there are robust procedures in place to ensure that any occurrence of slavery or human trafficking will be identified by us or our suppliers.

Relevant Policies

We operate the following policies that support preventing slavery and human trafficking in our operations and supply chain:

  • Whistleblowing Policy - we encourage all employees, customers and other business partners to report any concerns related to our direct activities, or supply chains. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Our whistle blowing policy is contained in an internal document (confidential reporting policy) and made available to all employees on our Intranet.

  • Employee Code of Conduct - our code makes clear to employees the actions and behaviours expected of them when representing us. We strive to maintain the highest standards of employee conduct and ethical behaviour.

  • Supplier Code of Conduct – our code makes clear to our suppliers the actions expected of them when partnering with us. It sets out that modern slavery and human trafficking must not exist in their business or supply chain.

  • Recruitment/Agency Workers Policy - we use only specified, reputable employment agencies to source labour and always verify the practices of any new agency we are using before accepting workers from that agency. All our employees have a written contract of employment and we carry out appropriate right to work and identity checks. We are also alert to any exploitation risk indicators such as a high number of people sharing the same address.

  • Safeguarding Policy – our safeguarding policies and procedures are aimed specifically at people with care and support needs who may be in vulnerable circumstances. Modern slavery is one of the principal categories of abuse that is contained within the Safeguarding Policy and our plan to safeguard the welfare of our residents is set out in detail.

Awareness-raising Programme

  • We have raised awareness of modern slavery issues by informing all of our employees by using our Intranet service. This information explains to employees:

  • The basic principles of the Modern Slavery Act 2015;

  • How employers can identify and prevent slavery and human trafficking; What employees can do to flag up potential slavery or human trafficking issues to the relevant parties; and what external help is available, for example through the Modern Slavery Helpline

We have also raised awareness of modern slavery issues at a senior level by providing training to our Board members.

In 2020, we also launched our ‘County Lines’ eLearning module to help promote awareness about this growing national exploitation issue. ‘County Lines’ is where illegal drugs are transported from one area to another to expand a drugs network, often across police and local authority boundaries, usually by children or vulnerable people who are coerced and exploited into it by gangs.


This statement will be reviewed and published annually. This statement is approved by our Board and signed on its behalf by:

Stephen Stringer, Board Chair's signature

Stephen Stringer
Chair of Vale of Aylesbury Housing Trust