Modern slavery statement

The Group ensures compliance with its legal and regulatory responsibilities. The Group notes the requirements of the Modern Slavery Act 2015 (the Act) and is committed to preventing modern slavery and human trafficking activities from existing within its business or supply chain.

In preparing this statement the Group assessed its potential exposure to modern slavery and human trafficking. The Group has determined that there are no current areas of its business considered to be at high risk from modern slavery or human trafficking. During the financial year 2023‐24 the Group received no reported concerns in relation to modern slavery or human trafficking.

The Group’s approach to modern slavery is communicated to all employees, suppliers, contractors and partners at the outset of the business relationship. The prevention, detection and reporting of modern slavery or human trafficking concerns is the responsibility of all those working for the Group or under its control. Employees, Jigsaw Homes Group Ltd suppliers contractors and partners are encouraged to raise, without fear of reprisal, concerns about suspicions of modern slavery or human trafficking in any parts of the business, or its supply chains, at the earliest opportunity.

The Group recognises an area of risk to be in its tenancies. Our employees and contractors, particularly those involved in visiting its properties, must be aware of the potential signs of exploitation and feel empowered to utilise our concern card process.

Concerns raised relating to tenancies made through the concern card process are dealt with by a specialist Neighbourhood Safety Team, who will seek to safeguard those adults or children at risk of exploitation and this team also have responsibility for the investigation of unauthorised subletting and tenancy fraud.

The Group has over 600 approved contractors who have evidenced compliance with our expected requirements to be accepted onto our approved contractor list. A number of these approved contractors will also be subject to the requirements of Section 54 of the Act. On very rare occasions, for example when using a specialist contractor, the Group may award a contract to an organisation not on the approved contractor list. In such cases a non‐compliance form is completed and it is proposed this be adapted to include an assessment of exposure to modern slavery and human trafficking.

The Group recognise an area of risk could occur with the subcontracting of work. The Group seeks to mitigate this potential with the vast majority of its grounds maintenance and cleaning services being delivered by staff directly employed by the Group, and it also directly employs clerk of works who have a presence at its development sites.

With regards to employees, the Group:

• Requires new employees to produce original document evidence of their right to work in the UK prior to the commencement of their employment
• Pays all permanent staff, including those still within a probationary period, the national living wage
• Uses employment agencies only by exception and when it does will only use specified, reputable employment agencies
• Has Probity and Anti‐Fraud and Whistleblowing Policies to ensure that employees may raise concerns without fear of reprisal
• Will provide annual awareness training in relation to Modern Slavery.

The nature of Group’s work means it engages with a diverse range and size of private and public sector organisations.

The Group’s approach to procurement is documented in its Financial Regulations. The Group is committed to ensuring that those it works with adhere to the highest standards of ethics. Contractors and suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, act ethically
and within the law in their use of labour and supply chains.

Jigsaw Homes Group will undertake due diligence when considering the appointment of a new contractor or supplier. This due diligence will include an evaluation of modern
slavery and human trafficking risks, an assessment of financial stability, insurance cover arrangements and compliance with various employment policies. The Group will mandatorily exclude working with any organisation or an individual that has been convicted of an offence under the Act.

Where evidence of working practice comes to light which suggests non‐compliance with the Act, either during the approved contractor process or whilst performing any contract, the Group will work with the contractor or supplier to address the non‐compliance. It is incumbent upon the contractor or supplier to co‐operate in rectifying any non‐compliance within a timescale provided by the Group. Where the Group is of the opinion that either the working practices significantly contravene its expectations set out in this statement, or there has been insufficient progress being made by the contractor or supplier to address non‐compliance, then it may terminate any business relationship immediately.

The Group offer a number of ways for employees, suppliers, contractors and partners to report potential concerns regarding tenancies or working practices.

For concerns relating to tenancies the Group operates a concern card procedure for employees and contractors to enable the reporting of suspicions Concerns may also
be reported to the Modern Slavery Helpline on 08000 121 700, Crimestoppers on 0800 555 111 or the Group Company Secretary by emailing governance@jigsawhomes.org.uk

Concerns regarding working practices can be raised by employees with their line manager. Suppliers, contractors and partners can do this via their nominated contact within the Group, and similarly through The Modern Slavery Helpline, Crimestoppers or the Group Company Secretary.

It also recognised that some employees, suppliers, contractors or partners may wish to report concerns regarding tenancies or working practices anonymously and this can be done through the methods set out in the Whistleblowing Policy.

Our aims for 2024‐25 are to:

• Issue refreshed e‐learning to all employees
• Raise awareness of Anti‐Slavery Day scheduled for October 2024
• Issue concern card guidance to all contractors engaged in delivering an on‐site services at our homes
• Incorporate modern slavery assessments into non‐approved contractor work

This policy and statement will be reviewed annually by the Group Board and published on the Group’s website and the Government modern slavery registry.

Policies supporting the delivery of this statement:

• Safeguarding Children and Adults Policy
• Financial Regulations
• Terms of Reference and Scheme of Delegation
• Recruitment and Selection Policy
• Equality, Diversity and Inclusion Policy
• Probity and Anti‐Fraud Policy
• Whistleblowing Policy
• People Strategy
• Tenancy Policy
• Employee Handbook
• Governance Handbook

• Jigsaw Homes Group Limited. Registered as a Community Benefit Society with FCA. Registration number: 29433R. Housing Regulator registration number: LH4345
• Jigsaw Homes North. Registered as a Community Benefit Society with FCA. Registration number: 16668R. Housing Regulator registration number: LH0131
• Jigsaw Homes Midlands. Registered as a Community Benefit Society with FCA. Registration number: 8378. Housing Regulator registration number: L4532
• Jigsaw Support. Registered as a Community Benefit Society with FCA. Registration number: 8241.
• Jigsaw Homes Tameside. Company number 3807022. Charity Commission number 1146435. Housing Regulator registration number: LH4266
• Cavendish Property Developments Limited. Company Number: 8166437
• Jigsaw Treasury Limited. Company Number: 12535831
• Jigsaw Funding PLC. Company Number: 13888642
• Palatine Contracts Limited. Company Number: 4056290
• Snugg Properties Limited. Company Number: 11052396
• The registered office address for the above companies is Cavendish 249, Cavendish Street, Ashton-under-Lyne, OL6 7AT.

This policy and statement will be reviewed annually (September) by the Group Board and published on the Group’s website and the Government modern slavery registry.  The responsible officer is Mike Murphy, Group Company Secretary.