Anti-Slavery and Human Trafficking Policy

2. This policy does not form part of any employee's contract of employment and may be amended from time to time.

The Organisation understands that modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. 

The Organisation expects the same high standards from all contractors, suppliers and other business partners and, as part of contracting processes, One Manchester includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for the Organisation or under our control (“staff”). Staff must ensure that they read, understand and comply with this policy. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Staff members must notify their line manager OR report it in accordance with our Whistleblowing Policy as soon as possible if they believe or suspect that a breach of this policy has occurred or may occur in the future.

Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If staff are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they should raise it with their line manager and the UK Modern Slavery & Exploitation helpline on 08000 121 700. 

One Manchester aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith a suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Whistleblowing Policy. 

One Manchester’s commitment to addressing the issue of modern slavery in our business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate on an ongoing basis.

A breach of the Policy by an Employee will be treated as a disciplinary matter under their contract of employment and an appropriate sanction may be applied. An investigation into any allegation of such a breach made against an Employee will be conducted in accordance with One Manchester’s Whistleblowing Policy for such investigations. 

A breach of this Policy by a Board Member will be treated as a breach of his or her duties and obligations and services agreement with One Manchester. An investigation into any allegation of such a breach made against a board member will be conducted in accordance with One Manchester’s relevant policy for such investigations and an appropriate sanction may be applied in accordance with One Manchester’s Board Member Code of Conduct, One Manchester’s standing orders and One Manchester’s Articles of Association. 

All incidences of slavery or human trafficking will be reported to the Regulator of Social Housing immediately. They should be informed of significant developments in any subsequent investigation

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this Policy.

This Policy will be reviewed every 12 months alongside the Anti-Slavery & Human Trafficking Statement. Should amendments be made, this Policy will be approved by the OM Board. If no amendments are required, the Director of Governance, Strategy & Business Assurance will sign off.

The Audit and Risk Committee will monitor the operation and adequacy of this Policy on a regular basis and will report accordingly to the Board.

Associated Policies and Documents