Modern Slavery Statement

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that GreenSquare Group (‘GreenSquare’) has taken to ensure that modern slavery or human trafficking does not take place anywhere in our organisation or its partners during the financial year 2019/20.

GreenSquare is a public benefit entity administered by a Board of Management. Its subsidiaries provide and manage affordable rented housing and develop private housing for rent and sale.

As well as owning and managing approximately 12,000 properties, GreenSquare is a major developer of new affordable housing and is a lead development partner under the Homes England National Affordable Housing Programme (NAHP). The Group employs 540 staff on a full-time equivalent basis. Any surpluses made by the subsidiaries are retained within the Group.

GreenSquare is a major provider of housing, regeneration, care and support and commercial services across Wiltshire, Oxfordshire, Gloucestershire, and the surrounding areas.

GreenSquare Group Ltd forms the holding entity of a group which includes the following subsidiaries:

  • GreenSquare Community Housing
  • GreenSquare Estates Ltd
  • GreenSquare Construction Ltd
  • GreenSquare Homes Ltd
  • GS Energy Services Ltd
  • Westlea Housing Association Ltd (trading as GreenSquare)
  • Sharpness Development LLP (joint venture)

GreenSquare aims to promote the highest standards throughout our business and in all of our employment and procurement practices. We fully support the principles of the Modern Slavery Act 2015 and we are committed to ensuring that appropriate controls and oversight are in place to prevent the occurrence of modern slavery or human trafficking.

Supply chain policy

We have an extensive supply chain of contractors, suppliers, and partners (1,055 in total) and procure goods and services predominantly within England. Some of our suppliers subcontract work or rely on recruitment agencies to supply temporary or permanent staff.

By the nature of their businesses, some of our suppliers are potentially at higher risk of exposure to modern slavery than others, for example, maintenance, repairs and construction companies, cleaning and grounds maintenance contractors, security firms and specialist managing agents who provide support and/or care.

We require all our suppliers, delivery partners, organisations within our frameworks and other suppliers we engage with to ensure their goods, materials and labour-related supply chains fully comply with the Modern Slavery Act 2015 and comply with our Corporate Social Responsibility (CSR) statement.

We have implemented clear procurement policy principles and procedures that we expect all our stakeholders to comply with, which include a commitment to the following:

  • training for all staff about the principles of good procurement where relevant;
  • code of conduct;
  • declaration of interest;
  • systems to measure procurement performance;
  • the involvement of residents in commissioning and procurement when possible and or required;
  • due diligence given to addressing issues of equalities and diversity;
  • in procurement exercises staff will have regard to improving the economic, social and environmental well-being in the area in which the procurement takes place.

In the current uncertain and rapidly changing climate we are conscious that there may be new or increased modern slavery risks in our operations and supply chains. We undertake regular risk assessments and review risk scores to ensure that all risks are appropriately considered and mitigated against.

Our people practices

Within GreenSquare, our recruitment and people management systems are designed to make sure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion once in our employment. They include:

  • carrying out pre-employment checks such as right to work in the UK by the production of appropriate original documentation, DBS (where applicable) and references;
  • paying at least the national living wage in line with Living Wage Foundation. Apprentices have a bespoke wage in line with Government guidelines;
  • implementing appropriate grievance procedures and having a comprehensive Whistleblowing Policy, with breaches managed under the Disciplinary Policy and Procedures; and
  • having a robust framework of health and safety policies and procedures overseen by our Health and Safety Committee, which is chaired by the Chief Executive, contains Board representation and reports directly to the Board.

Employees with any evidence of non-compliance with the Act, including any concerns about our supply chains or about any issues relating to our residents should refer to the Safeguarding Policy and are encouraged to contact the Company Secretary, or to use our Confidential Reporting (Whistleblowing) Policy.

Following the implementation of restrictions due to the Covid-19 pandemic GreenSquare acted quickly to safeguard its staff and their wellbeing. We take health and wellbeing seriously at GreenSquare, and we know that this is a difficult time for all our staff and suppliers. We have implemented all restrictions required by the government and we provide regular updates to all staff. Additional fortnightly calls have been implemented alongside monthly Board meetings to keep the Board fully informed of our actions. Line managers hold regular check-ins with staff to monitor their wellbeing and we have implemented a new health and wellbeing area on our intranet where employees can find information about Mental Health First Aiders, health services including the Employee Assistance Programme, and our new online health and wellbeing portal. We remind staff to be on alert for any signs that our suppliers are being negatively affected by the current restrictions.


The requirements of the Act and this statement have been discussed at our Executive Team and our Board has approved this annual statement and provides oversight to our approach.

Awareness raising articles have recently been published on our internal intranet to remind staff of the importance of continued vigilance and we provide training to all members of staff via our suite of multimedia e-Learning modules and additional resources. We have a suite of probity policies that are regularly reviewed and which cover a variety of subjects, including safeguarding and whistleblowing. We ensure that all staff are required to read and acknowledge these policies upon joining the Group and they are encouraged to review their knowledge via awareness-raising exercises.

Related policies

We have reviewed our existing policies and procedures considering the Act:

  • Group's Standards of Conduct;
  • Diversity and Inclusion Policy;
  • Anti-Bribery and Anti-Corruption Policy
  • Anti-Fraud Policy
  • Confidential Reporting (Whistleblowing) Policy;
  • Safeguarding Policy; and
  • Recruitment and Selection Policy and Procedures.

Compliance during 2019/20

During the financial year 2019/2020 we continued to take appropriate steps to make sure that there is no modern slavery or human trafficking in our organisation and its supply chains and that they operate ethically and transparently. We asked that all new contractors provide a declaration that they are not involved in modern slavery or human trafficking and that they comply with GreenSquare’s CSR statement in respect of modern slavery and human trafficking.

We increased staff awareness across the organisation via training, which was rolled out to apply to all staff. We continued to raise awareness via regular updates on our Group intranet.

We reviewed our procurement policies and procedures and implemented new procurement principles that are available to all staff and suppliers.

Steps we will take during 2020/21

  1. We will continue to make our staff aware of the Modern Slavery Act through our intranet, E-learning module and training for all staff. We have already undertaken a week-long awareness raising exercise of our probity policies and implemented a new fraud awareness e-learning module..
  2. We will carry out ongoing due diligence to support procurement and contract management.
  3. We will implement appropriate KPIs to monitor the effectiveness of our controls over modern slavery and human trafficking.
  4. We will continue to support our staff during the Covid-19 pandemic via our Employee Assistance Programme, colleague forum and regular updates and will ensure that all concerns are acted on and fed through to the relevant people.
  5. We will ensure that all staff are aware that the huge economic and societal changes that have resulted from the Covid-19 pandemic and that have affected both the Group and employees personally can increase the likelihood of modern slavery or human trafficking offences occurring.
  6. We will continue to remind staff that any concerns that they have should be acted upon and will be treated in the strictest confidence and that our Confidential Reporting (Whistleblowing) Policy offers guidance and support should they wish to do so.
  7. We will continue to review our risk management framework to ensure that the relevant risks are up to date and any new risks that have been identified are included and appropriately mitigated.

This statement has been approved by the GreenSquare Group Ltd Board in July 2020 and it will be reported on annually to the Board thereafter. The commercial subsidiaries, as separate legal entities will also receive this report.

Ruth Cooke
Chief Executive

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