Modern Slavery Statement

GreenSquare Group Ltd. is a charitable housing association, operating in the UK and employing approximately 600 employees. It forms the holding entity of a group which includes the following subsidiaries:

  • GreenSquare Community Housing
  • GreenSquare Estates Ltd
  • GreenSquare Construction Ltd
  • GreenSquare Homes Ltd
  • Westlea Housing Association Ltd (trading as GreenSquare) 
  • Sharpness Development LLP

GreenSquare develops affordable housing for rent, provides landlord and individual support and related services for people in Wiltshire, Gloucestershire and Oxfordshire. We own or manages circa.12,000 properties. We aim to promote the highest standards in how we run our business and, in our employment, and procurement practices. We support the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

Supply chain policy 

We have an extensive supply chain of contractors, suppliers, and partners and procure goods and services predominantly within England. Some of our supplier’s 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.  

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 Procedure; and
  • having a robust framework of health and safety policies and procedures.

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


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

Articles have been published on our internal intranet and we have provided training to relevant members of staff, typically ‘front line’ staff working in our communities via Unseen.

Related polices

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

  • Group's Standards of Conduct;
  • Diversity and Inclusion Strategy and Policy;
  • Anti-Fraud and Bribery Policy;
  • Whistleblowing Policy; 
  • Safeguarding Policy; and
  • Recruitment and Selection Policy and Procedure. 

Compliance steps during 2018/19 

  • We continued to take appropriate steps to make sure that there is no modern slavery or human trafficking in our supply chains.
  • From the beginning of 2018 all new contractors were required to 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 have increased staff awareness via training. 

Steps we will take during 2019/20

  1. Continue to make our staff aware of the Modern Slavery Act through our intranet, new E-learning module and training for front line staff.
  2. Carry out on-going due diligence to support procurement and contract management. Agencies supplying agency workers will be asked to sign up to the Act and to our CSR statement.
  3. Make sure that tender documentation includes the mandatory exclusion of any bidder who has been convicted of an offence under Part 1 Section 1, 2 or 4 of the Modern Slavery Act 2015.
  4. Communicate to staff that our Safeguarding Policy (in the first incidence) is the preferred method of reporting suspected modern slavery. Our recently reviewed Whistleblowing Policy is also an appropriate framework within which they or any other parties may report suspected modern slavery or human trafficking or any other related practices.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group's slavery and human trafficking statement for the financial year ending 2020.

This statement has been approved by the GreenSquare Group Ltd Board in July 2019 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