Corporate Social Responsibility

Our Corporate Social Responsibility (CSR) commitment is to always act in line with:

Our Values:- Commitment, Trust, Honesty, Integrity, Respect and Empathy; and

Our Purpose:-  which includes our wider role in improving your wellbeing: socially, economically and environmentally; as a community anchor organisation. It is also part of our commitment to being value for money as a social landlord.


We will continue to build an Association that our people feel proud of through recruiting, managing and developing our people in a responsible way and in a safe and rewarding environment. This includes ensuring our people have an opportunity to volunteer and support our chosen charities and develop our approach to people, rewards, health and well being. Our employee support package includes family friendly policies, healthcare for all and other flexible rewards tailored to individual needs.

Tenants want a sense of community, within their immediate area and the wider settlement. We are more than a landlord and provide services to improve quality of life and employability, tackle fuel poverty and discrimination, and address times of household crisis or financial difficulty through tenancy sustainability services provided through the SMART and ASSIST Teams. We are also addressing digital exclusion and engagement to ensure that tenants and other customers are part of what we do.

Our aim at community level is to grow and support the social capital and diversity of third sector and voluntary activity in communities we serve. We will continue to build sustainable communities through our investment in community regeneration.

What we will do to improve your social well-being
In the new community based operational model, Neighbourhood Officers will be able to make investment and operational decisions in support of their communities and work with tenants to find funding to improve their environment.

In order to calculate the social value of our projects, we will work with the SFHA to develop the methodology of determining social value.

In our wider role as a community anchor, we will support local groups by information sharing, offering volunteering opportunities for staff, provide governance and organisational advice and where appropriate support. We will develop a tenant apprentice scheme to help build confidence, engagement and customer board membership.


We will work with our partners to secure social value and manage our supply chain in an ethical and sustainable way. We will do this by developing a consistent approach to social value that encourages our partners and suppliers to contribute to the Grampian Group’s aims and work in partnership to attract inward investment, maximise our impact and grow our business.

The principles of the circular economy will apply to how we work whether that is through procurement, service design or our wider role in the community.

What we will do to improve the local economy
When considering our financial and buying power, we will place community benefit and local economic impact center-stage in our procurement of supplies and services. We will support the development of social and co-operative enterprise across the North East, where this has a positive impact on our communities and tenants. We are leveraging additional social value from our contracts and frameworks around the creation of local jobs and training opportunities.


Tenants want a safe, secure, biodiverse, healthy, pollution free place to live in, to reduce waste and recycle more, and opportunities to participate in a low carbon world, whether that be in terms of energy use, transport or food. We will nurture a sustainable environment – through understanding and managing GHA’s impact on the environment, looking for new and sustainable ways to operate our business and supporting our tenants & customers to do the same.

This includes educating our colleagues to minimise the impact they and our services have on the environment and using products and contractors who will minimise the impact that our built assets (existing and new) have on the environment. One outcome of transforming our business by moving to a new Grampian 2.0 operating model will be reducing travel to work time and our carbon footprint.

As part of our CSR commitment we will decarbonise our business and share innovation with our sector. Grampian's electricity supply is already 100% renewable. We will move away from fossil fuel use over the next decade, and work with tenants to become a carbon neutral association. We are also assessing our stock and identifying opportunities in existing and new build homes to install new energy technologies such as solar panels, electrical storage batteries, renewable heating systems and LED lighting.

We support your community with a range of initiatives including energy saving, employment opportunities, enterprise, training and volunteering. As our work goes far beyond bricks and mortar we will continue to develop and expand this support.

What we will do to improve the environment you live in
Create a set of standards for thermal efficiency, local electricity generation and use, water saving and biodiversity for new homes through our Grampian Design Vision.

We will increase biodiversity in green spaces on our estates with better maintenance and management, including planting more trees, food forests and looking after your environment.

We will improve our supply chain on social and environmental targets to cover responsible sourcing, energy and waste.

We will work with tenants, community groups, the councils and third sector to reduce food waste and find alternative uses for surplus and waste food in our communities.

Our planned maintenance programme will design out waste.

We are working with communities, councils and the third sector to create a social enterprise to turn fruit waste into value and investment in the environment. We are creating a energy transition strategy and operating model for existing and new homes that stops our reliance on fossil fuels, whilst keeping homes affordable to run.

Promoting Social Justice and Equality

The Association recognises that despite progress injustice and inequality remains and often unseen.

The Association has a charity sees action to tackle poverty and assist those in need as a core purpose. This is reflected in how it approaches service delivery and design as well as specific services which aim to support those who may be vulnerable or experiencing financial difficulty.

The Association is committed to addressing inequality and ensuring that all members of the community are able to access services and good quality homes. It has adopted a policy which sets out that commitment and an action plan to ensure that is delivered.

The Association is also committed to the eradication of modern slavery and has adopted a statement in support of that and action plan setting out the practical steps that it will take to make this commitment a reality.

Modern Slavery Statement

This statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015, which requires organisations supplying goods or services to publish annually.

The Grampian Group (Grampian) is opposed to all forms of modern slavery and is committed to acting ethically and with integrity in all its business relationships. The statement outlines the steps Grampian takes to ensure that adequate processes and controls are in place to ensure slavery and human trafficking is not taking place anywhere in our supply chains or in any part of its own business.

Structure and Supply Chains

Grampian owns and manages over 3,700 homes across the North East of Scotland. We employ over 120 colleagues, who support the provision of affordable, good quality homes and services to a significant number of customers and households.

Our supply chains cover goods, services and works necessary to:

  • Deliver front line services to residents in the properties we manage;
  • Build new homes;
  • Repair existing homes;
  • Support the “back-office” services that keep the business operating efficiently.


This Statement is approved by the Board of Grampian Housing Association and applies to all organisations within the Group:

  • TLC Housing Maintenance Limited
  • Kirkgate Developments Limited
  • Kirkgate Homes Limited (currently dormant)
  • Grampian Community Energy Limited (currently dormant)

The Group has adopted a set of values which serve as reference points for how we conduct our business and how we treat all our stakeholders. These values are:

Honesty | Integrity | Respect | Empathy | Commitment | Trust

The Group’s position in respect to modern slavery and playing its part in tackling that is entirely consistent with these values.

This Statement is reviewed and updated annually.

Policy Framework

We have an extensive and robust framework of policies, procedures and contractual requirements in place which contribute to the prevention of slavery and human trafficking.  Key policies and strategies include:

Equality Policy

The Association revised its policy in regard to Equality in October 2021 with the assistance of external and specialist support. This combined with a new Action Plan reflects our commitment to social justice and making a positive difference for people.

The equality policy sets out a framework of objectives and specific equality procedures that we use to address discrimination as well as to promote social justice.

The policy objectives are implemented through an equality action plan and a range of other equality procedures. This ensures that we adopt a holistic and systemic approach to equality rights implementation.

This framework provides the foundation on which we will deliver services and take positive action to address inequality and incidence of modern slavery.

Procurement Policy & Strategy

Procurement Selection Questionnaires were revised in 2021 to include questions related to modern slavery and human trafficking to identify and mitigate risk in supply chains. Specifically, all new procurement contracts were revised to ensure that they contain the following clauses:

  • The Service Provider shall, and shall use reasonable endeavours to ensure that its employees or agents and/or supply chain shall, at all-time act in a way which is compatible with the Modern Slavery Act 2015.
  • Where relevant the Service Provider must publish a statement as required by the Act.
  • The Client reserves the right, upon reasonable notice, to audit this at any time during the contract period. In the event that the Client considers that a Service Provider is not in compliance with the Modern Slavery Act 2015 the Service Provider must take all such appropriate remedial actions as requested by the Client to address any areas of concern.
  • The Service Provider agrees to indemnify and keep indemnified the Client against all loss, costs, proceedings or damages whatsoever arising out of or in connection with any breach by the Service Provider of its obligations under the Modern Slavery Act 2015.

Grampian will only trade with those who fully comply with this Policy or those who are taking verifiable steps towards compliance. We will assess any suspected instances of noncompliance on a case-by-case basis and take appropriate remedial action.

In 2021, we revised our Procurement Strategy. This incorporated the UK and Scottish legislative framework and follows good practice in procurement.

Recruitment & Selection Policy

Our recruitment and people management systems are designed to ensure that all prospective employees are legally entitled to work in the UK. There are mechanisms in place for colleagues to access support if they are experiencing any type of abuse once in our employment.

We pay all staff at least the Real Living Wage.

Safeguarding Policy

We have a Safeguarding Policy in place to ensure that all suspected cases of neglect or abuse are investigated and reported. The ASSIST Team have been designated as Safeguarding Officers and underwent online training on Modern Slavery and this is due to updated by early 2024. ASSIST also has policies and training for vulnerable adults.

Whistleblowing Policy

Our Whistleblowing Policy provides advice to colleagues and Board Members about how to report any instances of malpractice within our organisation or supply chain.

Lettings Policy

When signing up new tenants we undertake a robust process to ensure that they are who they say they are which includes background and identification checks. Staff will always investigate any allegations from customers or the wider community regarding potential tenancy fraud.

Poverty Strategy

The Poverty Strategy, approved in 2021, links to the Association’s online Modern Slavery Statement.


We are committed to raising awareness amongst colleagues about anti-slavery and human trafficking and will included this within training for all colleagues. This topic continues to be a regular feature in our Equality, Diversity and Inclusion plans.

Training is provided via a briefing note and online video available to all staff which highlights the signs of modern slavery and exploitation and how to seek help. Frontline staff who visit tenants and service users are trained to identify signs of exploitation and understand that instances of this should be reported to managers who would then work with other agencies including Social Service and Police Scotland to assess such cases.

Practical Delivery

Update on 2021-22 commitments

  • Procurement Strategy and Procurement Policy – these have been updated to reflect Modern Slavery Act requirements and were formally approved by the Board in February 2022.
  • Staff Training – the Modern Slavery Guidance was reissued to staff and training provided regarding the Procurement Strategy and Policy.
  • Modern Slavery & Exploitation Helpline - website links to the helpline site and social media to be completed in November 2023.
  • Operational Risk Register - the risk of failing to meet Modern Slavery requirements has been reviewed using the revised risk framework.
  • People Strategy – the revised People Strategy, which reinforces HR’s role in the both the prevention of, and awareness raising around, Modern Slavery was approved on 24 May 2022.


New commitments 2022-2023

In addition to outstanding item(s) above, in 2022-2023 we will:

  • Staff Training - reissue the Modern Slavery Guidance internally and ensure training is provided as required for new staff.
  • Suppliers - write to Grampian’s high-value (by Grampian’s spend) contractors to confirm our position regarding Modern Slavery, and the requirements that we have for our suppliers.
  • Safeguarding Officers - ensure existing Safeguarding Officers receive refresher training, and a vacancy within this role is appointed.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2023.

Malcolm McNeil
29 August 2023


Fair Work First Statement

The Grampian Group is committed to the advancement of Fair Work First criteria.  As employers, Group Members care about the well-being of staff and are committed to improving work-life balance. Consequently, we work with staff and their representatives to put fair work practices at the heart of our workplace.

One of our strategic objectives is ‘Being a Great Employer’.  We demonstrate this by:

  • An ‘open door’ policy from the Executive Team.
  • Through our People Strategy we invest in workforce development, supporting staff to develop and ensuring that they are supported to perform their roles.
  • Having in place a sector leading wellness framework.
  • A recognition agreement with UNISON and encouraging membership.  We make available, wherever possible, reasonable facilities necessary for Trade Union Representatives to carry out their duties efficiently and communicate  effectively with their members. We engage in constructive dialogue with our employees and their Trade Union representatives to address workplace issues and disputes.
  • Regular staff meetings both individually and with the wider team.
  • We are committed to promoting equality of opportunity and diversity as an employer in all areas of our business. We believe everyone is entitled to be treated fairly with dignity and respect.
  • We offer a wide range of flexible, hybrid and family friendly policies which are available to all our staff from the first day they join our team.
  • We oppose the use of fire and rehire practice.
  • We are committed to paying the Real Living Wage.
  • Only considering the use of zero hours contracts where absolutely necessary.
  • Conducting regular staff surveys communicating the results and proposed actions.
  • Adoption of a Modern Slavery Statement and Action Plan.

We will establish minimum conditions in relation to the supply and procurement of goods and services which constitute regulated procurement as defined within legislation applicable to Scotland. We will also seek to see these applied to other unregulated procurement activity.

Click here to read the Joint Statement between Grampian Housing Association Limited and UNISON, Trade Union.

Fraud Prevention Statement and Audit Arrangements

Fraud Prevention Statement 

The Association adopts a zero tolerance approach to any fraudulent activity.  Through robust procedures and processes in its Fraud Response Plan, preventative measures are in place to detect and prevent fraud, bribery and corruption including regular assessment of risk exposure, implementation of detection techniques and practices as well as staff training to raise awareness.

Where an occasion of fraud, corruption or bribery is established, the Association will take action against the perpetrator including reporting to Police Scotland.


Internal Auditors

MHA Henderson Loggie
The Vision Building
20 Greenmarket

T: 01382 200055