Introduction
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 take 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 nearly 4,000 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 (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:

Procurement Policy & Strategy
Procurement Selection Questionnaires have been revised to include questions related to modern slavery and human trafficking to identify and mitigate risk in supply chains. Specifically, all new procurement contracts have been 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. 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 have revised our Procurement Strategy (pending approval October 2021). This incorporates European and Scottish legislative frameworks 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 in 2020.  Assist also have 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 new strategy (approved June 2021) links to the Association’s online Modern Slavery Statement.

Training
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 will continue 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 2021-22
The following actions demonstrate ongoing measures being progressed in 2021-22 to ensure that steps consistent with this statement are taken forward.

  • Procurement Strategy and Procurement Policy – these have been updated to reflect Modern Slavery Act requirements and will be formally approved at Board (October 2021)
  • Staff Training – reissue Modern Slavery guidance and provide training on the updated Procurement Strategy and Policy
  • Modern Slavery & Exploitation Helpline - provide website links to the helpline site and promote on social media / internal communications platforms
  • Operational Risk Register - review the risk of failing to meet Modern Slavery requirements using revised risk framework
  • People Strategy – approval of a revised People Strategy, which reinforces HR’s role in the both the prevention of, and awareness raising around, Modern Slavery.


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 2021.

              Malcolm McNeil
              Secretary                    21/09/21

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