Modern slavery statement

Whether we are required to publish this

The duty to publish an annual modern slavery statement applies to a commercial organisation with a total annual turnover of £36 million or more, counting the whole group wherever in the world it operates.

TBD — Bluebell’s group turnover. Bluebell’s total annual turnover for the whole group, confirmed by finance. Section 54 of the Modern Slavery Act 2015 applies at £36 million or more. Until it is confirmed, this statement is published voluntarily and must be described as voluntary.

That distinction is not pedantry. A statement that says it is made “pursuant to section 54” when no duty exists misrepresents the law, and the Home Office’s own guidance warns against exactly that. If the threshold is crossed, this page needs the approval and signature the Act requires, a prominent link from the homepage, submission to the government registry and annual republication — and it will get all of them.

The Government has announced intended reforms to modern slavery reporting. They are not in force, organisations continue to report under the current requirements, and we have not written this page as though anything had changed.

Commissioners routinely ask for a statement in tender documents whatever the turnover is. That is a good reason to publish one. It is not a reason to describe it as compliance.

Our business, and where the risk actually sits

We lease residential property from private landlords, manage it, and provide accommodation with housing-related support to adults who need somewhere safe to live. We do not manufacture anything and we do not import anything. Almost everything we buy is either labour or the ordinary supplies of running a house.

Being specific about where the risk is, rather than claiming there is none:

• The trades who work in our properties. Maintenance, refurbishment, construction, cleaning, waste clearance and grounds work — sectors with known exploitation risks, often reached through layers of subcontracting where the person doing the work is several steps from the company we pay. This is our largest exposure and it is the one a landlord is most likely to overlook, because the risk is standing in our buildings rather than sitting in a distant supply chain.
• The people we house. Adults leaving homelessness, prison, care and abusive homes are among the most targeted groups there are. Forced labour, forced criminality, and people taking over somebody’s home to exploit them are things we expect to encounter, not things we hope not to.
• Agency and relief staff. Where we do not recruit somebody ourselves we are relying on another organisation’s checks.
• Our own recruitment, if we recruit at any scale — particularly anybody recruited from overseas, who may arrive owing money to an agent and afraid that raising a problem will cost them their right to remain.

If somebody we house is being exploited

This is the clause that matters most for this business, because it is the one that will actually be used.

What our staff are expected to notice:

• Somebody being collected and returned at odd hours, by the same person, every day.
• Somebody who never has their own money, or whose benefits go into another person’s account.
• Somebody whose documents are held by somebody else.
• A person answering for somebody, and not letting them speak.
• People who do not live there staying in a resident’s home, or controlling who comes and goes — which is also a safeguarding concern and a matter for our anti-social behaviour policy, and is treated as all three.
• Injuries, exhaustion, fear of the police, or debts that never reduce.

What we do:

1. Make the person safe first. If they are in danger, 999.
2. Report it as a safeguarding concern to the adult safeguarding team at the council, under our safeguarding policy. Modern slavery is one of the ten recognised categories of abuse.
3. Report it to the police, with the person’s wishes taken into account wherever it is safe to do so.
4. Help them reach the National Referral Mechanism, which is the route by which somebody is formally identified as a potential victim and gets support.

TBD — whether we can refer into that system ourselves. Whether Bluebell is a designated first responder organisation for the National Referral Mechanism. Only designated organisations can make a referral into it; a private housing provider ordinarily is not one, in which case we work through the police and the local authority. The answer changes what this page tells a resident to expect, and operations has to confirm the position.

Nobody loses their home for being a victim of this. Somebody who has been forced to work, or whose home has been taken over, has had something done to them. It is not a breach of their agreement and we will not treat it as one.

If you told us and nothing happened, that is a complaint, and our complaints policy sets out the two stages. The residents page has the other routes a resident may need.

The contractors who work in our properties

A landlord’s supply chain is mostly people standing in its buildings. What we require:

• Contractors who can tell us who is actually doing the work, including where they have subcontracted it.
• Written confirmation that no forced or child labour is used, that workers are paid at least the legal minimum, and that working time rules are followed.
• Workers who carry their own identification and are not accompanied by somebody speaking for them.
• A rate that makes lawful employment possible. A price far below everybody else’s is information, not a saving.
• The right to end a contract where exploitation is found, without penalty.

TBD — how far down the chain we have actually looked. “We assess the risk as low” is the standard sentence here and it is worth very little without saying what was examined to reach it. We would rather record the gap than fill it.

Recruitment

These are the checks we will run on every person before they start. They are not aspirational, and they are the same checks that catch forced labour.

• Right to work checked for everybody, before they start.
• A criminal record check at the level the role is eligible for — our safeguarding policy explains why that is decided role by role rather than applied as a blanket.
• Identity, full employment history with any gap explained, references taken up directly, and qualifications verified.
• Everybody paid at least the legal minimum, with hours inside working time limits, and paid directly into their own bank account. Never to a third party, never to an account shared with a recruiter, and never with a deduction we cannot explain.
• No worker charged a fee for finding them work, and no document — passport, permit, certificate — retained by us or by anybody acting for us.

Where an agency supplies staff, we require written confirmation that it has run the same checks.

How somebody raises a concern

A statement is worth nothing if the person who sees something is afraid to say it. In law, a worker who reports something in the public interest is protected from being dismissed or treated badly for it, from their first day.

Inside Bluebell: to a manager, or above them, or to the route that sits outside the normal line of management.

Outside Bluebell, and without telling us first: the police, the council’s adult safeguarding team, the Gangmasters and Labour Abuse Authority where it concerns work, and Protect, the independent whistleblowing charity, which gives free confidential advice to workers. The national Modern Slavery Helpline takes reports from anybody, including anonymously. In an emergency, 999.

TBD — the internal contact outside the line of management, and the current helpline numbers taken from those organisations’ own published material. We are not printing a number we have not verified.

Training

Modern slavery is covered within safeguarding training, because for our staff it arrives as a safeguarding concern rather than as a procurement question — it is one of the ten recognised categories of abuse. Managers who recruit, or who let contracts, get more. TBD — The modern slavery content within safeguarding training, the additional training for managers who recruit or who let contracts, and how often each is refreshed. No regulation sets an interval, so this is a commitment Bluebell makes rather than one it inherits, and operations has to set it.

Approval

Where the Act applies, a statement must be approved by the board and signed by a director, and published for each financial year.

TBD — The financial year this statement covers, the date it was approved, and the name and role of the person signing it. Where section 54 applies, a statement must be approved by the board and signed by a director — that is a governance act, not a form of words, and writing one for a meeting that has not happened would be a false statement about the company’s own governance. Until those exist this page carries no approval formula and no signature block.