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Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or with those we work in partnership with. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our partners. We make a clear annual statement setting out the steps we have taken to ensure slavery and human trafficking is not taking place and demonstrate that we take our responsibilities to our employees seriously.

The purpose of this policy is to: (a) set out our responsibilities, and of those working for and on our behalf, in observing and upholding our position on modern slavery and human trafficking; and (b) provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, trustees, staff, volunteers, partners. This policy does not form part of any employee's contract of employment, and we may amend it at any time.

The Board of Trustees has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Chief Executive (CEO) has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery. You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions, and queries are encouraged and should be addressed to the CEO.

You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or that of our partner organisations is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify the CEO as soon as possible, if you believe or suspect that a breach of this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or that of our partners at the earliest possible stage. If you believe or suspect that a breach of this policy has occurred or that it may occur, you must notify your manager or CEO, or you can report it in accordance with our Whistleblowing Policy as soon as possible. You should note that where appropriate, and with the welfare and safety of local workers as a priority, we may give support and guidance to our partners to help them address coercive or exploitative work practices in their own organisation. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our partners constitutes any of the various forms of modern slavery, raise it with your manager or CEO. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the CEO immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in SharePoint, Documents, General Organisational info.

Training on this policy, and on the risk our business faces from modern slavery, forms part of the induction process for all individuals who are involved in managing recruitment and our partners. Our zero-tolerance approach to modern slavery in our business and partners must be communicated at the outset of our business relationship with them and reinforced as appropriate on an ongoing basis.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations we work in partnership if they breach this policy.

We work directly with many partner organisations who work directly with the most disaffected within our community and whose aim is improving the wellbeing of this cohort.

We do not use recruitment agencies and recruitment is always undertaken internally by GL Communities. We always ensure all staff have a written contract of employment and that they have not had to pay any direct or indirect fees to obtain work. We always ensure staff are legally able to work in the UK. We check the names and addresses of our staff (a number of people listing the same address may indicate high shared occupancy, often a factor for those being exploited). We provide information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to. If, through our recruitment process, we suspect someone is being exploited, the appropriate staff will follow our reporting procedures.