Modern Slavery & Human Trafficking Statement
Financial year: [Year to confirm]
Last updated: [Date to confirm]
Version: 1.0 (Draft)
Our commitment
Diverse Supported Accommodation CIC has a zero-tolerance approach to modern slavery and human trafficking. Although we are not legally required to publish a statement under section 54 of the Modern Slavery Act 2015 (our turnover is below the £36 million threshold), we choose to do so because our residents include people who have themselves been at risk of exploitation — and because we believe transparency on this is a basic obligation of any organisation working with vulnerable adults.
Our organisation
Diverse Supported Accommodation CIC is a Community Interest Company registered in England and Wales (company number 14181585) with its registered office at 71-75 Shelton Street, London WC2H 9JQ. We provide supported housing for adults with mental health needs across Greater London.
Our supply chain
Because we operate as a housing provider with an in-house maintenance team, our direct supply chain is relatively short. It includes:
- Building materials and trades supplies (sourced from UK suppliers)
- Furniture and white goods for furnished accommodation
- IT and software services (including our repair-reporting platform)
- Professional services (accountants, legal, insurance)
- Cleaning and gardening products
- Specialist contractors where in-house cover is not available
We do not procure goods or services from regions identified as high-risk for modern slavery without additional due diligence.
Areas of potential risk
Within our operating model, we recognise the following areas of potential modern slavery or trafficking risk:
- Contractors and sub-contractors in trades and maintenance services, particularly where labour is informally sourced
- Cleaning and grounds contractors, an industry historically associated with labour exploitation
- Residents themselves, who may have been victims of trafficking or labour exploitation before being referred to us, and who may still be at risk
- Furniture and goods supply chains, particularly imported items
Steps we take
Procurement & contractors
- We use direct employment for most maintenance, gardening and cleaning work — reducing exposure to opaque sub-contracting
- Where we do use external contractors, we require them to comply with our modern slavery expectations as a condition of engagement
- For larger contracts, we ask contractors to confirm they meet section 54 obligations (where applicable) or to publish equivalent commitments
- We pay all our staff at or above the relevant National Living Wage / London Living Wage rates and do not use unpaid trial shifts
Recruitment
- All staff complete Right to Work checks before commencing employment
- Two written references are taken and verified
- Identity and address documentation is checked and retained on personnel records
- Our induction includes awareness of the signs of modern slavery and trafficking
Awareness for our work with residents
- Our staff and partner support providers receive awareness information on modern slavery indicators, given the elevated vulnerability of the residents we house
- Concerns about a resident's exploitation are referred via local authority safeguarding routes (see our Safeguarding Adults statement) and, where appropriate, to the National Referral Mechanism
Reporting
- We treat any reasonable suspicion of modern slavery in our operations or supply chain as a safeguarding concern under our standard policy
- Staff, contractors and partners can raise concerns via info@dsacic.co.uk or through the whistleblowing route in our Safeguarding Adults statement
Effectiveness & review
We will assess the effectiveness of these measures by:
- Tracking any modern slavery concerns reported or referred (target: all logged and responded to)
- Reviewing contractor compliance documentation annually
- Including modern-slavery awareness in our induction and ongoing training records
This statement is reviewed and re-published annually. It is approved by the sole director of Diverse Supported Accommodation CIC.
Approved by: Sukhbir Singh Ahluwalia, Director
Date approved: [To confirm]