Template — Requires legal review Section 54 of the Modern Slavery Act 2015 strictly requires a statement only from organisations with a turnover above £36 million. Diverse Supported Accommodation CIC is below that threshold, so this is a voluntary statement we publish in the spirit of the Act. Please have a solicitor review before publishing and update annually.

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]