BSJ Housing Solutions

BSJ Housing Solutions

Prevention of Modern Slavery and Human Trafficking Policy

Organisation: BSJ Housing Solutions
Policy Title: Prevention of Modern Slavery and Human Trafficking Policy
Effective Date: 15/3/2026
Review Date: Annually or sooner if legislation changes
Approved by: Board of Directors

1. Policy Statement

BSJ Housing Solutions is committed to preventing modern slavery, forced labour, human trafficking and exploitation in all areas of our operations, housing services, development activities and supply chains. Modern slavery is a serious criminal offence and a violation of fundamental human rights. It includes slavery, servitude, forced or compulsory labour, and human trafficking. BSJ Housing Solutions adopts a zero-tolerance approach to modern slavery and is committed to acting ethically, transparently and with integrity in all business relationships. This policy supports compliance with the Modern Slavery Act 2015, which requires organisations to take steps to ensure slavery and human trafficking are not taking place in their operations or supply chains.

2. Purpose of the Policy

The purpose of this policy is to:
• Ensure compliance with UK legislation relating to modern slavery.
• Protect tenants, service users, staff and contractors from exploitation.
• Ensure ethical procurement and supply chain practices.
• Support transparency and accountability across BSJ Housing Solutions’ operations.
• Provide clear guidance for identifying and reporting modern slavery risks.

3. Scope

This policy applies to: Employees, Volunteers, Board members and directors, Contractors and subcontractors, Suppliers and service providers, Development partners and construction contractors, Recruitment agencies and labour providers. The policy covers all operations of BSJ Housing Solutions, including: Housing management, Property maintenance and construction, Procurement and contracting, Partnerships with local authorities and support organisations.

4. Legal and Regulatory Framework

This policy supports compliance with: Modern Slavery Act 2015, Transparency in Supply Chains requirements (Section 54), UK statutory guidance on modern slavery reporting (updated 2025), Procurement Act 2023. Where applicable, BSJ Housing Solutions will publish an annual Modern Slavery Statement outlining actions taken to prevent exploitation in line with government guidance.

5. Our Commitments

BSJ Housing Solutions will: Maintain ethical employment practices, fair recruitment, and supply chain responsibility. Including requiring suppliers to comply with the Modern Slavery Act 2015 and including anti-slavery clauses within contracts. We will conduct due diligence checks during procurement and monitor high-risk sectors such as construction, cleaning and maintenance.

6. Risk Areas in Housing Services

The housing sector can face increased risk of labour exploitation due to: Construction and development supply chains, Maintenance contractors and subcontractors, Cleaning and facilities management, Agency and temporary labour providers, Migrant worker recruitment. BSJ Housing Solutions will apply enhanced due diligence in these areas.

7. Identifying Signs of Modern Slavery

Possible indicators may include: Workers appearing fearful, withdrawn or controlled; Individuals unable to speak freely or travel independently; Workers not holding their own ID or passports; Poor living or working conditions; Workers being transported to work by a controlling individual; Evidence of withheld wages or debt bondage.

8. Reporting Concerns

Anyone who suspects modern slavery must report concerns immediately to: Line managers, the Safeguarding Lead, or Senior Management. Concerns can also be reported externally to: UK Modern Slavery Helpline (08000 121 700) or Police (999 if immediate danger). All reports will be treated seriously and handled confidentially.

9. Responsibilities

Board of Directors: Provide oversight of modern slavery risk management. Senior Management: Implement this policy across the organisation. Staff and Volunteers: Remain aware and report concerns. Suppliers and Contractors: Must comply with UK legislation and ethical standards.

10. Training and Awareness

BSJ Housing Solutions will: Provide modern slavery awareness training to staff, ensure procurement staff understand supply chain risks, and promote awareness of reporting mechanisms.

11. Monitoring and Compliance

BSJ Housing Solutions will monitor this policy through: Procurement and supplier audits, Contract compliance monitoring, Risk assessments in high-risk sectors, Board review of modern slavery controls. Any breach may result in: Disciplinary action, Contract termination, Referral to law enforcement.

12. Policy Review

This policy will be reviewed: Annually, when relevant legislation changes, or following significant organisational changes. The review will ensure alignment with UK anti-slavery legislation, government guidance and housing-sector best practice.