Slavery and Human Trafficking Statement 2018/19

by The Gateshead Housing Company & filed under Governance - Modern Slavery Act.


The Gateshead Housing Company (“TGHC”) is a not-for-profit Arms-Length Management Organisation (ALMO) and a wholly owned subsidiary of Gateshead Council. We were set up in 2004 to manage the Council’s properties, to improve housing in order to meet the Government’s Decent Homes standard. We currently manage:

  • 18,964 council homes on behalf of Gateshead Council
  • 929 Leasehold properties

Our structure, business and supply chains

The principal activity of the company is the day-to-day management, maintenance and improvement of the housing stock of Gateshead Council and Keelman Homes.

The company also manages the building of new properties to be owned and managed by the company, where funding is available, and manages new-build programmes for both Gateshead Council and Keelman Homes.

The company also provides housing management services for several properties which are owned by registered providers and for the Council through the Private Empty Homes Programme.

A Property and Assets Directorate was established in April 2017 following the transfer of employees from Mears and Gateshead Council Construction Services. This effectively doubled the size of the workforce from 400 to 800. This brought the delivery of repairs and maintenance in-house and increased the company’s turnover to over £50 million.

Further information about our activities is detailed on our website at

Policies in relation to slavery and human trafficking

A Slavery and Human Trafficking Policy was agreed by the Board in July 2018. This reinforces our zero-tolerance approach to any form of modern slavery and trafficking. It also informs employees what they should do if they suspect modern slavery and tracking may be occurring within our supply chain.

We also have a number of associated policies including a TGHC Safeguarding Adults Policy, Children’s Safeguarding multi-agency policy and procedures, Anti Bribery, Fraud and Corruption and Whistleblowing Policy and a Single Equality and Inclusion Scheme, as part of our public-sector equality duty which includes the elimination of unlawful discrimination.

TGHC is also committed to the continual assessment of recruitment procedures and practices in order to comply with current employment legislation, and recruit staff according to best practice. Equality impact assessments are carried out on all HR-related policies to ensure they promote equality of opportunity.

Due diligence processes in relation to slavery and human trafficking in our business and supply chains

As a group we are governed by the Public Contract Regulations 2015, which are underpinned by our Financial Regulations and Contract Procedure Rules. This includes, as appropriate, a supplier suitability or pre-qualification questionnaire containing checks relating to a suppliers economic and financial standing, as well as compliance with labour law.

In addition, our standard contract terms require our suppliers to adhere to all of our policies and rules, together with compliance at all times with the Law in the performance of the contract.

Effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chains

We are confident that slavery and human trafficking is not taking place amongst our first-tier suppliers, due to the due diligence processes that we currently have in place, but we cannot be as certain that slavery and human trafficking is not taking place further down our supply chains.

All our tender documents, which are issued by Gateshead Council’s Corporate Commissioning and Procurement, include specific prohibition against any contractor who has been convicted of any offence involving slavery and human trafficking or the subject of any investigation, enquiry or enforcement proceedings by any governmental, administration or regulatory body. There is also a requirement that the contractor shall implement due diligence procedures for its own suppliers, sub-contractors and any other participants in its supply chains, to ensure that there is no slavery or human trafficking in its supply chains.

Training about slavery and human trafficking available to employees

Whilst TGHC employees do not currently undertake specific slavery training, following the introduction of the Care Act 2014 and the Modern Slavery Act 2015, ‘modern slavery’, a new category of abuse, is covered within Gateshead’s multi-agency Safeguarding Adults training courses. This training is targeted at employees who are responsible for making a referral to other services or those managers who have organisational or professional responsibility to safeguard adults at risk and who partake in risk assessments and protection planning. This training is mandatory and includes all employees in the Property and Assets Directorate.

Children’s Safeguarding training can also be accessed via Gateshead’s Children and Adults Safeguarding Training Directory.

During 2016/17, the company implemented its own TGHC Safeguarding Policy which is line with Gateshead Council’s approach to Safeguarding and will apply it to relevant policies as needed.

The company also delivered, through the Safeguarding training programme, training for relevant employees relating to their roles and responsibilities in relation to the eradication of slavery and human trafficking within the organisation and our supply chains. In addition, the company rolled out further safeguarding awareness briefings during 2019/20.

All safeguarding concerns (including suspected acts of modern slavery) are coordinated through a central point of contact within the company’s Neighbourhood Relations Team, which ensures appropriate gatekeeping, consistency, and that appropriate levels of intervention and referrals are made.

The company took part in Gateshead Safeguarding Board speed safeguarding drop-in event in November 2019. The event brought together experts from various organisations, such as Northumbria Police, Health, and the voluntary sector, to discuss all aspects of safeguarding adults, sharing information and good practice.

During the forthcoming year, we intend to:

  • Continue to deliver, through the Safeguarding training programme, training for relevant employees
  • Roll out further safeguarding awareness briefings

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and has been approved and published by the TGHC Board and will be reviewed annually.

Signed: Jim Coulter
Position: Chair of the Board
Date: 24 September 2020

Signed Slavery and Human Trafficking Statement 2019-20 (PDF)