INTRODUCTION 


This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. Modern slavery is a crime and a violation of human rights. It takes various forms, including slavery, servitude, compulsory labour and human trafficking for exploitation and can have a significant adverse impact on individuals, families, and communities across the world. 

Thrive own and manage nearly 6,000 homes throughout Hertfordshire, Bedfordshire Buckinghamshire and Oxfordshire. We are a charitable Housing Association, registered as a Community Benefit Society and are also registered with the Regulator of Social Housing. We employ over 170 colleagues with an annual turnover of £55.3m. 

COMPLIANCE 


In accordance with our Anti-slavery and Human Trafficking Policy, Thrive has a zero tolerance to modern slavery. Our approach is communicated to all colleagues as well as Board and Committee Members. The Board has overall responsibility for ensuring that Thrive complies with its legal and ethical obligations and that its policies are implemented effectively. At an operational level, line managers are responsible for engaging with their teams to implement and maintain the processes in place, ensuring all colleagues are informed and appropriately trained. Clear processes are in place for anyone who has any concerns about modern slavery and where to raise those concerns. 
As a supplier of services to individuals and communities, we recognise slavery and human trafficking as a potential risk. We address this risk through a number of organisational policies which include: 

  • Whistleblowing Policy  

  • Dignity at Work Policy 

  • Disciplinary Policy 

  • Recruitment & Selection Policy 

  • Onboarding Policy 

  • Procurement & Contract Management Policy 

  • Safeguarding Policy 

  • Professional Conduct & Probity Policy  

  • Domestic Abuse Policy 

  • Learning and Development Policy 

  • Equality, Diversity and Inclusion Statement of Intent 

 

HOW WE MANAGE RISK 

We understand that strong procurement and supplier relationship management processes may improve our business performance; this is by acquiring the best value goods and services. As part of Thrive’s supplier onboarding process, all suppliers are required to declare whether they have been involved in any breach of the Modern Slavery Act within the last five (5) years. Modern slavery constitutes an exclusion ground under public procurement regulations. Suppliers convicted of specific modern slavery offences during this period will be automatically excluded from participating in public procurement processes unless they can demonstrate that appropriate remedial actions have been taken to address and rectify the breach.  

COLLEAGUES 

Colleagues are required to avoid any activity that might lead to, or suggest, a breach of this statement. Colleagues are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our organisation or supply chains at the earliest possible stage. 

Disclosure can be made to an appropriate person under the Whistleblowing Procedure or to the Governance team. All Thrive’s policies emphasise our commitment to dignity at work and the fair treatment of colleagues and all policies are available to everyone in the organisation. To ensure the risks of modern slavery and human trafficking in our supply chains and our business are understood, all new colleagues undergo a training session on modern slavery as part of their induction. Thrive also provides a mandatory e-learning module to be completed annually by all colleagues, with additional training for those responsible for hiring and contracting through agencies. 

NEXT STEPS                                     

In the next 12 months we intend to take the following steps: 

  • Build on the existing practices in the business where contracts are procured outside of the procurement process to ensure that appropriate checks have been made. 

  • Encourage prospective suppliers to sign up to the Supplier Code of Conduct. 

  • Continue to raise awareness through various means across the business. 

  • Ensure that mandatory training for our employees is completed at induction as well as maintaining high levels of compliance of ongoing training. 

  • Continue to monitor our risk exposure, focussing on key areas of risk. 

As an organisation we continue to work together to tackle the risk of modern slavery and increase our efforts to engage with suppliers, following robust processes to tackle the risk of modern slavery and human trafficking. 

This statement has been approved by the Thrive Homes Board on 8 December 2025.