Modern Slavery Statement

Stay is committed to preventing modern slavery and human trafficking in all its activities and supply chains. We recognize that people experiencing homelessness are particularly vulnerable to exploitation and are dedicated to ensuring our operations and services uphold the highest ethical standards and respect for human rights. 

Organisation

This statement applies to Stay. The information included in the statement refers to the financial year 2025–6. 

Our Organisation

Stay employees work across various sites all within Telford and Wrekin.  The registered office address is Meeting Point House, Southwater Square, Telford TF3 4HS.  Stay is run by a Board of Trustees and its Management Team.  

The aim of Stay’s work is to prevent the causes of homelessness, respond and support those who face homelessness or housing difficulties and to champion the needs of homeless people and help empower people to gain independence. Stay achieves this by providing supported accommodation to homeless and vulnerable people within Telford & Wrekin.  We also provide practical support, advice and guidance via our Outreach Workers and The Net Intensive Support Service. 

All of Stay’s work is carried out within the Borough of Telford and Wrekin by our own employees, or on occasion agency workers. 

As a charity supporting individuals experiencing homelessness, we understand the heightened risk of exploitation faced by this population. We are vigilant in our interactions with clients/tenants and have safeguarding policies and procedures in place to identify and support potential victims of modern slavery. Our staff are trained to recognise the signs of exploitation and understand reporting mechanisms. 

Definitions

“When an individual is exploited by others, for personal or commercial gain. Whether tricked, coerced, or forced, they lose their freedom.” Anti-Slavery International (2023).  Stay considers that modern slavery encompasses: 

  • Being held in slavery or servitude 
  • human trafficking 
  • forced work, through mental or physical threat 
  • being owned or controlled by an employer through mental or physical abuse or the threat of abuse 
  • being dehumanised, treated as a commodity or being bought or sold as property 
  • being physically constrained or to have restriction placed on freedom of movement 
  • Being sexually exploited and/or forced pregnancy 
  • Being forced to commit crimes

Our Commitment

Stay acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015.  Stay understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains. 

Stay does not enter into business with any other organisation which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour. 

No labour provided to Stay in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking.  Stay’s processes ensure that prospective employees are legally entitled to work in the UK and safeguards employees from any abuse or coercion.  Stay strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation and in many cases exceeds those minimums in relation to its employees. 

Potential Exposure

In general, Stay considers its exposure to slavery/human trafficking to be low.  Nonetheless, it takes steps to ensure that such practices do not take place in its organisation, nor the business of any organisation that supplies properties or services to it. 

We recognize that our potential exposure to modern slavery exists primarily in two key areas: 

  • Our clients and tenants: People experiencing homelessness can be particularly vulnerable to various forms of exploitation, including forced labor, sexual exploitation, and criminal exploitation. Their circumstances can make them targets for individuals and organised groups involved in modern slavery. 
  • Our Supply Chains: the majority of our procurement is for essential operational needs. 

Supply chains

In order to fulfil its activities, the main supply chains of Stay include those related to property landlords and our partner organisations within The Net, as well as the day to day running of the charity such as office supplies, utilities, and cleaning services. 

We implement due diligence procedures on all our suppliers, including requesting information on their anti-slavery practices and conducting audits when deemed necessary. 

We expect our suppliers to adhere to ethical labor practices and respect human rights. We seek to work with suppliers who share our commitment to these principles. 

Our policies in relation to the Modern Slavery Act 2015

Stay endeavours to raise awareness among all employees of the identification, prevention and eradication of modern slavery and human trafficking, and has policies and procedures in place to ensure that they can do so. The following policies are available to all staff via the Staff Handbook Folder on Stay’s SharePoint: 

  • Code of Conduct 
  • Grievance Policy 
  • Public Interest Disclosure (Whistleblowing) Policy 
  • Anti-bullying, Harassment and Discrimination Policy 
  • Anti-slavery Policy 
  • Equality, Diversity, and Inclusion Policy 
  • Recruitment and Retention Policy 
  • Safeguarding Vulnerable Adults Policy 
  • Safeguarding Vulnerable Children Policy 

Due Diligence

Stay carries out due diligence processes in relation to ensuring modern slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers and requesting suppliers confirm their compliance with the Act. 

Stay has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery. 

In accordance with section 54(4) of the Modern Slavery Act 2015, Stay takes the following steps to ensure that modern slavery is not taking place: 

  • due diligence when working with landlords and potential landlords. 
  • due diligence of suppliers/potential suppliers of goods. 
  • due diligence of partner organisations. 
  • due diligence in recruitment 
  • due diligence regarding TUPE 
  • protect those who wish to raise concerns in confidence. 

Training and Awareness

Our staff are provided with Modern Slavery training on induction and then on a 12 monthly basis, to raise awareness and understanding of modern slavery and equip them to identify potential risks and know how to report any concerns. 

Monitoring and Review

We are committed to continuously monitoring and reviewing our practices to ensure their effectiveness in preventing modern slavery. This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed and updated annually at the end of each financial year to reflect any changes in our approach.  

Next Steps

Building on our existing commitments, during the financial year 2025/2026, Stay will undertake the following specific actions to further strengthen our approach to preventing modern slavery: 

  • continue to make our staff are aware of the Modern Slavery Act 2015 and inform them of the appropriate action to take if they suspect a case of slavery or human trafficking, with a specific focus on identifying indicators of exploitation within the homeless population and referral pathways. 
  • continuing to take action to embed a zero-tolerance policy towards modern slavery. 
  • monitor developments in legislation and best practices related to modern slavery.  
  • Raise awareness with our clients/tenants about the risks of exploitation and how to seek help if they are concerned. 

concerns

Any concerns regarding modern slavery and/or human trafficking can be addressed to Naomi Pay, Chief Executive Officer who will then undertake relevant action with regard to Stay’s obligations.