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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.

1 Organisation
This statement applies to Stay. The information included in the statement refers to the financial year
2026-2027.

2 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.

3 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

4 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.

5 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.

6 Risk Assessment: Identifying Vulnerability
We recognise that modern slavery is a complex crime. While we consider the risk within our direct
employment to be low, we acknowledge that the risk to our service users (clients/tenants) is high
due to their personal circumstances.
Key areas of exposure include:

  • Client Exploitation: Vulnerability to forced labour, sexual exploitation, and debt bondage.
  • Criminal Exploitation & “Cuckooing”: The risk of criminals taking over a vulnerable person’s
    home for illegal activities (e.g., County Lines).
  • Supply Chains: Risks associated with partner organisations, property landlords, cleaning,
    catering, and office utilities

7 Due Diligence and Supply Chain Management
Stay does not enter into business with any organisation known to be involved in slavery or forced
labour. We perform due diligence by:

  • Reviewing the anti-slavery practices of landlords and partner organisations.
  • Auditing suppliers of goods and services (e.g., cleaning and catering).
  • Ensuring TUPE transfers and recruitment processes include rigorous identity and right-towork checks

8 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:

  • Anti-slavery Policy
  • Code of Conduct
  • Grievance Policy
  • Public Interest Disclosure (Whistleblowing) Policy
  • Anti-bullying, Harassment and Discrimination Policy
  • Equality, Diversity, and Inclusion Policy
  • Recruitment and Retention Policy
  • Safeguarding Vulnerable Adults Policy
  • Safeguarding Vulnerable Children Policy
  • Whistleblowing Policy: Protecting those who raise concerns in confidence.

9 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

10 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.
They also receive training on:

  • Trauma-Informed Approaches: Recognizing that victims may not self-identify as being
    exploited.
  • Specialist Focus: Training specifically addresses County Lines

11 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
4 Version 2
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.

12 Next Steps for financial year 2026/27
Building on our existing commitments, during the financial year 2026/27, 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.
  • Continue to take action to embed a zero-tolerance policy towards modern slavery.
  • monitor developments in legislation and best practices related to modern slavery and
    safeguarding.
  • Educate tenants and clients on the risks of exploitation and how to seek help.
  • Strengthen Referrals by refining referral pathways for suspected victims of modern slavery.

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