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Housing Management Services

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Housing Management Services

Modern Slavery Policy

Purpose of the Policy

The Operations Manager has implemented this policy to support the company in ensuring that This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers.

Theori Housing Management Services Limited strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Modern Slavery and Human Trafficking

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

Commitments

  • We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
  • We conduct a strict approach to our contracting processes and vetting and keep them under review. We assess whether the circumstances warrant the inclusion of specific exclusions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our approach, we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

Consistent with our approach we may require:

  • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct.
  • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the Code
  • As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.
  • If we find that other individuals or organisations working on our behalf have breached this policy, we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.

Our Policy on Slavery and Human Trafficking

Theori Housing Management Services are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-Slavery policy reflects our ongoing obligation to acting ethically and with integrity in all our business relationships and to implement and enforcing systems and controls to ensure slavery and human trafficking is not taking place anywhere near our business.

We have established processes across our business, our trading partners and our supply chains to;

  • Identify inappropriate employment practices.
  • Identify and assess other potential risk areas.
  • Mitigate the risk of slavery and human trafficking occurring.
  • Monitor potential risks areas.
  • Protect whistleblowers.

Responsible Persons

Suppliers, contractors, Senior Management, Operations Manager, Directors

References

Reviewing of current process and information.

Evaluation of Compliance

Will be continually monitored.

Exclusions

None

Records

Information will be recorded and stored as a record retention for 5 years on the secure company server with restricted access only to senior management and Directors.

Created: 21/11/2025
Last Updated: 21/11/2025