In the financial year 1 April 2017 to 31 March 2018, NHBC continued its commitment and activities to combat instances of slavery and human trafficking that may have been present in its business and supply chain.
NHBC is the UK's leading warranty and insurance provider for new homes. Its purpose is to work with NHBC registered house builders and developers to help improve the construction standards of the new homes they build for the benefit of homeowners.
NHBC supplies inspection services, guidance and training to builders and developers and provides protection for homebuyers through its range of Buildmark warranty and insurance products.
With no shareholders, NHBC is able to invest surpluses in its purpose of helping to improve the quality of UK house building. NHBC also works with government and stakeholders to help shape housing policy.
NHBC is authorised by the Prudential Regulation Authority and regulated by the Financial Conduct Authority and the Prudential Regulation Authority. NHBC is a private company limited by guarantee. It has approximately 1,300 employees and operates in the UK.
NHBC supply chain
NHBC’s supply chain consists of the supply of goods and services required to support the delivery of NHBC’s trading activities.
NHBC’s supply chain continues to fit into three main categories:
- The settlement of claims activities (e.g. remedial works contractors and consultants who carry out work in relation to NHBC's Buildmark warranty product);
- Business to business services (e.g. marketing and events, IT and telecommunications, travel, car fleet, consultancy and other professional services);
- Operational services - all other procurement of goods and services (e.g. Personal Protective Equipment, cleaning, catering, stationery, maintenance of NHBC's offices etc.).
There were no substantial changes to NHBC's supply chain during the financial year.
Update on activity following NHBC’s 2017 statement
NHBC continues to make progress with its commitment and activities to combat slavery and human trafficking:
- The updated Procurement and Supplier Governance Policy (Policy) confirms that NHBC seeks to identify suppliers who share similar values and comply with the Modern Slavery Act 2015 (Act). The Policy is becoming established within the business, championed by the Procurement department which is leading the selection process for high risk/ high value suppliers;
- NHBC is starting to roll out the Policy across its business, specifically in regard to locally procured and lower risk / lower value purchases;
- The Policy introduces a Procurement Code of Conduct (Code) which outlines the principles to be adhered to by all staff when undertaking procurement activities on behalf of NHBC. The Code includes professional standards, and raises awareness of human rights, forced labour and modern slavery;
- A new E-Procurement system (Prolink) has been introduced to support the Policy. Prolink improves the way in which NHBC undertakes due diligence during the supplier selection process, in the following ways
- the pre-qualification stage of the procurement process asks suppliers to confirm their compliance with the Act or to provide details of their approach to modern slavery; and
- Prolink assists NHBC in monitoring existing suppliers for the purpose of on-going due diligence.
- Through internal communications, NHBC has made its staff aware of its approach to the Act;
- NHBC has established internal processes through which concerns on modern slavery can be rep orted. This is either through:
- the NHBC Whistleblowing Policy and process;
- the "Speak Up" confidential telephone line available to staff 24 hours a day, 7 days a week;
- the Incident Reporting and Management Process; and
- escalation directly to a line manager, and followed up through one of the above reporting channels.
Looking ahead to financial year 18/19
For the current financial year, NHBC will continue in its commitment to combat any instances of slavery and human trafficking in its business and supply chain. This will be achieved by:
- Completing the roll-out of the Policy across NHBC. This will be delivered through a programme of presentations, workshops and communications, and will be completed by October 2018;
- Introduction of a Supplier Coder of Conduct into the procurement process;
- NHBC will provide modern slavery awareness training through an E-Learning training module. It will be assigned to more than 100 roles across NHBC where employees are responsible for the selection or management of NHBC's suppliers. This includes the Procurement team, contract and business owners, Heads of Department and the Executive Committee. Training will be completed by October 2018;
- NHBC will continue to monitor changes within its supply chain and will update its approach accordingly;
- NHBC will continue to monitor the external environment in order to ensure that the risk within NHBC's supply chain remains low; and
- NHBC will continue to communicate to all employees on NHBC's position and approach to the Act.
NHBC is committed to ensuring that its processes and approach are appropriate, effective and reflect the risks within its business.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015, and constitutes NHBC's slavery and human trafficking statement for the financial year ended 31 March 2018.
Chief Executive Officer Date: 21st September 2018