NHBC Modern Slavery Statement
In the Financial Year 1 April 2016 to 31 March 2017 NHBC has continued its commitment and its activities to combat any instances of slavery and human trafficking that may be present in its business and supply chain.
NHBC is the UK’s leading independent provider of warranty insurance for new homes. Its purpose is to work with NHBC registered house builders to help improve the construction standards of the new homes they build for the benefit of house-building industry.
NHBC supplies inspection services, guidance and training to builders 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. It 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);
- Business to business services (e.g. marketing and events, IT and telecoms, travel, car fleet, consultancy and other professional services including outsourcing arrangements);
- Operational services – all other procurement of goods and services (e.g. PPE, cleaning, catering, stationery, maintenance of NHBC’s offices etc.).
There has been no change to the type of supplier within the NHBC supply chain during the year and we have taken further steps to reduce the risk in our supply chain through:
- Improvements to the supplier selection process
- Raised awareness within NHBC
- Engaging with our larger suppliers.
NHBC considers that the risk of modern slavery within its supply chain has been reduced with these improvements.
Update on activity following NHBC’s 2016 statement
NHBC has continued with its commitments made to Modern Slavery in the 2016 statement and made progress as follows:
- Updated the new Procurement and Supplier Governance Policy (Policy) to include reference to the Modern Slavery Act 2015 (Act). The Policy confirms that NHBC seeks in its selection process to identify suppliers who share similar ethical values and comply with the Act;
- Introduced improvements to the procurement process by updating the pre-qualification questionnaire stage of the supplier selection process in order to establish potential suppliers’ compliance with the Act;
- Considered the inclusion of appropriate contractual provision for suppliers’ compliance with the Modern Slavery Act within all new contracts between NHBC and our suppliers;
- Engaging with various stakeholders across NHBC who have responsibility for supplier selection and in life contract management to raise awareness of the requirements of the Act;
- Confirmed the provision for escalating and reporting concerns with supplier behaviour/activity within existing risk and compliance and whistleblowing policy and processes;
- Agreed a communications plan to raise awareness of modern slavery across NHBC;
- Taken a phased approach to contact existing suppliers in order to share NHBC’s position regarding modern slavery and to ask for suppliers to confirm their compliance with the requirements of the Act;
- Received and responded to requests from NHBC’s customers, relating to NHBC’s compliance with the Act.
Looking ahead to financial year 17/18
During the Financial Year 1 April 2017 to 31 March 2018 (inclusive) NHBC will further build upon progress made since the 2016 statement and focus on:
- Contacting more of NHBC’s existing suppliers, taking a risk based approach, to establish their compliance with the Act;
- Monitoring changes within NHBC and the external environment to ensure the risk within NHBC’s supply chain remains low risk;
- Enhancing the process for assessing and monitoring supplier compliance with the Act during the procurement process and in-life contract;
- Continue the training NHBC employees who have responsibility for contracting with and managing NHBC suppliers;
- Communicating with the entire organisation on NHBCs position and approach to the Act; and
- Liaising with NHBC’s legal department to ensure adequate contractual protections are included in supply contracts and to ensure that suppliers comply with the Act.
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 2017.
Chief Executive Officer Date: 29th September 2017