Modern slavery statement

We are Scotland's leading housing, and property management group and employ over 2,500 people.

Wheatley Homes Glasgow Limited, Wheatley Homes South, Wheatley Homes East and Loretto are subsidiaries of the Wheatley Housing Group Limited, Registered Social Landlords and registered charities.  Their principal business is social housing.  Lowther Homes (private rented tenancies, mid-market rent and property factoring), and The Wheatley Foundation (charitable support) are also covered by this statement.

We are committed to the highest ethical standards of business and ensuring there is no slavery or human trafficking in any part of our business or supply chain. Each entity in our group complies with applicable human resources legislation and the national minimum wage.

We are committed to developing the economies of the areas we work in and building strong relationships with local suppliers.   We operate solely within Scotland and do not have a large global supply chain. Our principal supply chains include construction and maintenance contractors; facilities management services; security services; ICT suppliers; and office and operational goods.

Our procurement is undertaken within the context of a wide range of legislative and regulatory requirements, including the Public Contracts (Scotland) Regulations 2015, The Procurement (Scotland) Regulations 2016, Procurement Reform (Scotland) Act 2014.

A contracts register is published on our website which contains details of our main suppliers. We update this annually.

We have a specialist procurement function that has primary responsibility for procuring goods and services on a group-wide basis in accordance with the aforementioned legislation and regulation.  High-value contracts require approval by the Board. We encourage our suppliers to sign up to our Wheatley Pledge.

We adopt a Community Benefit approach to our procurement and publish a Community Benefits Statement annually. Monitoring and reporting on this demonstrates that we, our partners and supply chain are making a positive difference to individuals, enhancing communities and supporting wider economic resilience. Through this:

• we require suppliers to declare Fair Work practices within their workforce and sub-contractors, as well as non-discrimination and promotion of Equality, Diversity and Inclusion policies;
• we seek to ensure suppliers' compliance with the Modern Slavery Act 2015. We implement this through the use of clauses in our contract conditions and ensure our commitment is embedded within our procurement strategy;
• Community Benefits are built into all contracts where clear benefit(s) can be gained by our communities. Progress on the implementation of Community Benefits will be managed and maintained in line with the Group’s Community Benefits Statement.

We have assessed our risk of exposure to slavery and human trafficking as low following our annual review of the measures we take to reduce the risk of exposure.

During 2025/26, these included:   :

• Standard contract terms including a provision that requires suppliers to comply with the Modern Slavery Act 2015;
• Regular contract management meetings with suppliers to confirm performance is in line with contractual terms;
• Quarterly review of supplier risk assessments;
• Annual review of our procurement policy and strategy;
• Mandatory annual training for staff on our Fraud, Corruption and Bribery Policy;
• Refreshed procurement training for staff, including our Passport to Procure e-learning; and
• the requirement of a formal declaration from suppliers that they comply with the Modern Slavery Act 2015.

To provide assurance that suppliers are complying with our contract terms, we review the Modern Slavery Statements and approaches of our contractors operating in sectors with an increased risk of forced labour (being construction framework contractors; facilities management contractor; and security contractor),  to confirm we are satisfied their statements.

We will ensure that relevant sections of our workforce understand the risk to our business from slavery and human trafficking and are equipped to identify and respond in situations where they suspect bad practice.  We have our Protecting People policy framework in place to support our staff to identify vulnerable people and have staff training for this also.

This Framework and training ensures our frontline staff who visit tenants and service users are trained to identify signs of exploitation and understand that instances of this should be reported to managers who would then work with other agencies including Social Service and Police Scotland to assess such cases.

Any concerns regarding potential modern slavery or labour exploitation are investigated in accordance with Group policies. Where concerns relate to suppliers, Wheatley will engage with the supplier, seek corrective action and, where appropriate, work with relevant agencies to safeguard affected individuals

Our staff can raise concerns or make complaints in relation to modern slavery and human trafficking through anonymous whistleblowing services, such as a helpline, or through trade unions or other worker representative groups. We promote grievance mechanisms for example, through our whistleblowing policy and video from policy lead highlighting to staff the process for whistleblowing.

We operate the following policies, each of which is designed to prohibit discrimination, support legal compliance and best practice:

• Recruitment Policies;
• Employee Code of Conduct;
• Procurement Policy and Strategy;
• Group Sustainable Procurement Policy;
• Whistleblowing Policy;
• Anti-fraud, Bribery and Corruption Policy;
• Equality, Diversity and Human Rights Policy;
• Scheme of Financial Delegation; and
• Group Protecting People Policy Suite

During 2026/27, we will complete our annual review of measures to reduce the risk of exposure to modern slavery and review any modern slavery risks within our construction supply chains as part of the development of a revised framework for construction suppliers.