Pinnacle Group is committed to opposing modern slavery in all its forms and preventing it by whatever means we can.
We demand the same attitude of all who work for us and expect it of all with whom we have business dealings. We have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business transactions.
Please see Pinnacle Group’s Modern Slavery Transparency Statement below.
Modern Slavery Transparency Statement 2022
Table of Contents
The purpose of this statement is to confirm that Pinnacle Group Ltd and other relevant group companies1 (“Pinnacle”) have taken appropriate steps during the year ending 31st March 2022 to ensure our continued compliance with the Modern Slavery Act 2015 (the “Act”). As a business we are committed to providing employment opportunities which are non-discriminatory, support living wage legislation, and offer regular hours and working conditions that are safe and hygienic. We are also committed to implementing and enforcing effective systems and controls to ensure that there is no modern slavery or human trafficking taking place anywhere in our own business or in any of our supply chains.
 This statement covers all subsidiaries of the group, but particularly Pinnacle Group Ltd, Pinnacle Housing Ltd and Pinnacle FM Ltd who each fall within the scope of section 54(2) of the Modern Slavery Act 2015.
Pinnacle is a community-facing, people-first business that delivers, manages and maintains communities and places where people Live, Learn, Work & Play including multi-tenure housing, schools/universities, open spaces, public/private buildings, retail centres, manufacturing plants and district heating networks.
We currently manage a portfolio of 80,000+ homes across a wide variety of tenures. We also provide integrated neighbourhood FM services to over 300,000 homes, more than 200 schools, academies and universities, and a range of public open spaces. We now provide more than 1 million hours of security and concierge services each year.
Additionally, we deliver a range of neighbourhood-related services that support the sustainability of low-income communities including employment, skills and training services on behalf of Central Government, the design, build and operation of district heating networks and the installation and operation of our own hyper-fast broadband network.
Our business operates across public and private sectors, and we now directly employ over 3,700 people of more than 50 different nationalities, operating from over 100 locations across the UK. Our service infrastructure allows us to “localise” service delivery and be a part of the communities we serve.
Further business information can be found at https://www.pinnaclegroup.co.uk.
Pinnacle is heavily reliant on its people and supply chains in the delivery of services. We are also aware of our diverse customer base with a wide range of backgrounds and needs. Each business within the group is responsible for ensuring that they can demonstrate compliance with the Act by working to our Group policies and procedures.
Due diligence across our business and supply chain
Our governance in relation to slavery and human trafficking
Pinnacle has a reputation for and prides itself on being a moral and principled employer. We believe this provides a platform to deliver a more consistent service and quality across our contracts and sends out a message that we care about the wellbeing of the people working for us.
We support living wage requirements and regularly review our terms of employment to ensure that they comply with all relevant legislation.
All staff employed by Pinnacle have identity and Right to Work checks, employment reference checks, and where applicable DBS checks prior to employment commencing. These checks are always carried out in line with the relevant legislation and in accordance with UK Government guidance. For certain roles, where additional background checks are required, a more in-depth vetting process is in place.
Our HR and Payroll system provides us excellent transparency in this area, through extensive DBS workflows and reporting to incorporate 3-yearly checks, significantly reducing any compliance risk.
During the pandemic, we developed and implemented a new Order Management System which enhanced our ability to make quick decisions and bring on new suppliers safely, whilst supporting our management of essential supplies throughout the crisis (for example, PPE and cleaning materials).
We are accredited to the “Investor in People” standard, holding Silver status. The accreditation requires a rigorous internal and external assessment framework to ensure our policies, procedures, and the way we treat our staff sets a standard of a great employer, and an outstanding place to work. As part of this assessment we ask staff to complete a satisfaction survey.
During the year, we launched our “Your Voice” engagement survey which asks staff to anonymously comment on their experience in the workplace and beyond. This survey will be repeated annually. At the end of every section is a free text field allowing the opportunity to provide honest feedback or raise concerns. All staff are encouraged to complete the detailed questionnaire and are informed of the purpose. The data collected is used to identify areas of improvement and flag any issues. We are also in the process of launching targeted surveys for onboarding and exiting staff.
Our supply chain in relation to slavery and human trafficking
We have zero tolerance to slavery and human trafficking. We expect our suppliers to work to the same high standards that we impose on ourselves. We actively promote safe and fair working conditions, including the responsible management of environmental and social issues within our supply chain.
Through our procurement processes we monitor our supply chain to ensure only reputable suppliers and contractors who share those same high standards and comply with our values remain on our preferred supplier list.
As part of our supplier onboarding process, all suppliers are required to complete various due diligence checks and return a signed copy of our Supplier Code of Conduct. We assess our supply chain for potential areas of risk of non-compliance with the Act, considering a number of factors including:
- Suppliers operating outside of the UK / EU regulatory framework;
- Raw materials that are produced, or likely to be produced, outside of the UK / EU;
- Suppliers operating using temporary and/or low skilled labour; and
- Issues surrounding COVID-19.
Within our standard tender documents and commercial contracts, there is an obligation for suppliers to fully support and operate in accordance with the Act and take all reasonable steps to ensure that there is no modern slavery in its business or supply chain – Pinnacle reserve the right to terminate any supplier relationship where this obligation is not adhered to. We continue to identify suppliers that should have their own modern slavery policy – to date we have reviewed well over 100 such policies.
Our Supplier Code of Conduct (the “Code”) includes key modern slavery provisions (i.e. equal pay, working hours compliant with legislation etc.) The Code is integrated into our supplier on-boarding process, meaning all new suppliers are required to review and confirm they will adhere to anti-slavery principles. At the time of writing, approximately 1,000 suppliers have been on-boarded and signed up to our Code.
We have also continued to roll out quarterly audits with our strategic suppliers where the management of environmental and social issues is addressed as an agenda item for discussion. This now forms part of a more detailed annual audit of major suppliers.
We will be introducing a supply chain management CRM system where we will be able to flag suppliers that should have a modern slavery policy and/or publish an annual transparency statement and will be carrying out audits to check their policies are in place, robust, and fully implemented. We will also be exploring ways to boost awareness within our supply chain and monitor engagement.
Effectiveness in ensuring that slavery is not taking place
Pinnacle has a set of policies and procedures which in general cover human rights issues and are aimed at minimising the risk of slavery or human trafficking. Our policies are reviewed on an annual basis, or more regularly as required by any legislative change.
In addition to our Modern Slavery Policy, some of the policies and procedures of particular note are our Supplier’s Code of Conduct, Equal Opportunities, Equality, Diversity and Inclusion, Recruitment and Selection, Grievance, Harassment and Discrimination, and Whistleblowing. These are all easily available on our intranet and upon request.
Our staff, customers and suppliers are encouraged to report any concerns or suspicions they have that any unlawful conduct, including slavery or human trafficking, is taking place at work. For our staff, we have introduced a dedicated and confidential Report a Concern link on our intranet to facilitate this.
We also promote the Modern Slavery Helpline 0800 0121 700 (https://www.modernslaveryhelpline.org/), where individuals can report any suspicious activity or seek help and advice in confidence.
In an effort to combat the hidden nature of modern slavery and boost awareness of the signs, we now display posters and infographics created by the UK Home Office (part of the ‘Modern slavery is closer than you think’ briefing documents) in company offices, site depots and customer facing notice boards. Our regular internal communications provide links to a UK Home Office short film and other relevant information to further educate the business. Looking ahead to the next financial year, our aim will be to broaden the accessibility of our resources such as providing information in different languages.
Staff training about slavery and human trafficking
Our policies are communicated to staff from the point of induction and regular updates are provided as required either through training programmes or Corporate Communications as the group see fit. All staff are signposted to our Core HR policies and “The Pinnacle Way” handbook at induction.
Our policies and procedures are reviewed on an annual basis, or more frequently where legislation or regulation updates dictate, to ensure that they remain fit for purpose. Of particular relevance are our policies on safeguarding and vulnerability issues, mindful of our diverse customer base and workforce.
To boost awareness, we marked this year’s Anti-Slavery Day with a communications campaign addressing what is modern slavery and how to spot signs. The article also spotlighted our policies, procedures and provided contact details in the event of an employee wanting to raise a concern. Over the next twelve months, we will continue to roll out refresher training to our human resources, procurement, commercial and operational teams to increase their awareness of the Act and our associated due diligence processes. As part of induction training for new starters and refresher training for existing staff, staff are reminded of our core policies, including the Whistleblowing policy and who to contact with any concerns. The HR team conduct Right to Work checks in accordance with the applicable legislation.
We are developing an internal accessible training module open to all Pinnacle staff. Participation will be recorded so we can understand engagement per division and develop ways to reach a wider audience, including within our supply chain.
Modern Slavery Working Group
We launched the Modern Slavery Working Group (“MSWG”) in May 2021. The principal purpose of the MSWG is to support the ongoing development of responsible business practices in relation to modern slavery. The MSWG is tasked with developing guidance materials to improve key stakeholders’ awareness of modern slavery; monitor (and highlight any increased areas of) risk across Pinnacle; develop training and policy; and assist with supply chain audits.
The MSWG comprises representatives from across the business. This broad, non-exclusive membership is beneficial to promoting discussion at all levels and gaining different perspectives – vital to influencing real change.
In the year, various members of the MSWG and operational staff from our Homes division attended an external certified training webinar provided by a prominent anti-slavery charity. We will continue to support attendance at this type of event.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Pinnacle’s slavery and human trafficking statement for the financial year ending 31 March 2022 as approved by the Board of Directors.
Group Chief Executive