Slavery and human trafficking statement 2019

Introduction

Poplar HARCA is committed to delivering high standards of corporate governance and a key element of this is ensuring that we comply with our legal and regulatory responsibilities, including the Modern Slavery Act (2015). We ensure that our practice in this area is reviewed and continually improved every year, to ensure our business practices and procurement methods remain ethical.  

We are an exempt charity committed to a wider social responsibility. We have taken steps to understand the risks of modern slavery in our supply chains and organisation, and to ensure that     these risks are mitigated.

We support international efforts to eradicate modern slavery and human trafficking. We expect the same commitment from all organisations we do business with and will not knowingly support any business involved in slavery or human trafficking.

Requirements under the Act

Poplar HARCA must:

  1. Ensure that its supply chains are free from domestic servitude, forced or compulsory labour and human trafficking
  2. Demonstrate a proactive approach to assessing, mitigating and managing the risk of slavery in supply chains
  3. Publish an annual statement setting out the steps taken to ensure that slavery and human trafficking is not taking place within its supply chains. This statement summarises measurements taken during the previous reporting period and is published within six months of the end of the financial year. It is approved by the Board, signed by a Director and must be prominently displayed on the website.

All Poplar HARCA suppliers must ensure that their own employees and those of their suppliers:

  1. Are legally able to work
  2. Have freely chosen employment (no forced or bonded labour)
  3. Have a written contract
  4. Have not had to pay fees or lodge documents to obtain work
  5. Understand their statutory rights (i.e. sick pay and holiday pay)
  6. Are paid in accordance with national law
  7. Are working in a safe and hygienic environment
  8. Are not expected to work excessively long hours and that working hours comply with national laws and guidelines

All Poplar HARCA suppliers should assess quotations and fees from any agency or supplier providing unusually low rates when compared with industry standards.

Our supply chain 

Procurement is mostly undertaken by the Technical Resources and Development Directorates who are responsible for all construction related works and services, along with buying items such as stationery, coffee and mobile phones for the company as a whole. 

Purchasing decisions must comply with the Modern Slavery Act (2015) and, under the Transparency in the Supply Chain Provision, Poplar HARCA must monitor and report compliance with the Act.

•    Repairs and maintenance is delivered through a series of trade specific Measured Term Contracts. Due to the place-based nature of our business, many of our contractors are small, local firms, which allows us to build close relationships with suppliers allowing us to promote our commitment with regards to social value and responsibility, living wage, sustainable procurement, a focus on supporting the local economy when possible and to work with our supply chain providers to zone out and, when possible, fully eliminate slavery and human trafficking. A clause requiring compliance with our Slavery and Human Trafficking Statement is now inserted in all new contracts which contractors sign annually.

•    A clause requiring compliance with our Slavery and Human Trafficking Statement is now inserted in all Service Level Agreements with groups and organisations to whom we award grants including those funded through our partner, East End Community Foundation.

•    Constructionline - the UK’s register of pre-qualified local and national construction and construction-related contractors and consultants - is used as Poplar HARCA’s Approved List for all small non-measured term contract building related works and services. This gives us access to suppliers who have been checked for their compliance with ethical procurement standards.

•    We are also members of purchasing clubs – notably Procurement for Housing – and use them to service many of our centralised contracts including the buying of cleaning products and paper. 

We audit our supply chains on an ongoing basis and work with our suppliers to identify areas where slavery or human trafficking is a risk. We perform an annual contractor health check and part of this process is to verify sub-contractors compliance.

Our staff

•    Recruiting permanent staff – Poplar HARCA operates comprehensive and transparent recruitment processes which are subject to the oversight of the People and Development department and periodic external auditing.  Our processes include Right to Work checks for all permanent and interim staff, and we pay at least the London Living Wage.

•    Temporary workers are recruited via reputable agencies under the supervision of our People and Development department. Where possible, we ensure that any agencies we use for temporary staff pay London Living Wage. We also ensure that these partners apply good HR practices and processes including Right to Work checks and Poplar HARCA has access to these records and carries out regular audits to ensure they are up-to-date and accurate.

Policies and procedures  

The Poplar HARCA Modern Slavery Policy mirrors this statement but includes an ‘Impact Assessment’ for internal purposes. The statement is reviewed annually by the Director of Technical Resources and presented to the Audit & Risk Committee and then to the Poplar HARCA Board for approval. Contract managers/procuring officers and their line managers are responsible for ensuring that new contracts are compliant with this policy, and that suppliers under existing contracts (those awarded before introduction of the policy) and suppliers who are not under contract comply with this policy.

Policies are reviewed every five years or sooner if they no longer reflect best practice. The current Policy was presented to the Audit & Risk Committee in March 2017 so will be reviewed March 2022 at the latest.

Our Procurement Policy and Procedure is designed to ensure that buying decisions demonstrate proper consideration of quality, cost and purpose; and that value for money, added value and social value have been maximized. 

Future Steps

Following a review of the steps we have taken in 2018-19 we intend to take the following further steps to combat slavery and human trafficking:

  • We will share this statement with our staff, volunteers and clients and raise awareness of the Modern Slavery Act and what action to take if staff have concerns
  • We will continue to raise awareness of the Act with our suppliers by requesting evidence, where they reach the turnover threshold, such as their Modern Slavery statement, Corporate Social Responsibility Policy, commitment to paying a living wage, social value policies, modern slavery preventative practices and recruitment procedures as part of the procurement process. Our standard terms and conditions of contract for goods and services refer to the Act.

Commitment from our Board of Directors 

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Poplar HARCA’s slavery and human trafficking statement for the financial year ended 31 March 2019.

Our Board of Directors is committed to preventing slavery from occurring in any part of our supply chains and, accordingly, have approved this statement.  

 

PAUL BRICKELL

Chair of the Poplar HARCA Board of Directors  

17 September 2019

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