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Slavery & Human Trafficking Statement 2026

Introduction

Poplar HARCA is committed to delivering high standards of corporate governance and to complying with its legal and regulatory responsibilities, including section 54 of the Modern Slavery Act 2015. We review our approach annually so that our business practices, recruitment processes and procurement methods remain ethical, proportionate and aligned with current statutory guidance.

We are an exempt charity committed to wider social responsibility. We take steps to understand the risks of modern slavery in our organisation and supply chains, including risks relating to labour exploitation, forced or compulsory labour, domestic servitude and human trafficking, and to prevent, mitigate and respond to those risks.

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.

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 prevent modern slavery and human trafficking in its operations and supply chains. This statement summarises measures taken during the reporting period and is published within six months of the end of the financial year, approved by the Board, signed by a Director and made available in a prominent place 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.

Where a supplier, contractor or partner identifies a potential modern slavery concern, we expect prompt escalation, cooperation with any investigation and appropriate remedial action. Poplar HARCA will consider proportionate contractual, safeguarding and procurement responses, prioritising the protection and support of affected individuals.

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 are 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. This enables us to build close relationships with suppliers and promote our commitments to social value and responsibility, the London Living Wage, sustainable procurement and support for the local economy. We work with supply chain providers to identify, reduce and, where possible, eliminate the risk of slavery and human trafficking. A clause requiring compliance with our Slavery and Human Trafficking Statement is inserted in all new contracts and contractors are required to confirm compliance annually.

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

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.

Risk assessment and due diligence

Our highest potential exposure to modern slavery risk is considered to be in areas involving labour-intensive services, construction, repairs and maintenance, cleaning, agency labour, facilities management and extended supply chains where there may be less visibility beyond first-tier suppliers.

Our due diligence includes proportionate supplier checks, contractual requirements, procurement controls, annual contractor health checks, review of sub-contractor compliance where relevant, and escalation of concerns through contract management, safeguarding and governance routes. We recognise that not identifying any incidents does not remove the need for active risk assessment, monitoring and continuous improvement.

Effectiveness and continuous improvement

We assess the effectiveness of our approach through procurement compliance checks, contractor health checks, supplier engagement, contract management reviews, audit and risk oversight, and review of any concerns raised through safeguarding, whistleblowing or complaints channels. We will continue to strengthen our reporting by improving the quality of information collected on supplier risk, training completion and actions taken in response to identified concerns.

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.

Relevant staff involved in procurement, contract management, recruitment, safeguarding and frontline service delivery are expected to understand the indicators of modern slavery and the appropriate routes for raising concerns. We will continue to promote awareness of modern slavery risks through policy communication, procurement guidance, contract management processes and relevant training or briefing activity.

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 September 2022 so will be reviewed September 2027 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.

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 2026.

This statement will be reviewed and updated on an annual basis and is approved by our Board. It applies to call companies within the Group other than those that are exempt.

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

JON LORD
Chair of the Poplar HARCA Board of Directors
15th September 2026