Appendix 6.5B
Slavery and human trafficking statement 2017
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 take steps to understand the risks of modern slavery in our supply chains and to ensuring that these risks are mitigated.
We support international efforts to promote practices aimed at the prevention of 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.
Our supply chains
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.
•Repairs and maintenance is delivered through a series of trade specific Measured Term Contracts. Many of our contractors are small, local firms. A clause requiring compliance with our Slavery and human trafficking statement is now inserted in all new contracts.
•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.
•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.
•Recruiting substantive staff – Poplar HARCA operates comprehensive and transparent recruitment processes which are subject to the oversight of the Human Resources department and periodic external auditing.
•Temporary workers are recruited via reputable agencies under the supervision of our Human Resources department.
We are currently auditing our supply chains, and working with our suppliers, to identify areas where slavery or human trafficking is a risk.
Policies and procedures
We have a Modern Slavery Policy to ensure our business practices and procurement methods are ethical. This is achieved through our Procurement Policy and Procedure to make sure that buying decisions demonstrate that quality, cost and purpose have been properly considered; and that value for money, added value and social value have been maximized.
Steps taken in 2016-17
- Created a Modern Slavery Policy approved by our Audit & Risk Committee.
- Added a clause about slavery and trafficking to all new Technical and Development contracts
- Raised contractor awareness of the Modern Slavery Act by circulating a fact sheet and our policy
- Created a Modern Slavery Charter signed by all of our principal repairs and maintenance contractors.
- Developed an action plan which sets out the steps we will take over the coming financial year including increasing staff awareness of the legislation.
Commitment from our Board of Directors
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our Group’s slavery and human trafficking statement for the financial year ended 31 March 2017.
Our Board of Directors are committed to preventing slavery from occurring in any part of our supply chains and, accordingly, have approved this statement.