Introduction

This statement is made on behalf of Pocket Living Limited pursuant to section 54(1) of the Modern Slavery Action 2015 and comprises our slavery and human trafficking statement.

Who we are and our Vision and Values

We are a property developer that builds Affordable homes for the people that make London tick – the city makers.

We create cleverly designed homes for local people so that they can stay in their communities and continue to make London great.

In pursuit of that mission, we are committed to doing everything we can to prevent slavery and human trafficking. This statement sets out how we deliver that commitment and understand and mitigate the risk of slavery or human trafficking taking place within our business and supply chain. Modern slavery is the illegal exploitation of people for personal or commercial gain, often in horrendous conditions which the victim cannot escape. We believe that businesses have a key part to play in the effort to tackle this crime and protect vulnerable workers from exploitation.

The UK Modern Slavery Act (2015) requires commercial organisations that operate in the UK and have an annual turnover above £36m to produce a Slavery and Human Trafficking statement each year which sets out the steps the organisation has taken during the year – if any– to ensure that slavery or human trafficking is not taking place in its business and supply chain.

Our policies on slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business. We have several strategies, policies and procedures in place which help detect and prevent slavery and human trafficking. They include:

• Identifying inappropriate employment practices;
• A commitment to paying the London Living Wage as a minimum to all London employees;
• Requirements for all new employees to provide original documentation (such as a passport) before they start working with us to verify their legal right to work in the UK;
• A diversity and equal opportunities policy;
• A whistleblowing policy which protects staff should they raise concerns about issues such as modern slavery;
• Mitigating the risk of slavery and human trafficking occurring.

To ensure a high level of understanding of the risks posed by modern slavery and human trafficking in our business, in our supply chains and in our business partners we encourage open communication between our own employees and those who are working on our sites.

Our supply chains

Our procurement activities take place in England and our contractors and suppliers are predominantly UK and EU-based. We have zero tolerance to slavery and human trafficking. To ensure those in our supply chain and contractors comply with our values we will look to have in place a supply chain compliance programme as detailed below to ensure that our suppliers share our values on modern slavery and carry out their own due diligence on their own supply chains to limit the risk of modern slavery taking place.

As part of this due diligence process, we compiled a list of suppliers identifying and prioritising those entities which submit the highest value and most regular invoices. We selected 10 of our most regular contractors, for example construction and security companies, and contacted these providers to request information regarding each supplier’s approach to dealing with modern slavery within its organisation.

Although we consider the majority of our business operations and providers to be relatively ‘low risk’, we have identified that the greatest risk with respect to modern slavery is within our supply chain.

Accordingly, we will continue to focus our due diligence efforts in the coming years on ensuring that our suppliers remain complaint with the MSA legislation.

Over the course of the coming year, we will look to take the following steps to further prevent modern slavery in our supply chain:

• Seek to identify and enter into commercial relationships with companies who share our values and standards;
• Require any new building contractor or security services company to provide details of its policies on slavery and human trafficking and provide assurance that it does not (and nor does any entity within its own supply chain) engage in slavery of human trafficking or any associated activity;
• Refuse to enter into commercial relationships with entities knowingly involved with slavery or human trafficking; and
• Encourage a culture of whistleblowing within our supply chain by reporting any concerns to the relevant Director.

This statement was approved by Director Management Board on 8 June 2021.