Modern Slavery Statement

L&Q is one of the UK’s leading housing associations and one of London’s largest residential developers, owning or managing over 105,000 homes primarily across London, the South East and North West.

As an exempt charity with a strong commitment to social responsibility, we rigorously comply with our legal and regulatory responsibilities under the Modern Slavery Act 2015. We proactively work to ensure that slavery, human trafficking, and exploitation do not exist within any part of our business or supply chains.

Governance and accountability 

Our Board has oversight of our anti-slavery and human trafficking strategy, with clear accountability through our Executive Group. We have established internal oversight through regular reporting, including quarterly safeguarding reports reviewed at senior management levels and annually by our Group Board.

Safeguarding our residents 

As a landlord, we remain vigilant against all forms of modern slavery affecting our residents, particularly exploitation linked to vulnerability. We proactively identify residents with vulnerabilities through comprehensive assessments at allocation, regular tenancy verification audits, and vulnerability flags. Our “Supporting Residents with Additional Needs” policy outlines how reasonable adjustments are implemented to safeguard individuals at heightened risk.

We maintain robust training programs to empower our staff in recognising and responding to safeguarding concerns. All staff complete annual mandatory safeguarding e-learning modules covering adults and children at risk, alongside specialised modern slavery and human trafficking training. Front-line colleagues, including housing officers and care workers, receive additional classroom training. 

Our network of safeguarding champions meets monthly to provide continuous guidance, promoting a proactive safeguarding culture. We closely monitor safeguarding referrals, specifically tracking modern slavery indicators such as cuckooing, forced labour, and exploitation through anti-social behaviour. In 2023/24, we recorded 369 safeguarding cases, including specific instances of cuckooing and county lines exploitation, and continue targeted awareness campaigns in these areas.

Resident and community engagement 

We are committed to increasing resident and community awareness of modern slavery through targeted campaigns in areas identified as higher risk, encouraging residents to report concerns promptly.

Employment practices

L&Q has achieved full accreditation from the Living Wage Foundation, guaranteeing that all directly employed staff (excluding apprentices who receive at least the National Living Wage) are paid at or above the real Living Wage rate.

We have an Employee Assistance Programme (Health Assured) and a comprehensive Whistleblowing policy, providing robust support mechanisms for staff to confidentially raise concerns relating to labour conditions, exploitation, or coercion. No concerns regarding labour exploitation or coercion were raised in the past year through whistleblowing or HR channels.

We are exploring opportunities to introduce spot-check audits of recruitment agencies’ pre-employment and right-to-work processes to enhance oversight of temporary staff.

Procurement and supply chain management

Recognising our supply chain as an area of heightened risk, particularly within construction, we maintain stringent supplier compliance measures. All works Contractors above procurement threshold must hold Constructionline Gold membership, adhering to the Common Assessment Standard (CAS), which requires demonstration of ethical employment practices, anti-slavery policies, and annual reassessments to ensure ongoing compliance. This includes verifying subcontractors’ practices to prevent forced labour, deception, or exploitation.

Our updated procurement contract templates incorporate comprehensive anti-slavery clauses and Living Wage commitments, mandating that all future suppliers and subcontractors uphold these standards. We actively require suppliers to declare their compliance with anti-slavery legislation, maintaining transparent and auditable records of their supply chains.

We are implementing an advanced Source-to-Pay (S2P) system in line with the Procurement Act 2023, significantly enhancing transparency, supplier performance visibility, and contract management efficiency. This will include real-time data monitoring, facilitating proactive identification and management of modern slavery risks.

Policy framework and compliance

Our approach to modern slavery is supported by internal policies, accessible via our intranet, including our Whistleblowing Policy, Safeguarding Policy, Anti-Bribery Policy, Equality, Diversity & Inclusion Policy, Recruitment Policy, and Procurement Policy.

Performance indicators and effectiveness

We monitor the effectiveness of our anti-slavery practices through defined KPIs, including training completion rates, safeguarding referrals categorised by type, and supplier compliance audits. The effectiveness of these practices is assessed through regular audits and internal reviews.

No confirmed instances of modern slavery were identified within our operations or supply chains during 2023/24. Should any incidents be identified, we are committed to immediate investigation, reporting to appropriate authorities, and supporting victims appropriately.

We actively collaborate with local authorities, law enforcement, and other housing associations to share best practices and strengthen collective efforts against modern slavery.

Future Initiatives

Our future actions include:

• Accelerating category management and increasing site visits to key tier 1 suppliers for enhanced assurance of labour practices
• Implementing systematic spot checks on recruitment agencies supplying temporary staff
• Expanding supply chain risk assessments beyond tier 1 suppliers to include second- and third-tier providers
• Continuing targeted training and awareness campaigns, focusing on high-risk issues such as county lines, cuckooing, and forced labour within our properties and supply chains
• Hosting annual awareness activities aligned with key dates such as Anti-Slavery Day (18 October)

This statement is made under section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2025. It will be reviewed annually and approved by L&Q’s Group Board, applying to all entities within the Group. This statement is also published on the Government Modern Slavery Statement Registry.

Fiona Fletcher Smith
Group Chief Executive

London & Quadrant Housing Trust and its subsidiaries are listed below: