Introduction & statutory basis
This statement is made by Legacie Contracts Limited (company number 09494137) and the Legacie group of companies (together, “Legacie”) pursuant to Section 54(1) of the Modern Slavery Act 2015 (the “Act”).
It sets out the steps Legacie took during the financial year ended 30 September 2025 — and the steps we are committed to taking during the current year — to ensure that slavery and human trafficking are not taking place in any part of our own business or in our supply chains. Legacie has a zero-tolerance approach to slavery, servitude, forced or compulsory labour and human trafficking in any form.
Legacie’s turnover is well above the £36 million threshold at which the Section 54 disclosure duty applies: audited turnover for the year ended 30 September 2024 was approximately £117 million (2023: approximately £96 million), and turnover for the year covered by this statement again exceeded that threshold. Legacie would continue to publish an annual statement as best practice even if turnover fell below it.
This statement is the company’s statutory public disclosure. It is read alongside our Anti-Slavery & Human Trafficking Policy — the binding internal control document that describes the arrangements this statement reports on. The two are reviewed together, at least annually.
Organisation, business & supply chains
Legacie is a North-West-England-headquartered construction and property group, operating through three principal entities:
- Legacie Contracts Limited — the principal-contractor entity that delivers our construction projects, headquartered in Liverpool.
- Legacie Developments — the developer that commissions many of the projects delivered by Legacie Contracts Limited.
- Legacie Management & Lettings — the agency that manages the occupied residential portfolio after handover.
Our work spans new-build residential and build-to-rent construction, mixed-use and hotel schemes, student and social housing, Higher-Risk Building work under the Building Safety Act 2022, façade and cladding remediation, and the management and maintenance of occupied homes. The direct workforce is supplemented by a fluctuating on-site subcontractor workforce that typically numbers several hundred to over a thousand individuals across our active projects at any one time.
How our supply chain is structured
Because we operate a full principal-contractor model, our largest exposure sits in our subcontractor and labour supply chain. We map it in tiers:
Materials are predominantly UK-sourced; imported components originate primarily from the EU, with a smaller share from elsewhere. For in-scope imported supply we also have regard to comparable overseas transparency laws.
Our policies
Our principal instrument is the Anti-Slavery & Human Trafficking Policy, approved at senior-leadership level and issued to every supplier at onboarding. It is supported by a connected framework of policies:
- Subcontract Procurement Procedure — carries the supply-chain cascade clause and the pre-award modern-slavery gate.
- Competence Policy — the worker-side due-diligence framework, including the Employer Pays Principle for direct hires.
- Supervision, Instruction & Information Policy — places responsibility for noticing and reporting indicators with site supervisors.
- Whistleblowing Policy — a confidential channel protected under the Public Interest Disclosure Act 1998, with modern slavery an explicitly listed category.
- Equality, Diversity & Inclusion Policy — protecting the vulnerable workers most exposed to modern-slavery risk.
Every policy is reviewed at least annually, and immediately on any material change in law or guidance.
Due diligence
Our due-diligence framework operates across four channels, calibrated to risk:
Supplier pre-qualification
Every Tier-1 supplier completes a Modern Slavery pre-qualification set on ProcurePro at onboarding — covering their own statement, GLAA licence status, right-to-work protocol, worker complaint mechanism, Employer Pays Principle attestation, accommodation declaration and any enforcement history. It is refreshed on a cadence set by trade risk (quarterly for high risk).
Tier-2+ cascade & audit
Every Tier-1 subcontract carries a Modern Slavery Cascade Clause requiring the supplier to impose equivalent expectations down its own chain, and granting Legacie a right of audit. We run targeted Tier-2 spot audits across the highest-risk trades each year.
Recruitment due diligence
Every direct hire passes a statutory right-to-work check, an identity-document review for trafficking indicators and an Employer Pays Principle attestation, followed by confidential welfare interviews at 30, 90 and 180 days. Recruitment agencies are screened on GLAA licence and REC compliance.
Site-level vigilance
Site managers and supervisors work to a trained-eye indicator list and can log observations for immediate review. The Modern Slavery & Exploitation Helpline number is displayed at every site entrance in eight languages plus a pictogram-only format.
Reports from any channel feed a single response pathway with a 24-hour triage service level:
Risk assessment & management
Modern slavery is a recognised, high-inherent-risk feature of the UK construction sector. Our risk assessment — refreshed annually — identifies where that risk concentrates, both across the sector and specifically within Legacie’s portfolio.
Where the highest risk sits
Legacie’s specific exposures
- Subcontractor dependency — with a large Tier-1 vendor base, our supply-chain cascade is our primary exposure surface, so cascade discipline and audit are where we concentrate effort.
- Geographic concentration — a portfolio anchored in the North-West, an area of higher-intensity labour-market enforcement.
- Higher-Risk Building work — HRB sites carry the highest density of subcontractors and worker throughput, and so attract the most demanding indicator-detection discipline.
- Managed-housing maintenance — a pool of maintenance contractors operating in occupied homes, where per-contractor visibility is lower, so the anti-slavery check is embedded directly in contractor onboarding.
This risk picture is not left on paper. It drives the operational response directly: high-risk trades attract enhanced pre-qualification, quarterly refresh and on-site spot audits; medium-risk trades an annual refresh; lower-risk a biennial refresh.
Effectiveness — our key performance indicators
We measure the effectiveness of our anti-slavery arrangements against a defined set of key performance indicators, reported to the Chief Operating Officer monthly and to the quarterly management review. The outturn for the year ended 30 September 2025 was as follows:
| Indicator | Outturn | Target | Status |
|---|---|---|---|
| Tier-1 supplier modern-slavery pre-qualification completion | 98.2% of active suppliers; onboarding-grace exceptions cleared by year-end | 100% (30-day grace) | On track |
| In-scope suppliers (≥£36m turnover) with a statement on file | 100% — all in-scope suppliers | 100% | Met |
| Indicators reported and reviewed | 9 (site observations, welfare-interview disclosures and one anonymous tip-line report) | Rising count = better detection | Monitored |
| Triage completed within 24-hour service level | 100% (9 of 9) | 100% | Met |
| National Referral Mechanism referrals required | 0 required — 7 closed at triage as not credible; 2 remediated supplier-side | Any required referral made promptly | Met |
| Induction module completed before site entry | 100% — enforced gate prevents entry without completion | 100% | Met |
| Site-manager refresher within past 12 months | 96.4% | ≥ 95% | Met |
| Multi-language site poster displayed at active sites | 100% — verified at the annual site-poster audit | 100% | Met |
| Welfare-interview completion (30 / 90 / 180-day) | 100% for direct hires and for agency placements over 30 days | 100% | Met |
| High-risk Tier-2 spot audits | 4 — demolition, finishing, façade-cladding and site cleaning | ≥ 4 | Met |
| Supplier consequence actions | 2 corrective action plans issued and closed within 60 days; no suspensions, de-listings or terminations | Engaged remediation preferred | Monitored |
A rising number of reported indicators is treated as a positive signal of a maturing detection culture, not of deterioration — provided every report is triaged and resolved. During the year, it was.
Cases & remediation during the year
Two matters progressed beyond triage to full investigation during the year. Both illustrate how our arrangements work in practice, and our preference — in line with the UN Guiding Principles on Business and Human Rights — for engaged remediation that supports the worker over disengagement that can harm them.
A withheld “deposit” disclosed at a welfare interview
Two operatives disclosed that a “deposit” had been withheld from first-month wages by a Tier-2 recruitment agency. Investigation established a non-compliant Tier-2 practice — not the Tier-1 contractor’s own arrangement. Remediation: the Tier-1 supplier was issued a corrective action plan requiring replacement of the offending agency, full restitution of the withheld monies to the affected workers (settled within 14 days), refresher training and 12 months of quarterly reporting. The plan was verified complete and closed at the 60-day review.
An anonymous report of shared bank accounts
An anonymous tip-line report indicated shared bank accounts among three workers. Investigation established a voluntary family arrangement between siblings, with right-to-work, payroll and welfare all in order. The matter was closed as not modern slavery, and the reporter received written confirmation that the report had been taken seriously and acted upon.
No Legacie supplier was suspended, de-listed or had a contract terminated for a modern-slavery cause during the year, and no referral to the National Referral Mechanism, or notification to a regulator, was required.
Training & awareness
Training is calibrated to role:
- All workers completed a modern-slavery awareness module — available in eight languages plus a pictogram-only format — before first site entry, through an enforced digital induction gate.
- Site managers and supervisors completed an annual modern-slavery-in-construction refresher (96.4% within the 12-month window; the balance newly appointed and scheduled).
- Procurement, HSQE and compliance leads attended external continuing-professional-development events during the year, including industry anti-slavery briefings.
- Designated investigators maintain investigator-grade training on a rolling refresh cycle.
- Toolbox talks on modern slavery were delivered at every active site during the year.
Looking ahead
For the current financial year we are committed to the following measurable improvements:
- Engage independent third-party assurance of our anti-slavery arrangements, separate from our ISO management-system audits.
- Extend the supplier pre-qualification set to capture each supplier’s own training-completion rate, not merely that training exists.
- Increase the Tier-2 spot-audit programme, with a specific focus on imported and off-site-fabricated components.
- Introduce an independent interpreter framework so welfare interviews can be held in a worker’s first language without reliance on the engaging supplier.
- Maintain a live internal KPI dashboard to keep anti-slavery vigilance visible to all staff.
- Continue our engaged-remediation approach, and submit each annual statement to the UK Government Modern Slavery Statement Registry.
- Approve and publish the next statement — for the year ending 30 September 2026 — within six months of year-end (by 31 March 2027).
Board approval & signature
This statement was approved by the Board of Directors of Legacie Contracts Limited and is signed by Gavin Currie, a Director of Legacie Contracts Limited, for the purposes of Section 54(6)(a) of the Modern Slavery Act 2015. It is made on behalf of the Legacie group and covers the entities named in Section 1, and it will be reviewed and re-published annually. This statement relates to the financial year ended 30 September 2025 and was approved on 12 May 2026; Legacie is committed to approving each future statement within six months of the relevant financial year-end.
Signed on behalf of the Board of Legacie Contracts Limited
Publication & raising a concern
This statement is published on the Legacie website, included in the pack issued to every new supplier, made available to any worker on a Legacie site on request, and submitted to the UK Government Modern Slavery Statement Registry. Previous statements remain available as a historical record.
Anyone can raise a concern — confidentially
If you have any concern about modern slavery on a Legacie site or in our supply chain, you can contact us in confidence, raise it through any site supervisor, or report it directly to the UK Modern Slavery & Exploitation Helpline, free and confidential, 24 hours a day:
Reporters are protected under the Public Interest Disclosure Act 1998 and our Whistleblowing Policy. Retaliation against anyone who raises a concern is treated as a disciplinary or contract-termination matter.