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.
How this statement addresses each matter under Section 54
Section 54(5) of the Act lists the matters a slavery and human trafficking statement may cover, and Section 54(6) sets the approval and signature requirements. Every one is addressed in this statement, as set out below.
| What Section 54 requires | Where | How this statement addresses it |
|---|---|---|
| The organisation’s structure, its business and its supply chains | §2 | Three trading entities described; the supply chain mapped across three tiers, with ~1,060 Tier‑1 suppliers and ~235 on the critical path. |
| Its policies in relation to slavery and human trafficking | §3 | The Anti‑Slavery & Human Trafficking Policy, plus five connected policies covering procurement, competence, supervision, whistleblowing and equality. |
| Its due‑diligence processes in relation to slavery and human trafficking in its business and supply chains | §4 | Four due‑diligence channels — supplier pre‑qualification, Tier‑2+ cascade and audit, recruitment due diligence and site‑level vigilance — feeding a single response pathway with a 24‑hour triage service level. |
| The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk | §5 | A published risk register naming nine risk concentrations, each stating where in the business or supply chain it sits, why the risk is elevated, how we assess it and the controls and assurance applied to manage it. |
| Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate | §6 | Eleven performance indicators with reported outturn against target for the year, the basis on which each is measured, and a stated assessment of effectiveness — what is working, what is not yet proven, and what we are changing as a result. Two worked cases are given at §7. |
| The training about slavery and human trafficking available to its staff | §8 | Role‑calibrated training: an enforced pre‑entry induction gate for all workers, annual refresher for site managers, investigator‑grade training for designated investigators, and site toolbox talks. |
| Approved by the board of directors, and signed by a director — with the role of the approver specified (s.54(6)(a)) | §10 | Approved by the Board of Directors of Legacie Contracts Limited and signed by Gavin Currie in his role as a Director of that company (a registered directorship, appointed 10 December 2021), who is also its Chief Operating Officer. |
| The statement is signed and dated | §10 | Signed and dated 11 August 2026. The full approval and publication timetable — reporting period, approval date, and the date by which the next statement will be approved — is set out in §10. |
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 risk sits, and how we assess and manage it
Set out below is our published modern-slavery risk register. For each risk concentration it states where in our business or supply chain it sits, why the risk is elevated, how we assess it, and the controls and assurance we apply to manage it.
Agency & day-rate labour
High inherent risk- Where it sits
- Tier 1 and Tier 2 — labour providers engaged by us and by our subcontractors
- Why the risk is elevated
- Placement through intermediaries, high turnover and cash-in-hand pressure reduce visibility of who is actually on site and who controls their pay.
- How we assess it
- Modern-slavery pre-qualification set; GLAA licence and REC compliance check; confidential welfare interviews at 30, 90 and 180 days.
- How we manage it
- Quarterly pre-qualification refresh; Employer Pays Principle attestation; wages paid only to a verified account in the worker’s own name.
Recruitment fraud & debt bondage
High inherent risk- Where it sits
- Tier 2 — recruitment agencies engaged by our Tier-1 subcontractors
- Why the risk is elevated
- Worker-paid recruitment fees and withheld “deposits” create debt that ties a worker to an employer. This is the risk that materialised in Case A at §7.
- How we assess it
- Welfare interviews conducted away from the engaging supplier; payroll pattern analysis for shared accounts, shared addresses and third-party wage control.
- How we manage it
- Employer Pays Principle enforced by contract; full restitution to affected workers; corrective action plan with 12 months of quarterly reporting.
Demolition & asbestos abatement
High inherent risk- Where it sits
- Tier 1 — enabling-works packages
- Why the risk is elevated
- Short-duration, physically demanding, lower-skilled work with a transient workforce and strong price pressure.
- How we assess it
- Enhanced pre-qualification at onboarding; unannounced site labour-standards checks during the package.
- How we manage it
- Classified high-risk: quarterly refresh and inclusion in the annual Tier-2 spot-audit programme.
Façade & cladding trades
High inherent risk- Where it sits
- Tier 1 installation and Tier 3+ imported components
- Why the risk is elevated
- Combines a high-turnover installation workforce with manufactured components whose sub-tier labour conditions are hardest for us to see.
- How we assess it
- Enhanced pre-qualification; targeted origin enquiry for imported component lines.
- How we manage it
- Cascade clause with right of audit; a named focus of the FY2026 Tier-2 spot-audit programme.
Finishing trades
High inherent risk- Where it sits
- Tier 1 and Tier 2 — painting, drylining, tiling, second fix
- Why the risk is elevated
- Deep multi-layer subcontracting and a high proportion of migrant labour, so the engaging entity can sit two or three steps from us.
- How we assess it
- Welfare interviews; site-supervisor indicator list; anonymous tip-line.
- How we manage it
- Enhanced pre-qualification; corrective action plans where practice falls short, with re-audit at 60 days.
Site cleaning
High inherent risk- Where it sits
- Tier 1 and Tier 2 — site and post-construction cleaning
- Why the risk is elevated
- Low-margin, low-visibility work, frequently performed outside main working hours and outside routine supervision.
- How we assess it
- Anonymous tip-line; out-of-hours spot checks; Tier-2 spot audit.
- How we manage it
- Classified high-risk with quarterly refresh; included in the annual spot-audit programme.
Site-adjacent services
Medium inherent risk- Where it sits
- Tier 2 — canteens, transport, security and waste
- Why the risk is elevated
- Engaged outside the main works packages, so they can fall outside standard construction supervision and induction routines.
- How we assess it
- Onboarding modern-slavery check; inclusion in the site-poster and induction audit.
- How we manage it
- Contractual flow-down of equivalent expectations; annual pre-qualification refresh.
Imported & off-site fabrication
Medium inherent risk- Where it sits
- Tier 3+ — manufactured components and modular elements
- Why the risk is elevated
- Our visibility falls away beyond Tier 2, and imported manufacturing carries the sector’s highest documented forced-labour risk.
- How we assess it
- Targeted origin enquiry where risk warrants; requirement for in-scope suppliers to provide their own Section 54 statement.
- How we manage it
- Cascade clause; a specific focus of the expanded Tier-2 spot-audit programme committed at §9.
Managed-housing maintenance
Medium inherent risk- Where it sits
- Own operations and Tier 1 — contractors working in occupied homes
- Why the risk is elevated
- Small contractors and sole traders working alone in occupied properties, where per-contractor visibility is lower than on a managed site.
- How we assess it
- Anti-slavery check embedded directly in contractor onboarding; resident-reported concerns routed to the same triage pathway.
- How we manage it
- Onboarding gate; biennial refresh for lower-risk trades, annual for the remainder.
Inherent risk is the risk before our controls are applied; the assessment and management columns describe the controls that reduce it. The register is reviewed annually and on any material change to the supply chain.
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.
Basis of measurement
So that these indicators can be relied on rather than simply read, each is measured from a defined system of record: supplier pre-qualification and cascade indicators from our ProcurePro procurement platform; induction, refresher and toolbox-talk completion from the digital induction and training records; reports, triage timing and case outcomes from the HSQE incident and investigation log; and welfare-interview completion from HR records. Figures are compiled at year-end and reported to the Chief Operating Officer monthly and to the quarterly management review.
Our assessment of effectiveness for the year
Overall: the arrangements operated effectively, with one area not yet independently proven
Measured against the indicators above, we assess our arrangements as having operated effectively during the year ended 30 September 2025. Every report raised through any channel was triaged within the 24-hour service level and resolved; the two matters that warranted full investigation were remediated with the workers made whole; no worker was found to be in a situation of slavery or trafficking within our business or supply chains; and no referral to the National Referral Mechanism was required. Detection worked where it matters most — the withheld-wages issue in Case A reached us through a welfare interview, which is precisely the control designed to surface it.
The controls that produced results are the ones closest to the worker: confidential welfare interviews (which surfaced Case A), the anonymous tip-line (Case B), and the enforced pre-entry induction gate, which held at 100% because site entry is technically impossible without it. Engaged remediation also worked — both corrective action plans were verified complete and closed within 60 days.
Two limitations are stated openly. First, our assurance beyond Tier 2 remains largely documentary rather than audited, so our confidence in Tier 3+ is lower than in Tier 1. Second, our arrangements have not yet been tested by an independent third party. Both are addressed by the commitments at §9 — independent third-party assurance, an expanded Tier-2 spot-audit programme focused on imported and off-site fabrication, and an independent interpreter framework so welfare interviews no longer depend on the engaging supplier for translation.
We do not treat “no confirmed cases” as evidence of effectiveness on its own. A zero result is only meaningful alongside evidence that the detection controls are live, used and producing reports — which is why the indicators above measure detection activity and response, not merely outcomes.
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 on 11 August 2026, and was signed on that date by Gavin Currie, who holds the role of Director of Legacie Contracts Limited — a registered directorship held since 10 December 2021 — and who is also the group’s Chief Operating Officer.
He signs in his capacity as a Director, which is the capacity required by Section 54(6)(a) of the Modern Slavery Act 2015 for a statement made by a body corporate. The statement is made on behalf of the Legacie group and covers the entities named in Section 1, and it is reviewed and re-published annually.
Signed on behalf of the Board of Legacie Contracts Limited
Approval and publication timetable
Publication & raising a concern
This statement is published on the Legacie website at legacie.co.uk/modern-slavery/, linked from the footer of every page, included in the pack issued to every new supplier, and made available to any worker on a Legacie site on request. It is also being submitted to the UK Government Modern Slavery Statement Registry, the government’s central register of statements, and each annual statement will be submitted there from this year onward. 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.