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Anti-Slavery and Human Trafficking Statement Annual Update 1st April 2025- 31st March 2026
Introduction from Kevin Rodgers, Chief Executive
This is the tenth annual Anti-Slavery and Human Trafficking Statement1 and Citizen remains proud of the steps we have taken to combat slavery and human trafficking and remain committed to improving our practices in this area. I can confirm that we have received no reports of slavery or human trafficking in our business or with any of our wider supply chain partners.
Citizen and its partners remain committed to a zero-tolerance approach to modern slavery and human trafficking in its supply chains. We recognise our obligations in identifying, targeting and preventing slavery and human trafficking and we understand that everyone has a role to play to eliminate this.
Our approach to tackling slavery and human trafficking involves -
• Ensuring we have an up-to-date Anti-Slavery and Human Trafficking Policy.
Training our staff to understand our policy and procedures for identifying and reporting modern slavery.
We undertake due diligence in appointing contractors and suppliers.
It is for these reasons that we believe our working practices to be adequate and as such our statement remains similar to those issued in previous years.
Our previous statements will be available on request.
1. Organisation's structure
Citizen undertakes a range of community and social based activities, including housing, regeneration, community development and care. We employ over 1,000 members of staff and manage more than 30,000 homes across Birmingham, Coventry, Herefordshire, Worcestershire and the wider West Midlands.
1 previous statements published as WM Housing Group Limited
POLICY STATEMENT Anti-Slavery and Human Trafficking Statement
Version : 10 Author(s) : Kevin Rodgers Approved at/by: Citizen Board
Date: March 2025 Page 1 of 5 Date of review: March 2026
UNCONTROLLED WHEN PRINTED
We are a not-for-profit social housing business creating homes that are a foundation for life. We do however have Signature New Homes, who develop open market housing to subsidise the development of more affordable homes.
2. Our supply chains
As a registered provider we do not operate extensive, worldwide supply chains. Due to this, we can build close relationships with suppliers which enable us to promote our commitment with regards to slavery and human trafficking.
3. Our policies on slavery and human trafficking
We are committed to ensuring that there is no modern slavery in our supply chains or in any part of our organisation. As part of this, we have an Anti Slavery and Human Trafficking Policy which reflects our commitment to acting ethically and with integrity in all our business relationships, as well as implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. This policy was reviewed in May 2022, underwent an interim review in December 2023 and is due for a full review in July 2025. A copy of the policy can be found on our website.
Citizen’s Procurement Policy underwent a full review in 2024/25 to ensure it’s compliance with the new procurement act. The Procurement Team have undertaken work to prepare colleagues for the requirements of the Act including enhanced duties around reporting instances of modern slavery should a breach be identified.
Citizen recognises that modern slavery is not confined to supply chains and we see identifying modern slavery or human trafficking as part of our duty as a landlord and as an employer.
In 2024 it was reported that some major employers in the U.K. had been employing victims of modern slavery, failing to identify the same key risk indicators such as the same bank accounts or addresses used for several employees. Following these reports, we checked our policies and processes, and we are confident in our payroll processes and reporting would identify such risks. Similar checks are also made for customers' account when issuing credit recharges.
We are an organisation that plays an active role in our communities and are often in a unique position to spot signs that may indicate a concern. We have policies and procedures in place to ensure that safeguarding concerns can be reported easily including
POLICY STATEMENT Anti-Slavery and Human Trafficking Statement
Version : 10 Author(s) : Kevin Rodgers Approved at/by: Citizen Board
Date: March 2025 Page 2 of 5 Date of review: March 2026
UNCONTROLLED WHEN PRINTED
CITIZEN
a specific process for concerns relating to modern slavery. Colleagues who are based predominantly in our communities including engineers, estates services and grounds maintenance colleagues can now rapidly report concerns via their hand-held devices using a simple app. We have trained these colleagues to use our processes, and our Safeguarding Committee keeps the effectiveness of these process under review. A new suite of performance indicators has been developed and allow the Safeguarding Committee to have greater insight into modern slavery and other safeguarding issues.
All colleagues, regardless of role, must undertake some level of safeguarding training, this helps all staff to identify any safeguarding issues within our supply chains or in our homes and ensures they follow the correct referral procedures. We have Safeguarding Leads in all areas of the business who have enhanced levels of training to support them to spot signs of abuse that may indicate modern slavery.
4. Due diligence processes for slavery and human trafficking
As part of our initiative to identify and mitigate risk we have in place systems to:
identify and assess potential risk areas in our supply chains;
mitigate the risk of slavery and human trafficking occurring in our supply chains;
monitor potential risk areas in our supply chains; and
protect whistle blowers via our Speak-Up Policy.
5. Our risks and how we manage this
As we are based in and operate solely within the UK, we have identified that as an organisation our exposure to the risk of slavery and human trafficking is low. However, as part of our ongoing process to identify and monitor risks we have identified that our key area of risk lies in our relationships with supply chains and contractors. Through the procurement process suppliers are required to share their Modern Slavery Statement or agree to comply with Citizen's, failure to do so will result in their exclusion.
6. Supplier adherence to our values
As an organisation we have a zero-tolerance approach to slavery and human trafficking. To ensure all those in our supply chain and any contractors comply with our values, we have in place a supply chain compliance programme. This consists of incorporating a standard clause into all our new agreements with suppliers and contractors which informs them of our commitment to combatting slavery and human trafficking and requires them to agree to this commitment when working with us.
We are committed to tackling modern slavery and human trafficking and want to work with suppliers who share this commitment.
POLICY STATEMENT Anti-Slavery and Human Trafficking Statement
Version : 10 Author(s) : Kevin Rodgers Approved at/by: Citizen Board
Date: March 2025 Page 3 of 5 Date of review: March 2026
UNCONTROLLED WHEN PRINTED
7. Our effectiveness in combating slavery and human trafficking
We use the following indicators to measure how effective we have been ensuring that slavery and human trafficking is not taking place in any part of our organisation or supply chains:
recording and monitoring any incidents or reports made to us by staff in accordance with our Anti Slavery and Human Trafficking Policy using the mechanisms established in our Speak-Up Policy and Safeguarding Policy and Procedures.
monitoring any incidents or allegations across our supply chains which conflict with our values; and recording any incidents or complaints received from any third parties concerning slavery and human trafficking.
Provide the Safeguarding Committee with performance information on the safeguarding reports made including modern slavery.
8. Training and awareness
We understand that training is fundamental in our duty to ensure that there is no slavery or human trafficking in our business or supply chains. We continue to train and raise awareness amongst staff to help them better understand modern slavery and human trafficking as well as the risks associated with it and how as an organisation, we are working to manage this.
9. Further steps – 2025/26
We are committed to ensuring that our business and supply chains remain slavery and human trafficking free. During the year we will –
Ensure there is continuous monitoring of our business and its supply chains to ensure we are free from slavery and human trafficking.
Undertake a full review of the Anti-Slavery and Human Trafficking Slavery Policy.
Review the training offer and identify any gaps.
Implementation of Citizen's new Procurement Policy and Strategy to ensure ongoing transparency and diligence.
This statement is made pursuant to 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.
POLICY STATEMENT Anti-Slavery and Human Trafficking Statement
Version : 10 Author(s) : Kevin Rodgers Approved at/by: Citizen Board
Date: March 2025 Page 4 of 5 Date of review: March 2026
UNCONTROLLED WHEN PRINTED
Kevin Rodgers, Chief Executive Citizen Housing Limited Date: March 2025
10. VERSION CONTROL
VERSIONDATEAMENDMENTSAPPROVED AT/BYREVIEW
V10.0March 2025Annual updateKevin RodgersMarch 2026
V9.0March 2024Annual updateKevin RodgersMarch 2025
V8.0March 2023Annual updateKevin RodgersMarch 2024
V 7.0March 2022Annual updateKevin RodgersMarch 2023
V 6.0March 2021Annual updateKevin RodgersMarch 2022
V 5.0March 2020Annual update and change to Citizen brandKevin RodgersMarch 2021
V 4.0March 2019Annual updateKevin RodgersMarch 2020
V 3.0March 2018Annual updateKevin RodgersMarch 2019
V 2.0March 2017Annual updateKevin RodgersMarch 2018
V 1.0March 2016Annual updateKevin RogersMarch 2017
POLICY STATEMENT Anti-Slavery and Human Trafficking Statement
Version : 10 Author(s) : Kevin Rodgers Approved at/by: Citizen Board
Date: March 2025 Page 5 of 5 Date of review: March 2026
UNCONTROLLED WHEN PRINTED