Modern Slavery Statement

Introduction

Karbon Homes Group is committed to preventing, identifying and reporting modern slavery and human trafficking in our business, supply chains and communities. We do this through:

• our procurement activities;
• our employment practices; and
• our role as a social housing provider, including reporting any suspected cases of modern slavery or human trafficking within our communities to the relevant authorities.

This statement sets out how we seek to prevent modern slavery and human trafficking. It is made pursuant to Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 and is Karbon Homes Group’s modern slavery statement for the financial year 1 April 2026 to 31 March 2027.

Structure and supply chains

Karbon Homes Group (the Group) is a provider of social housing and related services registered with the Regulator of Social Housing. We are a charitable registered society under the Co-operative and Community Benefit Societies Act 2014.

Since our formation in 2017, we have focused on delivering our three strategic aims: providing as many high-quality homes as possible, delivering excellent services to our customers, and helping to shape strong, sustainable communities.

Karbon provides homes and services which form the foundations for people and places to fulfil their potential. As a housing association, we own or manage over 35,000 properties across the North-East of England and Yorkshire and develop more homes every year. We provide social rented, affordable, specialised, and market rented homes, along with the development of shared ownership and market sale homes to meet our customers’ aspirations.

We always make the effort to understand our customers. We believe that everyone deserves respect.  Everyone’s voices should be heard.  And everyone deserves someone in their corner now and then.  We believe that by focusing on our three strategic aims, combining a sound business head with a strong social heart, and staying true to our values, we can build strong foundations for even more people.

We recognise our responsibility to take a robust and zero-tolerance approach to slavery and human trafficking. We are also committed to ensuring there is transparency in our own business and that our approach to tackling modern slavery is consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect our contractors, suppliers and business partners to share the same high standards. We do this through our structure, which is outlined in appendix 1.

Policies on modern slavery and human trafficking

The group has a Policy and Strategy Framework which is approved by the Board. Our policies apply group wide, and to our subsidiary organisations as appropriate. We review policies at least every three years to make sure that they continue to reflect the Group’s aims and our regulatory and statutory obligations.

All our policies set out specific responsibilities by role and have a named owner responsible for overall implementation, enforcement and monitoring. Policy documents are available to all employees via SharePoint. We also publish relevant policies on our website so that they are accessible to customers and to suppliers.

The following strategy and policies comprise our approach to identifying modern slavery risks and preventing slavery and human trafficking in our operations.

Anti-Fraud, Anti-Theft and Anti-Bribery and Corruption Policy 

Confirms the group’s anti-financial crime position and sets out the control framework that is in place to mitigate financial crime. All allegations of financial crime, including allegations of modern slavery and human trafficking, are investigated and reported. We complete an annual financial crime risk assessment including modern slavery and human trafficking. The risk of financial crime and modern slavery and human trafficking are assessed as low.

Procurement Policy and Strategy

Our Procurement Policy sets our rules and principles for procurement. All staff engaged in managing or leading contracts for goods or services must also adhere to our Contract Management Framework. We have controls in place to make sure that goods and services are procured in compliance with modern slavery and human trafficking. Procurement activity above and below relevant thresholds requires bidders to provide confirmation and information on Modern Slavery Act compliance.

Our Procurement Strategy 2025-28 includes actions to build trust in our supply chains through supplier relationship management and market engagement. We are enhancing supply chain and contract management controls by driving maturity in our procurement practices and understanding risk in our supply chains. This includes maintaining embedded compliance principles and oversight throughout the contract lifecycle from procurement to contract expiry.

Speak Out

We encourage all employees, customers and other business partners to report any concerns related to our activities or supply chains. We maintain a register which is overseen by our Audit and Risk Committee. Our Speak Out Policy sets out the group’s commitment to employees who make disclosures that they can do so without fear of retaliation.

Code of Conduct

Our code provides a clear framework for how we expect Karbon employees and contractors to conduct themselves. We strive to maintain a work environment in which honesty, integrity and respect for colleagues, customers and clients are constantly reflected in personal behaviour and standards of conduct.

Onboarding, Probation & Transition Policy

We carry out Right to Work checks for all new employees. We have a Preferred Supplier List for recruitment and agency workers. We use only specified, reputable employment agencies to source labour and always verify the practices of any new agency before accepting workers from that agency. We will complete a scheduled review of the Colleague Selection Policy in 2026 to ensure it remains effective.

Grievance Policy

We aim to ensure that colleagues are treated in the same way in similar circumstances and issues are dealt with fairly and reasonably. Employees can raise a grievance if they are concerned with the way in which they have been treated by the business, managers or colleagues. Our Grievance Policy is consistent with the ACAS code of practice on grievance procedures.

Safeguarding Policy

We seek to tackle modern slavery and human trafficking in our communities in our role as a social housing provider. Our Safeguarding Policy reinforces our commitment to work with partners to prevent harm, promote dignity, and safeguard the wellbeing of both adults and children in our communities. It outlines clear roles and responsibilities for staff members, contractors and partners, embeds the principles of professional curiosity, and sets expectations for recognising, reporting, and responding to concerns.

All employees, agency workers and contractors are responsible for sharing information and raising alerts where there is a concern of modern slavery and human trafficking. Our mobile IT system allows employees to report welfare concerns in real-time, which are triaged by managers and the Customer Services Team. Customers are also able to report to us any suspicions they may have regarding potential instances of modern slavery and human trafficking.

Risk Management Policy

Our Risk Management Framework, including our Risk Management Policy, ensures we have a consistent approach to risk management and assurance. The policy identifies and assigns responsibilities in relation to risk management, control and assurance aligned to our governance and delegated authority arrangements.

Due Diligence processes

The group will only trade with suppliers who fully comply with the Modern Slavery Act or are taking the necessary steps towards compliance.

We undertake due diligence when we take on new suppliers and procure new contracts. Our procurement procedures require potential suppliers to declare whether they comply with the Modern Slavery Act. If they are not compliant, they are required to explain why. We will reject any bids that indicate non-compliance and fail to provide sufficient detail regarding the reasonable measures being taken to achieve compliance.

Our Standard Terms and Conditions of Purchase for suppliers include a requirement to comply with the Modern Slavery Act.

Our contract management framework and central contracts register ensure consistency across the group and allow contracts to be managed and actioned accordingly. Contract managers are required to maintain and review contract records including evidence of supplier policies and procedures. We carry out contract monitoring reviews on a sample basis.

Work to enhance understanding of risk in our supply chains in 2025-26 has enabled a greater focus on due diligence both prior to contract award and throughout the contract lifecycle.

We have carried out a review of the recommendations in the Government’s updated Transparency in Supply Chains Guidance (March 2025) which has informed our risk assessment and preparation of this statement, and the identification of future improvement actions.

Assessing the Risk

Our 2026 modern slavery and human trafficking risk assessment found that the group is at low risk of slavery and human trafficking within our operations. The assessment was made by reviewing our operating and internal control environment, including the sector we work in, our governance and procurement arrangements, incident reporting mechanisms, and training and support for staff to identify and report concerns or indicators of modern slavery and human trafficking encountered during service delivery.

Potential risks are mitigated by our policies and procedures, controls built into our business operations and the knowledge, skills and behaviours of our employees.

The Board, Audit and Risk Committee and Executive Directors Team regularly review risk exposure, controls and assurance activity along with how this aligns to defined risk appetite and tolerance measures. The Board approves and monitors actions where risks may require closer alignment to risk appetite.

The group has a rolling programme of internal audit activity covering all areas of our operations. An internal audit review of Counterparty Risk took place in December 2025. It reached a reasonable assurance risk conclusion, and we will act on the recommendations in 2026-27. None of the identified actions related to modern slavery and human trafficking.

Performance and Future Plans

We are pleased to state that no incidents of modern slavery and human trafficking in our operations have been reported during this period.

In 2026-27 we will continue our programme of work to improve the group’s procurement maturity and Procurement Act 2023 compliance related controls. This will help teams better understand their supply chains and further strengthen our controls relating to modern slavery and human trafficking compliance.

Approval

This statement has been published pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Karbon’s slavery and human trafficking statement for the financial year 2026-27. It has been approved by the Board of Directors and will be reviewed annually.

Date of approval: 25/09/2026