Modern Slavery Statement
Although we understand that the scope of the Modern Slavery
Act 2015 is limited to companies carrying on business in the UK with a turnover
of at least £36m, as an organisation committed to the welfare and protection of
children, we have prepared this statement to reflect our zero-tolerance approach
to modern slavery and human trafficking. We are committed to acting ethically
and acting to prevent and tackle modern slavery and human trafficking throughout
our own organisation as well as in our supply chain and partner organisations.
The policies and processes we have implemented to reflect our zero-tolerance approach to modern slavery and human trafficking include the following:
committed to the welfare and protection of children, we have a comprehensive Child
Safeguarding and Protection Policy and require that our grantees also have
their own safeguarding policies. We often work with our grantees and partner organisations
to help them develop their own safeguarding procedures and encourage them to
regularly report and investigate any issues that may arise.
check that all our staff have appropriate right to work documents and have a
staff Code of Ethics and an Equal Opportunities Policy that includes commitments
to treat all our staff with respect, fairness and good faith (including in
respect of remuneration) and provide conditions of employment that safeguard
their rights, welfare and wellbeing in the work place.
staff employ our shared values and behaviours in their work including honesty.
Our Whistleblowing Policy, along with our Health & Safety Policy are also
designed to give staff the confidence to raise serious concerns, including
where the health and safety of an individual is being endangered.
- We ensure
that adequate information and training is provided to all our employees and
contractors relating to equal opportunities and respect for all. We will provide
training for all our staff, with a focus on types of modern slavery and human
trafficking and how to identify them.
- We use
suppliers and consultants to support the operations of our organisation in the
UK and internationally. The key areas in
which we engage suppliers are:
o facilities management
o construction and design
o information technology
o legal and investments
o learning and development
o payroll, pension and insurances services
o hotel accommodation
also deal with many organisations through our grants and charitable
investments. The majority of these are international organisations, who
do not explicitly consider modern slavery in their policies and processes
as this is not a legal requirement for them.
adopt a risk-based approach to the organisations that we fund or suppliers that
we engage. Before working with a
supplier or funding an organisation, we may carry out a modern slavery and
human trafficking risk assessment, where we believe the risk of modern slavery
may arise. Based on that assessment we may
request further information to satisfy ourselves that the organisation is
taking appropriate actions to prevent modern slavery and human trafficking in
out due diligence, where we provide funding to an organisation or contract with
a supplier using one of our template standard form contracts, we require them
to confirm that slavery and human trafficking is not taking place in their
business or supply chain. These
organisations are also required to implement appropriate due diligence procedures
in their own businesses to identify and prevent modern slavery and human
trafficking in their supply chains. Our
contracts require contract counterparties to report serious incidents and to
cooperate with us in discharging any legal obligations in respect of such
incidents. We reserve the right to
terminate the contracts where they fail to do so.
diligence and monitoring are ongoing to improve supplier vetting and to
minimise further a range of risks, including slavery and human trafficking.
Our Legal and Finance teams have responsibility for our
approach to modern slavery. As part of
the process of preparing this statement, a questionnaire was sent to each of
our suppliers where we identified a potential risk in relation to modern
slavery and human trafficking. We
reviewed those responses to identify any concerns and followed those up where
necessary. The responses received were also
used as part of a review of our own procedures to ensure they were effective. We intend to continually review our processes to
ensure they are appropriate and effective in identifying and addressing modern
slavery and human trafficking in our business.
Our policies are monitored by a relevant policy owner within our organisation. We will continue to review our policies to ensure that they are effective and appropriate.