The Modern Slavery Act (the ‘Act’) became law on 26 March 2015. Section 54 of the Act, ‘Transparency in Supply Chains’, requires every organisation carrying on a business in the UK with a total annual turnover of £36m or more to produce an annual Statement; setting out the steps they have taken to tackle slavery and human trafficking in their organisation and supply chains.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015.
1. Our organisation
ActionAid in the UK (AAUK) is a member of the ActionAid International federation; a global partnership working together against poverty and co-ordinated by the ActionAid International (AAI) Secretariat based in Johannesburg, South Africa.
We focus our efforts on supporting women and children in extreme poverty to change their lives and communities for good. We raise money to carry out programmes in 44 countries around the world and provide humanitarian assistance in response to emergencies and disasters. We build awareness, and undertake campaigning and policy work.
2.1. Our values
We adhere to clear values including mutual respect, equality and justice for all people. We believe that modern slavery or any kind of forced or involuntary labour is wrong. For this reason, we are committed to zero tolerance of modern slavery in any form. We hold ourselves to the highest ethical standards and expect the same of our partners and suppliers.
2.2. Our supply chains
Firstly, to support our UK operations, fundraising, and influencing work, AAUK procures goods and services across a wide range of indirect categories; including marketing, media, research, facilities, insurance, finance, HR services, IT, and the lease of our office premises. We do not have any significant UK spend in the vulnerable sectors of agriculture, construction, hospitality or manufacturing.
Secondly, we have programme activities in developing countries which are managed locally by our partners, AAI, and federation member organisations (Delivery Partners), rather than directly by AAUK. These organisations receive grants from AAUK, and they in turn may work with additional partner organisations to procure goods and services as required to deliver programmes. We are reliant on our Delivery Partners to put in place policies and procedures to prevent modern slavery within their supply chains.
To date we have seen no evidence of modern slavery in our organisation or supply chains. However, we recognise that modern slavery is very much a hidden crime and we are committed to continuing to focus on understanding our risk exposure and putting in place measures to mitigate risk.
We set out below our approaches both in the UK and in the ActionAid Federation’s international programmes.
3. Our approach in the UK
We are an Accredited Living Wage employer, which means that we pay a living wage to our staff and also all contracted staff who work directly and regularly with us within or on our UK sites.
We have in place the following policies, procedures, agreements, and resources which form part of our approach to mitigate the risk of modern slavery among our direct suppliers in the UK
i. Ethical & Environmental Procurement Policy
ii. Procurement Policy
iii. Agency Workers Policy
iv. Recruitment Policy & Procedure
v. Grievance Policy & Procedure
vi. Harassment Policy & Procedure
viii. Whistleblowing Policy
viiii. Child Protection Policy
ix. Access for staff to free Confidential Counselling and Advice Helpline
x. Union Recognition Agreement with Unite
xi. Federation Corporate Engagement Framework
xii. Federation Financial Management Framework
Under our Board of Trustees, our Chief Executive and four directors make up our Senior Leadership Team (SLT) and are responsible for day-to-day decision making and managing our four departments:
- Public Engagement
- Policy, Advocacy and Partnerships
- Organisational Effectiveness.
Our Head of Internal Audit provides assurance to our Board and SLT; through reviewing the effectiveness of our governance, risk management and control processes, and also working with the ActionAid International audit team to carry out reviews of ActionAid programmes globally.
In the UK, we carry out due diligence, including ethical checks, prior to using any new suppliers with a total spend of £5k or more.
Given our direct contractual relationship with UK suppliers of goods and services, we are in a position to take the following steps to prevent modern slavery in our supply chains in 2017.
a. Ethical Code
We have developed an Ethical Code of Business Conduct which explains the manner in which we will behave as an organisation, and the standards which we want our suppliers and partners to also achieve. In the coming year, we will make it a mandatory requirement that all our UK-based direct suppliers (with whom we spend £5k or more per year) agree to comply with our Code.
b. Enhanced Due Diligence
We will carry out enhanced due diligence on all new UK-based direct suppliers with whom we will spend £20k or more (based on total contract value). This will include:
- vetting questions related to Modern Slavery Act compliance, as applicable
- contracts or agreements which stipulate assurances relating to tackling modern slavery in their own organisation and supply chains
In relation to partners, we will be developing a new due diligence checklist which will increase our levels of assurance relating to the sound governance and ethical practices of our partners.
We will be amending our standard supplier contract to include a right to terminate in the event that we find, or have reasonable grounds to believe, that modern slavery or any form of forced or involuntary labour is being used.
However, where appropriate we will work with suppliers and partners to address any issues which arise, always bearing in mind the best interests of those who may have been badly treated, harmed or exploited in our organisation or anywhere in our supply chains due to modern slavery or any forced or involuntary labour.
d. New Safeguarding Policy
We currently have a Child Protection Policy, but we are aware that we need to introduce standards relating to the safeguarding of vulnerable people more generally. We are therefore in the process of developing a new Safeguarding Policy which will cover both children and vulnerable adults. This will be completed this year.
e. Staff Policy Handbook
We continually review and update all of our policies in line with both legislation and best practice, ensuring that we have a robust review and renewal schedule in place. Currently these policies are online yet are not easy to navigate. To rectify this we are consolidating all our policies together into one staff handbook which will be completed this year.
f. Awareness and Training
The introduction of our Ethical Code of Business Conduct and updating of our procurement, screening and contracting processes will result in an increased awareness of modern slavery amongst our staff and suppliers. All our staff will be made aware of this Modern Slavery Policy statement and our Ethical Code of Business Conduct as part of their induction, and it will be included in our online Staff Policy Handbook.
Our Commercial Manager, who has overarching responsibility for procurement and contracting, has completed the Open University’s 15-hour course on Modern Slavery and has attained the CIPS certificate in Ethical Procurement and Supply.
g. Monitoring Effectiveness
We will monitor the effectiveness of this Policy Statement with UK-based direct suppliers and report next year on our progress against the following measures:
- % of applicable procurements adopting new procurement questionnaire documents which include obtaining assurances related to modern slavery
- % of new partnership screenings which include obtaining assurances related to modern slavery
- % of applicable new contracts and agreements entered into with modern slavery provisions
- % of applicable suppliers and partners signed up to our Ethical Code
4. Our approach to international programme delivery
We recognise that there is a heightened risk of modern slavery in the countries where our partners deliver programmes, as we know that poverty is a key driver of slavery and is often used unethically as a justifier of modern slavery practices.
However in relation to international programme procurement, further work needs to be done to increase awareness of modern slavery across the ActionAid Federation, work with our partner organisations to develop effective policies which address the unique challenges of the development sector in each individual country, and see these adopted and embedded within each member organisation’s operations. This will take time, but AAUK are committed to achieving this over the medium term.
In accordance with ActionAid’s membership regulations, it is for AAI to set policies and procedures to be adopted across the global federation and to monitor compliance with these by every member organisation (including AAUK). Therefore, in 2017 we will work to commence a dialogue around modern slavery with colleagues in AAI and federation member organisations, with the aim of being in a position to agree a global policy in 2018.
5. Review and responsibility
The Board of Trustees has overall responsibility for ensuring that this statement complies with our legal and ethical obligations, and that it is reviewed on an annual basis. Management are responsible for raising awareness and implementing the policy. The Commercial Manager and Head of Internal Audit have responsibility for implementing this policy statement and monitoring its effectiveness.
This statement was approved by the ActionAid Board of Trustees on 15 June 2017.