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 to support women and girls, as part of our works against poverty and co-ordinated by the ActionAid International (AAI) Secretariat based in Johannesburg, South Africa.
We focus our efforts on supporting women and girls 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 departmental directors make up our Senior Leadership Team (SLT) and are responsible for day-to-day decision making and managing our four departments:
Policy, Advocacy and Partnerships
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 taking the following steps to prevent modern slavery in our supply chains in 2019 and beyond.
a. Ethical Code
We have 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. This Code is attached to every AAUK Supplier Contract (Company and Individual), and where the Supplier contract is used in lieu of the AAUK contract, the Ethical Code of Business Conduct is inserted into such contracts, making all suppliers subject to our AAUK Ethical Code.
b. Enhanced Due Diligence
Since 2017, we have carried 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:
New Supplier Questionnaires, with Terms, which specifically investigate a company’s adherence to both labour wages, London Living Wages, and modern slavery legislation adherence. Once a Supplier is selected, we conduct review by vetting questions related to Modern Slavery Act compliance, as well as require adherence in subsequent contracts or agreements which stipulate assurances relating to tackling modern slavery in their own organisation and supply chains.
In 2017 and again in 2018, and again in 2019 we amended our standard supplier contract forms 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
In 2017-18, we put in place a new Safeguarding Policy in line with the commitment in our 2017 Modern Slavery Statement. In 2018-19 we will work with colleagues from around the ActionAid International Federation to finalise and roll out a new suite of safeguarding-related policies, which will dovetail with the global Anti-Modern Slavery Policy. This will include a new Code of Conduct for staff.
e. Staff Policy Handbook
The new Staff Policy Handbook has been completed and is online for staff use. The Handbook links to the 2017 version of the Modern Slavery Statement rather than the present 2018 version, which is located on AAUK’s main pages.
f. Awareness and Training
A new global Anti-Modern Slavery Policy is being adopted in June 2019. Therefore, a key focus over the next year will be to train staff on this policy so that they can recognise and report incidence of modern slavery which they observe.
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 Procurement induction, and it will be included in our online Staff Policy Handbook.
Our Contracts and Procurement Manager, who has overarching responsibility for procurement and contracting, has a law degree and additional training in ethical contracting via the International Association of Contract and Commercial Management, and maintains updates in the subject regularly.
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:
For the period of August 2018 – May 2019:
- 100% of applicable procurements adopting new procurement questionnaire documents which include obtaining assurances related to modern slavery;
- 95% of new partnership screenings which include obtaining assurances related to modern slavery;
- 98% of applicable new contracts and agreements were entered into with appropriate contractual provisions relating to the prevention of modern slavery;
- 97% 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 AAI’s Membership Regulations, it is for the General Assembly of 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). Accordingly, AAUK has proposed a global Anti-Modern Slavery Policy to the General Assembly due to take place on 27 June 2019. Once adopted, this policy will be rolled out across the ActionAid Federation. The policy will:
set out a zero-tolerance approach to modern slavery within our organisation and our supply chains;
establish global minimum standards in respect of labour within our organisation and those of our partners and suppliers;
put in place procedures for the identification and investigation of incidents of modern slavery;
put in place due diligence monitoring of partners to minimise modern slavery within our supply chains (including programme partners).
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 updated statement was approved by the ActionAid Board of Trustees on 14 June 2019.