Modern Slavery Act statement 2025

• Supplier Code of  Conduct
• Staff Code of Conduct
• Procurement Policy  
• Recruitment and Selection Policy
• Grievance Policy & Procedure
• Dignity and Respect at Work Policy
• Sexual Harassment, Exploitation and Abuse (SHEA) and other Safeguarding Concerns Overarching Policy
• Protection from Sexual Exploitation and Abuse (PSEA) Policy
• Sexual Harassment Exploitation and Abuse (SHEA) at Work Policy
• Child Safeguarding Policy
• Whistleblowing Policy
• Access for staff to free Confidential Counselling and Advice Helpline
• Union Recognition Agreement with Unite
• Federation Corporate Engagement Framework
• Federation Financial Management Framework
• Donations Acceptance Policy
• Data Protection Impact Assessment process
• Records Retention & Disposal/Information Asset Register
• Privacy Policy
• Information Security Policy  

We are governed by a Board of Trustees whose role it is to make sure that we stay true to our mission and values, set our strategic direction and monitor delivery against our strategic objectives.

Under our Board of Trustees, our co-CEOs and directors together make up our Executive Leadership Team. The Executive Leadership Team is responsible for day-to-day decision making and managing our four departments

• Advocacy and Influencing
• Funding
• Innovation and Impact
• People, Culture and Transformation
• CEO Office (including Finance, Media and Internal Audit) 

Our Head of Internal Audit and Risk provides assurance to our Board and Management; 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 financial, adverse media and sanctions checks, and references where needed) prior to using any new suppliers with a total spend of £5k or more and/or who will be processing personally identifiable information. For freelancers or consultants, we carry out due diligence on all new engagements regardless of spend.  

3.1 Actions

Given our direct contractual relationship with UK suppliers of goods and services, we have taken the following steps to prevent modern slavery in our supply chains. 

a. Supplier Code of Conduct

We have a Supplier Code of 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. It is a mandatory requirement that all our direct suppliers (with whom we spend £5k or more per year) agree to comply with our Code.

b. Enhanced Due Diligence.

We 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 includes:

• 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.

c. Contracts

Our standard supplier contract forms 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. For all spend over £5k we have the following in our AAUK contracts: 

Modern Slavery and Child Labour 

We apply a zero-tolerance approach to tackling the practice of modern slavery, child labour, trafficked, bonded, or compulsory labour in any of its forms. This applies to both supplier and consultant contracts. In addition, when a supplier prefers to use their contract and we are not able to persuade them otherwise, we always ask for this to be included. 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. Safeguarding Policies

ActionAid has a suite of Global Safeguarding-related policies which dovetail with the global Anti-Modern Slavery Policy. The Global Safeguarding policies were developed by colleagues from around the ActionAid International Federation before being further localised to the AAUK context and ratified by AAUK trustees in March 2022.

e. Staff Policy Induction

We are committed to ensuring that all employees are aware of our policies and procedures, including those related to ethical working practices and modern slavery. As part of our induction process, managers follow a structured checklist that requires employees to read and acknowledge key policies, of which the Anti-Modern Slavery policy is one. Additionally, our policies, including those relevant to modern slavery, are accessible through our online MyHR platform, where employees must confirm they have read and understood them. 

f. Awareness and Training

All staff also undertake mandatory Safeguarding training as part of their induction, either a 2 hour introduction or a full day workshop. A refresher training is carried out every two years. 

All staff are made aware of our Supplier Code of Conduct and the Modern Slavery statements it includes when they join. We also hold  regular training sessions for any staff who require an update.  

g. Monitoring Effectiveness

We monitor the effectiveness of this Policy Statement with UK-based direct suppliers and aim to ensure all suppliers have zero tolerance to modern slavery.

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.

Good progress has been made to increase awareness of modern slavery across the ActionAid Federation.

In relation to international programme procurement, we continue to 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). In June 2019 a global Anti-Modern Slavery Policy was adopted formally by the General Assembly and has subsequently been rolled out across the ActionAid Federation. The policy:

• sets out a zero-tolerance approach to modern slavery within our organisation and our supply chains;
• establishes global minimum standards in respect of labour within our organisation and those of our partners and suppliers;
• puts in place procedures for the identification and investigation of incidents of modern slavery;
• puts in place due diligence monitoring of partners to minimise modern slavery within our supply chains (including programme partners).

AAI undertake scheduled Internal Audits on all federation members to confirm they have a Partnership Policy in place with their Partnership Organisations, these audits also consider their procurement and partner due diligence arrangements more broadly.

AAUK receives copies of internal audits for all delivery partners. An annual attestation process is followed globally to highlight any countries which might be struggling to fully comply with all Anti-Modern Slavery policy terms.

Where this occurs, action plans are drawn up. Progress against the plans is monitored throughout the year and AAUK works with AAI and countries to understand the challenges that contribute to any delays.

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 is responsible for raising awareness and implementing the policy. 

6. Approval

Our financial year end was 31 December 2024. This statement was approved by the ActionAid UK Board of Trustees and signed off by the Treasurer of our Board of Trustees, Anne Tutt, on the 26 March 2025.