Modern Slavery Act statement 2022
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.
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.
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, the steps we take to monitor this are set out in Section 4.
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 with us.
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:
- Supplier Code of Conduct
- Staff Code of Conduct
- Procurement Policy
- Recruitment and Selection Policy
- Grievance Policy & Procedure
- Harassment 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
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 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 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 have taken the following steps to prevent modern slavery in our supply chains.
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.
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 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.
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.
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 January 2021.
The Staff Handbook has been completed and is online for staff use. The Handbook links to the Modern Slavery Statement which is located on AAUK’s main pages.
Awareness and Training
The Anti-Modern Slavery Policy adopted in June 2019, is a mandatory policy for every staff induction.
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.
We have recently updated our Supplier Code of Conduct to include more rigorous screening processes and formal reviews of our top suppliers. We are currently rolling this out to all existing suppliers, and it will be included in all future contracts above £5k. All staff are made aware of this Supplier Code of Conduct and the Modern Slavery statements it includes when they join. We also hold monthly induction sessions for any staff who require an update.
We monitor the effectiveness of this Policy Statement with UK-based direct suppliers. We aim to achieve 100% compliance. 95% of new partnership screenings which include obtaining assurances related 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.
In 2022, AAUK provided 3 grants to fellow federation members to develop resources to increase awareness and understanding of the modern slavery policy. Resources included policy translations, one page posters and a training video. These resources have been made available to the wider federation.
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.
Our financial year end was 31 December 2022. 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 16 June 2023.
Page updated 5 July 2023