As part of our commitment, we uphold the standards set out in the Modern Slavery Act 2015 by implementing systems and controls to ensure that modern slavery is not taking place anywhere within our organisation, or in any of our supply chains.

This statement, made in accordance with section 54 of the Modern Slavery Act 2015, summarises our current approach and sets out the further action we plan to take in the coming year in our business and our supply chains.


Actions to Mitigate Risks


We apply high standards in the recruitment, selection and employment of our people to ensure that:

  • All legal obligations are complied with in the recruitment and induction process;

  • We recruit, promote and develop our people on the grounds of merit and capability;

  • We pay at least the national minimum or above;

  • We periodically conduct an anonymous and confidential staff survey, in which we elicit views about pay, benefits, working hours and conditions as well as leadership, values and culture;

  • We encourage the reporting of concerns and provide appropriate protection for whistle-blowers;

  • All staff and partners are expected to comply with our business principles, ethical values and our sustainable procurement policy as well as any relevant laws and professional codes of conduct applicable to us;

  • We will train new and existing employees to help them understand the issue of modern slavery and its impact.

Supply Chain

As part of our approach to supply chain management we currently, and will continue to:

  • Build long-term relationships with all key suppliers and clearly highlight to them our expectations of business appropriate behaviour and the requirement to meet or exceed all requirements of the Act;

  • Undertake reviews of our current suppliers to identify those where the risk may be enhanced either by the nature of the sector or territory where they operate;

  • Work with such suppliers to understand their own policies on modern slavery, and terminate relationships with any supplier where breaches of the Act are discovered;

  • Develop our standard terms and conditions for suppliers to include a reference to compliance with the modern Slavery Act, and an obligation on suppliers to sign up to our Statement of Supplier Undertakings Relating to Anti-slavery and Human Trafficking Laws;

  • When contracting with third-party supplier terms, seek to include contract clauses relating to modern slavery and human trafficking, and where possible, require suppliers to sign up to our Statement of Supplier Undertakings Relating to Anti-slavery and Human Trafficking Laws.