Modern slavery statement 2021-22
This Statement is designed to satisfy the requirements of Part 6 Section 54 of the Modern Slavery Act (2015) and forms part of our commitment to the Welsh Government’s ‘Code of Practice for Ethical Employment in Supply Chains’ and the UK Woodland Assurance Standard (UKWAS).
As the largest Welsh Government Sponsored Body, we hold ourselves to the highest standards of ethical conduct in all our activities and are committed to continuous improvement. NRW does not engage in, or condone, the practices of human trafficking, slavery or enforced labour.
Our Values are at the heart of who we are as an organisation. They outline what is important to us, what we are like as people and what we are here to do:
- We are passionate about the natural environment of Wales
- We care for each other and the people we work with
- We act with integrity
- We make a difference now and for the future
- We are proud to serve the people of Wales
We are committed to improving our business practices to combat modern slavery and human trafficking and to ensure that we are not complicit in any human rights violations. We are committed to zero tolerance of slavery, human trafficking, and child labour practices.
For the purposes of this statement, we have adopted the following definitions:
- 'Slavery' is where ownership is exercised over a person. Someone is in slavery if they are:
- forced to work through mental or physical threat
- owned or controlled by an 'employer', usually through mental or physical abuse or the threat of abuse
- dehumanised, treated as a commodity or bought and sold as ‘property’
- physically constrained or have restrictions placed on their freedom.
- 'Servitude' involves the obligation to provide services imposed by coercion.
- 'Forced or compulsory labour' involves work or service extracted from any person under the menace of a penalty and for which the person has not offered themselves voluntarily.
- 'Human trafficking' concerns arranging or facilitating the travel of another with a view to exploiting them.
This statement will be published on the Transparency in Supply Chains (TISC) register (tiscreport.org).
About Natural Resources Wales (NRW)
Natural Resources Wales is the largest Welsh Government Sponsored Body – employing over 2,400 staff across 17 offices and 36 depots pan Wales with a budget of £240 million in 2022/23.
We were set up as per the specifications in The Natural Resources Body for Wales (Establishment) Order 2012 and The Natural Resources Body for Wales (Functions) Order 2013. We receive a Remit Letter setting out what the Welsh Government wants us to achieve during that year and a Funding Letter setting out the budget available to us.
Our work is overseen by a Board that consists of the Chair and 11 further Non-Executive Directors who are appointed by the Welsh Government, plus the Chief Executive.
Around half of our income budget is derived from Grant in Aid from the Welsh Government, but we also generate income by charging for some of our services and several commercial activities including timber sales and tenancies.
Our Supply Chains
NRW’s supply chains predominantly fall within the following categories:
- Civil Engineering
- Fleet & Facilities
- ICT equipment and services
- Professional services
- Land Management
- Hydrometry & Telemetry
- Forest Operations
NRW has many existing contracts and frameworks for specific categories of expenditure. The National Procurement Service (NPS) is a central purchasing body whose role is to set up contracts and framework agreements for use by the Welsh Public Sector. We also utilise the Crown Commercial Service (CCS), Yorkshire Purchasing Organisation (YPO) and Eastern Shires Purchasing Organisation (ESPO) frameworks where appropriate. Decisions on whether to purchase from a suitable NRW contract or framework agreement are made by the Procurement Lead or Category Lead.
We honour the Living Wage for all our employees, full time, or part time.
We are committed to making sure that there is no modern slavery or human trafficking in our supply chain or in any part of our business. We continue to develop our policies and procedures to reflect our commitment to acting sustainably, ethically and with integrity in all our business relationships.
We are aiming to develop, implement and enforce effective systems, processes, and controls to ensure that no child labour, slavery, or human trafficking is taking place linked to our activities. This is a significant undertaking and will cover many areas of NRW’s business.
NRW mitigates the risk of modern slavery occurring in its workforce by ensuring that directly employed staff are recruited via robust HR recruitment policies. There is a whistleblowing policy in place for members of staff to raise any concerns about wrongdoing as well as guidance for staff experiencing domestic abuse. Staff employed on a temporary basis are, where possible, recruited through NRW’s approved suppliers.
Progress against our commitments
Our operational teams continue to be vigilant to this issue. Via their partnership work and proactive engagement with outside specialist agencies, we have developed a greater understanding of potential areas of our operation where instances of modern slavery are more likely.
We have set up an intranet page to raise awareness of Modern Slavery internally. This page includes information on how to spot potential signs of Modern slavery, informs staff how to raise concerns and provides various signposts to more in-depth sources of advice.
We have established a Contract Management Support Service for the organisation. Although newly established, this team will embed good Contract Management practice, supporting staff to manage contracts to ensure outcomes are achieved by equipping them with the necessary tools and guidance. This initiative will also ensure greater transparency.
We have continued to make prompt payment to our supply chain during the Covid pandemic to reduce the risk of unethical practices filtering through our supply chain.
Within our tendering processes, Modern Slavery and Ethical Employment have become embedded as key considerations, forming part of our selection criteria.
Our future commitments
This is NRW’s third Modern Slavery Statement. Our work in this area is built upon and developed each year, and we continue to review our progress and statement annually at the end of each financial and operational year.
We recognise that combating modern slavery and human trafficking requires a coordinated, collaborative, and long-term approach.
We will review our procurement strategy and associated documentation over the coming year and ethical procurement will feature in this review. We will also look to support Welsh Government in its review of Fair Work Principles and respond appropriately to the new Draft Social Partnership and Public Procurement (Wales) Bill.
We will continue to review our internal processes and monitor the effectiveness of our actions against modern slavery and human trafficking. We will attempt to raise awareness of increased transparency in our supply chains to be able to reduce the risk of modern slavery and unethical practices.
Over the 2022-23 operational year we will continue to provoke discussion and raise awareness across the organisation about the Modern Slavery Act (2015) and what risks this could pose to us as an organisation.
We are reacting to the unfolding crisis in Ukraine and will act in line with Welsh Government procurement policy in relation to identifying any impacts on our supply chains.
This statement will be reviewed annually and has been approved by the Board.
Signed by: Clare Pillman, Chief Executive of Natural Resources Wales