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.
- forced to work through mental or physical threat
- '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 in the Transparency in Supply Chains (TISC) register on the the TISC webpage
About Natural Resources Wales (NRW)
Natural Resources Wales is the largest Welsh Government Sponsored Body - employing 2,070 staff across 17 offices and 36 depots pan Wales with expenditure of £225 million in 2020/21.
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 each financial year 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.
Almost half of our income is derived from Grant in Aid from the Welsh Government, but we also generate income by charging for some of our services and a number of commercial activities including timber sales and tenancies. We are a member of two limited liability partnerships: ‘Forest Holidays Public Sector Holdings LLP’ and ‘Camping in the Forest Public Sector Holdings LLP’.
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) and Eastern Shires Purchasing Order (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 out business relationsips.
We aim 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 whistle-blowing 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 Pertemps and Hays.
Progress against our commitments
This is NRW’s second Modern Slavery Statement. Our first statement was published at the start of the Covid-19 lockdown, and unfortunately the pandemic has seriously affected our ability to make progress against our objectives.
Over the 2020-21 operational year we intended to facilitate a discussion across the organisation about the Modern Slavery Act (2015) with a view to developing a more detailed plan and priorities for the following year. In practice, we made progress in some areas, but there is still much more to do:
- We signed up to the Welsh Government’s ‘Code of Practice for Ethical Employment in Supply Chains’.
- We carried out an assessment in the areas of Procurement, Commercial, Leases, Human Resources and Facilities & Fleet Services to review our current compliance with the commitments in the Code of Practice.
- We amended our Invitation to Tender document to make a specific commitment to eliminating Modern Slavery.
- We investigated what training opportunities exist in this area and might be appropriate for NRW staff.
- We established an internal group of staff volunteers to help shape our response to eliminating Modern Slavery.
- We connected with other regional and Welsh groups who are working in this area so that we can learn from best practice.
- We ensured that our whistle-blowing mechanism allows for people outside our organisation to raise suspicions of unlawful and unethical employment practices.
Our future commitments
Our priorities for the 2021-22 operational year will be:
- We will initiate discussions across the organisation to identify other areas of the business that could potentially be affected by issues related to Modern Slavery
- Once these assessments and discussions have concluded, we will prioritise the commitments according to NRW’s current position and develop an action plan with timescales to set out the activities and actions that we will undertake to implement each commitment
- We will appoint an Anti-Slavery and Ethical Employment Champion
- We will incorporate consideration of the Modern Slavery Act (2015) into the development and review process for all our corporate policies and procedures
- We will roll-out training on Modern Slavery across NRW
This statement will be reviewed annually and has been approved by the Board.
Signed by: Clare Pillman, Chief Executive of Natural Resources Wales