Modern slavery statement 2023-24
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.
Through our Corporate Plan and legislation such as the Modern Slavery Act, the Well-being of Future Generations Act and the Social Partnerships and Public Procurement Act, our ambition is to see nature and people thriving together and our values are at the heart of who we are as an organisation. We are proud to
serve the people of Wales by being:
- Connected: we value our deep-rooted attachment to the land and water, nature and communities of Wales and build meaningful partnerships
- Bold: we use our voice, take action to make a difference and lead by example
- Caring: we listen to understand, care for each other and the communities we serve, and the environment we all depend on
- Resourceful: we explore new ways of doing things, innovate to accelerate change and use our resources effectively.
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:
o forced to work through mental or physical threat
o owned or controlled by an 'employer', usually through mental or physical abuse or the threat of abuse
o dehumanised, treated as a commodity or bought and sold as ‘property’
o 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 circa £265 million for 2023/24.
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 12 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 and Consultancy
- Fleet Management
- Facilities and Assets
- Professional Services
- Land Management
- Hydrometry & Telemetry
- Forest Operations
- Laboratory Services
NRW has many of its own contracts and frameworks for specific categories of expenditure and these are used by our staff to deliver our objectives.
The Welsh Government Commercial Delivery (WGCD) department work in conjunction with the wider public sector including local authorities and NHS Wales to develop and deliver collaborative national framework agreements. NRW utilise a number of these agreements and 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 are an accredited member of the Real Living Wage Foundation and therefore honour the Real Living Wage commitments to our employees (including Agency workers), full time, or part time.
Our policies and working practices
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.
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 Raising a Serious Concern in the Public Interest (Whistleblowing) policy in place for members of staff to raise any concerns about wrongdoing as well as
guidance for staff experiencing domestic abuse. We also have a Bullying and Harassment as well as a Resolution procedure through which staff can raise grievances. Staff employed on a temporary basis (as Agency workers) 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. These new ways of working and improved contract management will also ensure greater monitoring and transparency against the agreements we put in place.
We have continued to make prompt payment to our suppliers 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 fourth 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 have completed a review of our procurement documentation and ensured that ethical employment practices are considered as part of the procurement process.
We will develop a procurement and contracts strategy and will complement the aims of the Social Partnership and Public Procurement (Wales) Bill, once it becomes law, further embedding fair pay and equal treatment of employees and the employees of our supply chains within NRWs ways of working.
We will liaise with other Welsh public sector bodies to share approaches and adapt any good practice that is commonplace in Wales when adhering to the Modern Slavery Act.
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 increase transparency in our supply chains with the aim of reducing the risk of modern slavery and unethical practices.
Over the 2023-24 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 will ensure we remain up to date on external supply chain risks and issues that impact on our service delivery, through close networking with the Welsh Government and other key stakeholders.
This statement will be reviewed annually and has been approved by the Board.
Signed by: Clare Pillman, Chief Executive of Natural Resources Wales