Modern slavery statement
Introduction
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.
Definitions
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 (www.tiscreport.org).
About Natural Resources Wales (NRW)
Natural Resources Wales is the largest Welsh Government Sponsored Body – employing circa 2,700 staff across Wales with a budget of circa £298 million for 2025/26.
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 currently 11 further Non-Executive Directors who are appointed by the Welsh Government, plus the Chief Executive.
Around 60% 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
- Digital, Data and Technology (DDaT)
- Corporate and People 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 and statutory duties.
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, in consultation with key stakeholders (internally and externally).
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 policy as well as a Resolution procedure through which staff can raise grievances. Staff employed on a temporary basis (as Agency workers / specialists) 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.
To strengthen our due diligence against Modern Slavery and Human Trafficking, we've incorporated a specific question into the Category Management Strategy template. This vital improvement will enable a strategic level assessment of risk, complementing the updates we've also made to the Procurement Plan template.
We undertook a benchmarking exercise with other public sector bodies to understand their approaches to Modern Slavery and Human Trafficking. This engagement confirmed that our current processes align with the practices adopted by other organisations in the public sector across the UK.
Our ability to focus on our Modern Slavery and Human Trafficking initiatives has been greatly enhanced by the appointment of a Procurement Strategy and Development Advisor. Part of the role is to manage and mitigate these risks for the organisation.
We have continued to make prompt payment to our suppliers to reduce the risk of unethical practices filtering through our supply chain.
Our future commitments
This is NRW’s sixth Modern Slavery Statement. Our work in this area is built upon and developed each year, and we continue to review our progress and update the statement annually within each financial year.
To drive continuous improvement, we will conduct a formal review of our Modern Slavery and Human Trafficking prevention initiatives. This will involve assessing the effectiveness of our actions over the past five years and strategically planning future commitments for Procurement, the Contract Management Support Service (CMSS) and other areas of the business where these risks can occur.
We will develop and regularly update a newly created action plan, allowing NRW to track and monitor the effectiveness of our initiatives. This structured approach will allow us to demonstrate measurable progress and drive continuous improvement in combating modern slavery and human trafficking.
To enhance staff understanding, we will formally review and update our Modern Slavery intranet page and will then launch initiatives to actively promote and boost awareness of this important issue across the organisation.
We will undertake e-learning training on Modern Slavery within the Procurement and Contracts function with a view of rolling it out to staff via the Learning Management System (LMS) in the future.
We will continue to develop our Procurement and Contracts strategy, embedding enhanced Modern Slavery and Human Trafficking management prevention measures into the strategy and the accompanying Procurement and Contract strategy action plan.
Our ongoing commitment to prompt supplier payments will be formally evidenced through the introduction of payment compliance notices and strengthened contract management approaches. These measures align with the compliance requirements of the Procurement Act 2023 and the Socially Responsible Procurement Duties of the Social Partnerships and Public Procurement (SPPP) Act, promoting fair and timely transactions.
We will maintain our collaboration with other Welsh public sector bodies, across a range of procurement networking groups and relationships. Through this, we aim to share our approaches and integrate any widespread good practice in Wales to strengthen our adherence to the Modern Slavery Act.
We will remain up to date with all available policies, tools, guidance, and training on Modern Slavery and Human Trafficking from the UK Government and Crown Commercial Services.
This statement will be reviewed annually and has been approved by the Board.
Signed by: Ceri Davies, Interim Chief Executive Officer
Date: 5 December 2025