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Published 25 November 2021
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This publication is available at https://www.gov.uk/government/publications/dit-modern-slavery-statement/department-for-international-trade-modern-slavery-statement-2020-to-2021
From William Wilberforce to the modern day, the commitment of HM Government to eradicating slavery remains. Work remains necessary too. Forty million innocent men, women and children across the globe have been forced into various forms of modern slavery – in sectors, products, and regions that most people would not ever consider – as we all go about our daily lives.
The exploitation of our fellow man is a vile practice. My department is using its considerable influence on the world stage, leveraging global moments, such as the G7 Summit, and harnessing trade deals, to put focus on this issue. We have undertaken to develop robust policies and processes that will underpin our future work, and we have set ambitious targets to guide our progress in tackling this important issue.
We are at the start of a new journey. Just as the Royal Navy tackled slavery in the 19th century, so too must Global Britain tackle modern slavery as she sets sail again in the 21st century. We know that today’s global supply chains are complex and that this provides significant challenge for any organisation seeking to unearth and tackle these practices. We acknowledge that there is more to do.
We know that we need to work across HM Government to work closely with our suppliers. We know that many are equally committed to tackling modern slavery, and we pledge to work with them to make sure that we are always improving our ability to identify and act against these practices.
I am pleased to support the Department for International Trade’s first modern slavery statement. I will be reviewing and monitoring our progress against the objectives we have set in the statement regularly, and I look forward to reporting on this in our statement next year.
My thanks to all who have worked to date to eradicate modern slavery from HM Government’s supply chains. Together, we answer the question of the Wedgwood Medallion without doubt: we are all men and brothers.
The Department for International Trade (DIT) is a world-class trade negotiation and trade promotion department. Our global network of highly dedicated staff brings together policy, promotion, and financial expertise. Our mission is to create a prosperous future for all by delivering our priority outcomes. We recognise that the risk of modern slavery occurs in the supply chains for goods and services across the world. We know that by its very nature it is hard to detect. As a ministerial department, DIT is committed to furthering the objectives of HM Government to eradicate modern slavery across supply chains.
This is DIT’s first modern slavery statement. It outlines the work carried out across 3 primary areas. Firstly, increasing understanding of the practices of modern slavery and how and when it can occur. Secondly, analysing our procurement portfolio and identifying where the risks are highest. Thirdly, building the capability required to progress work to reduce modern slavery risks across supply chains. It highlights where we have taken action to protect workers at highest risk and sets out our goals for the forthcoming year too.
Throughout 2020 to 2021, DIT focused on laying solid foundations for a multi-year modern slavery programme. Our commercial function, which is responsible for procurement, embedded Chartered Institute of Procurement and Supply (CIPS) ethical procurement e-learning[footnote 1] within the commercial training package. This was made mandatory for all commercial staff. Modern slavery and social value policies were reviewed, and processes defined, particularly around risk identification and mitigation. A comprehensive risk identification process was developed and undertaken across all in scope contracts.[footnote 2] This provided an understanding of risk and will enable prioritisation of activity to those areas where it will have the most impact. External engagement, both across and outside of government, facilitated shared learning and best practice. DIT took clear action to protect vulnerable workers across DIT contracts operating in high-risk sectors.[footnote 3]
DIT had over 100 suppliers operating across national and global supply chains in the reporting period. Initial work, outlined in section 3 of this statement, shows that there is a low risk of modern slavery occurring across most of this portfolio. Despite this, we recognise that uncovering and eradicating modern slavery takes sustained effort over time and have set ambitious goals to drive forward our work. These can be found at the end of this statement.
DIT will publish a modern slavery statement annually, reporting on progress and setting out where improvement can be made year on year.
This statement covers the reporting period from 1 April 2020 to 31 March 2021. Facts, figures, and activity detailed are taken from this period. The department’s structure and strategic priorities evolved through this reporting year, and this is reflected in the sections below.
DIT’s vision is to create a fair and open global trading environment that supports jobs and higher wages, raises living standards and lifts people out of poverty. We promote the United Kingdom across the world as a great place to do business, helping to level up the economy by attracting inward investment to all parts of the United Kingdom. We support exporters to maximise opportunities too, by opening up new markets and trading partnerships for UK businesses.
DIT has published an Outcome Delivery Plan for 2021 to 2022. This sets out an ambitious set of trade and investment objectives for the current year focused on achieving 4 priority outcomes.
The priorities are to:
Throughout 2020 to 2021 DIT employed 4,428 FTE staff. Further details and breakdown of this figure can be found in DIT’s annual report and accounts 2020 to 2021.
DIT is led by our Secretary of State.
The departmental structure for most of the 2020 to 2021 reporting year was:
Towards the end of 2020 to 2021, DIT introduced some changes to its operating structure to fully align with the new Outcome Delivery Plan for 2021 to 2022. Four new Director-General led groups were established, each responsible for the delivery of a priority outcome. They have replaced the TPG and GTI groups which no longer exist within our new structure.
The 4 new groups are:
These 4 new groups will continue to work alongside ‘UK Export Finance’ (UKEF) and the department’s corporate functions. Further details on DIT’s structure and strategic objectives can be found in DIT’s annual report and accounts 2020 to 2021.
DIT works closely with UKEF, the United Kingdom’s export credit agency. This is a separate government department but reports to the Secretary of State for International Trade, and is strategically and operationally aligned with DIT. UKEF have produced their own modern slavery statement. As DIT provides procurement services to UKEF via memorandum of understanding (MOU), DIT have provided UKEF with relevant information and data for their statement.
DIT overseas staff operate across 9 regions and are led by Her Majesty’s Trade Commissioners (HMTCs).
A proportion of DIT’s departmental spend is for procurement undertaken on the department’s behalf by third parties within HM Government. This procurement is governed by the modern slavery policies and processes implemented within those organisations.
These areas of spend include but are not limited to:
DIT categorises contracts based on the Cabinet Office contract tiering tool.[footnote 4] Gold tier contracts represent our most complex and/ or high value contracts, through a descending scale to silver and bronze tier contracts. The table below shows a breakdown of DIT contracts for 2020 to 2021.[footnote 5]
Figure 3 shows the location of DIT’s tier 1 supply chain.
DIT is in the early stages of tier 2 supply chain mapping. We have identified that a small proportion of our tier 2 supply chain operate in high-risk areas. Supply chain mapping forms part of DIT’s objectives for the next phase of our work on modern slavery as outlined in the next section.
DIT recognises that gaps remain in our knowledge of the lower tiers of our supply chain. In the year ahead, we will include terms in our standard contracts that will oblige tier one suppliers to provide supply chain maps for all contracts identified as high risk. This will be supported by new processes that will regularly gather this data from suppliers enabling us to have greater insight into our global supply chains.
DIT has appointed the Department’s Commercial Director as our Anti-Slavery Advocate. They will be responsible for developing and promoting policies and programmes to address modern slavery in commercial activity, alongside wider cross departmental engagement. In addition, there are individuals across the commercial directorate with responsibilities to tackle modern slavery. This includes through internal governance processes, reporting, future planning, and attendance at the Modern Slavery Procurement and Implementation Group (MSPIG).[footnote 7]
DIT follows and adheres to cross government policies, as listed in the HM Government modern slavery statement (pages 7 to 9). All departments have been directed to carry out actions in accordance with the Modern Slavery Public Procurement Note (PPN 05/19) and associated public procurement guidance. Within the department, we have taken steps to implement the policy and put in place the processes and the training to support this.
In addition, DIT’s commercial team utilises the bi-monthly Contract Management Transformation Board (CMTB) to engage department wide directors on all aspects of commercial policy. This includes the modern slavery agenda, internal risk identification and any further processes to be followed. This board includes the Commercial Director, the Commercial Deputy Director responsible for procurement and directors from all areas of critical spend across the department (DIT’s gold contracts).
DIT’s modern slavery policy outlines the processes that staff must follow to implement this policy. Commercial staff, responsible for procurement across the department, must undertake an internal modern slavery risk assessment for all procurements over £10,000 in value. This will determine the level of modern slavery risk that each contract is exposed to and will identify where further action may be necessary. Future actions in 2021 to 2022 will include mandated supplier completion of the HM Government approved Modern Slavery Assessment Tool (MSAT) for any contracts assessed as medium/high risk. This will be supported by the inclusion of contractual measures and targeted key performance indicators (KPIs) where appropriate. Managing and monitoring of these contracts takes place across the wider department, with ongoing support and guidance provided by DIT commercial.
In 2021 to 2022 DIT commercial will introduce a workstream focused on embedding awareness and implementation of all commercial policies across appropriate stakeholder groups. This is in alignment with the new Commercial Continuous Improvement Assessment Framework (CCIAF) Standard 8. Whilst this new standard does not explicitly reference modern slavery, it will underpin our activity in this area. This activity will include using established channels to drive awareness of this important agenda across the department. These channels include our regular grant manager and contract manager fora, our departmental intranet, and our CMTB referenced above. We also have an action to improve our internal reporting suite to identify any areas that may need strengthened support.
DIT Commercial’s Sponsorship Centre of Expertise has established a standard sponsorship contract template and due diligence policy for the engagement of sponsors in DIT and across HM Government. The team are developing a framework to address modern slavery within this policy. This policy is particularly important in Value in Kind (VIK) sponsorships where goods and services are offered in lieu of financial investment. There is potential for greater risk of modern slavery policy infringement in these agreements, and this will be addressed in the policy.
More trade need not come at the expense of our values. The United Kingdom is committed to working with international partners and businesses to tackle modern slavery in global supply chains. DIT continues to work closely across government to consider how we can best shape future trade policy and make sure the exploitation and abuse of workers is prevented.
HM Government is committed to ending modern slavery, forced labour and human trafficking worldwide by 2030, as unanimously adopted in the UN Global Goals for Sustainable Development (UNGSD). DIT contributes to this agenda through multilateral fora.
DIT has taken a systematic and proportionate approach to determining modern slavery risk across our portfolio. Internal risk assessments, based on PN 05/19, have been carried out across existing and new contracts. Existing contracts due to expire in the short term were not included in this activity, as DIT would have little opportunity to influence contracts in this stage. This work has enabled us to gain a robust understanding of the risk across our portfolio. This will be an important enabler in phase 2 of our work, which will focus on those areas where we can have most impact to reduce modern slavery practices.
Tracking of risk assessment outcomes is mandatory in DIT’s procurement platform and reported to the senior governance forum for contract management (CMTB). DIT included contracts procured through Crown Commercial Services (CCS) frameworks in this exercise, with outcomes detailed in the tables below. We have engaged with CCS to gain an understanding of their modern slavery governance and processes and DIT’s responsibility as the end contractor of these services. We will build this into our future activity.
In 2021 to 2022 the DIT commercial team will support suppliers and contract managers to implement the next step in the Department’s efforts to tackle modern slavery. This will ensure that the modern slavery assessment tool (MSAT) is completed within 60 days for all new contracts rating as high or medium risk (in line with DIT policy). Appropriate actions will then be agreed, implemented, monitored, and managed to reduce the risk of modern slavery occurring in the supply chains of these contracts. We recognise that many existing DIT contracts will not have specific anti-slavery action plans in place. Commercial staff will work with these suppliers to influence good practice across these contracts where possible, and in line with ongoing contract longevity.
Internal risk assessment of new DIT procurement activity (non-CCS) identified one medium risk contract. It also identified 5 high risk and 7 medium risk existing contracts. Though mitigated, initial review of these outcomes shows that the potential for highest direct risk related to DIT’s involvement in Dubai Expo. These contracts predate the introduction of our modern slavery policy. However, our previous engagement on this agenda, coupled with our work with Dubai Expo on workers’ welfare, ensured that modern slavery risks were considered and addressed in contracts where necessary. We welcome the support of the Emirati ministries in tacking this issue too. One such example can be found in the case study in section 3.
We recognise there is a medium risk relating to some contracts that DIT operates internationally. DIT will undertake work to support suppliers, where appropriate, to undertake a more detailed modern slavery assessment and consider further action.
We will strengthen focus on the impact of potential non-compliance with commercial policy aligned to the new CCIAF standard 8. In addition, we will identify and monitor actions relating to modern slavery and the non-delivery of HM Government’s intended outcomes in this area. This will increase the governance and visibility of this crucial policy area, ensuring regular reporting to the DIT commercial senior leadership team.
A mandatory reporting field for internal risk assessment outcomes is included in DIT’s e-sourcing tool. This allows for regular review, monitoring and reporting to senior leaders on the modern slavery risks in our supply chain.
Where risk mitigation measures are built into contract terms, these will be monitored and managed in the wider business by contract managers. These will be reported back through senior level assurance channels including through the CMTB for review, learning, and decision on further action to be taken.
Our procurement activity with Dubai Expo was identified as having the potential for risk at an early stage. In addition to the departmental governance and monitoring processes outlined above, DIT have engaged independent consultants to carry out regular audits and assessments on all aspects of workers’ welfare across this project. We also have an experienced operations and security lead overseeing the project. They have been based on site at crucial stages to ensure that the workers’ welfare standards set by DIT are maintained. DIT commercial will utilise the learning from this project to inform future work on monitoring and managing modern slavery risk across our supply chains.
As of 1 January 2021, social value is now considered in all DIT procurements above the threshold mandated in PPN 06/20. This will be supported by the inclusion of mandatory reporting fields on our e-sourcing tool, to monitor trends and performance across the social value themes and outcomes that are implemented.
DIT recognises the relationship between responsible payment practices and the mitigation of modern slavery risks occurring across the supply chain. The department is committed to the implementation of responsible purchasing practices across its commercial portfolio. This is demonstrated by consistently high-levels of prompt payment to the direct supply chain. We have also embedded prompt payment practices across the procurement life cycle in line with PPN 07/20.
The United Kingdom is participating in the next World Expo in Dubai, from 1 October 2021 to 31 March 2022, with the theme ‘Innovating for a Shared Future.’ With expertise in major world events, DIT has a specialist team managing procurement for Dubai Expo.
DIT has worked closely with the team at Dubai Expo to ensure that the steps and processes stipulated by Dubai Expo to highlight workers’ welfare risks have been considered. These have been embedded, both within the early stages of the procurement process, and across the management of the project to build our pavilion.
Elements we have incorporated include:
A robust workers’ welfare audit was embedded in the pre-qualification stage which focused on contractual terms, payment practices, accommodation standards and working conditions. Short term, 4-weekly follow-up audits are stipulated within this regime.
DIT recruited an experienced health, safety, and security lead early in the process. Having this appointee based on site at critical points throughout the project, working directly with suppliers and partners, brought an increased level of oversight to the project. That became critical as the coronavirus (COVID-19) pandemic unfolded across the globe.
DIT appointed a risk consultancy to manage a thorough 6-monthly audit regime covering all aspects of workers’ welfare, including:
Suppliers who fail an audit have a short timeframe in which to respond with mitigating measures. Audits will occur throughout the life of the project and will include exit audits to ensure that workers’ welfare standards, including prompt payment, are upheld throughout.
Prime contractors are required to explain how they operate across their supply chains and carry out regular audits of these. That is in addition to the DIT led audits outlined above.
In addition to the audit schedule outlined above, all contractors must deliver on a schedule of weekly reporting, directly to the Workers’ Welfare Lead. They in turn report back to DIT commercial’s Head of Procurements and Contracts for Expo 2020 Dubai. The Head of Procurements and Contracts is responsible for monthly reporting on strategic risks to senior, cross department governance bodies.
The implementation of these measures has had a positive impact on workers’ welfare across our pavilion. For example, the robust procurement process has led to DIT working with a supplier who has workers’ welfare embedded as a priority requirement for their operations. This company have appointed a focused Workers’ Welfare Manager responsible for governance, reporting and ongoing management of their lower tier supply chain on the project.
Adverse weather was a major concern for workers’ welfare in the region, and forced delays to the project schedule due to the COVID-19 pandemic elevated this issue. The supplier in question developed and implemented a heat stress management plan to mitigate risk and manage this issue. A vital aspect of this plan is designated role related responsibilities for preventing and managing heat stress. It also sets out clear processes for ongoing risk assessment of both job related and environmental heat stress. Another important element is easy to understand, visible communications across all areas where employees work and live.
DIT aligns closely with the HM Government approach to work with suppliers to improve workers’ welfare, rather than introducing punitive measures that could drive these practices further underground. As part of our contract management process we do not immediately terminate contracts when concerns are raised. Instead we work with suppliers to raise conditions and improve outcomes for workers on the department’s contracts. DIT has worked with suppliers to improve the terms and conditions on staff contracts, develop supplier action plans and incorporate KPIs to measure improvement against workers’ welfare issues. This approach has led to ongoing improvement against the targets set.
Having a Workers’ Welfare Lead on site as the COVID-19 pandemic spread to the region had an immediate impact for the ongoing welfare of workers on our pavilion. With experience in health and safety management, the Worker’s Welfare Lead recognised the health and safety implications for our pavilion workforce from the pandemic. They worked with suppliers and the Dubai Expo team and instructed the appointed risk consultancy to carry out gap analysis and implement ongoing COVID audits at speed. This ensured the ongoing health and wellbeing of workers involved in the project to build our pavilion at Expo 2020 Dubai.
DIT commercial works actively to engage across government modern slavery networks. We recognise that we are in the initial stages of our work in this area. We recognise the importance of engaging with, and learning from, wider best practice to further the aim of eradicating modern slavery from our global supply chains. In addition, one of our tier 1 suppliers in the Expo 2020 Dubai project is a member of a supplier health and safety network, which encompasses workers’ welfare. All learning and insight from our engagement will be channelled into our ongoing work on modern slavery.
DIT commercial’s Sponsorship Centre of Expertise has embedded tackling modern slavery in its due diligence process. This has been useful, such as when contracting Majid Al Futtaim (MAF), the large UAE based trading company, as our Official Hotel Partner for Dubai Expo. This Value in Kind partnership will deliver 2,000 hotel rooms to the project, and due diligence showed a low risk of modern slavery practices occurring through this agreement. Highlighting the need to tackle modern slavery risk early in the sponsorship process has helped raise awareness of these practices with suppliers and across the team.
Focused training was delivered to the DIT commercial team as part of the modern slavery policy launch in autumn 2020, using the CIPS ethical procurement e-learning and test. This was an important element of our phase one activity. It ensured that all commercial and procurement staff understood the importance of the modern slavery agenda, where this can occur and their responsibilities in minimising these risks. This is now a mandatory training module for all commercial and procurement staff. Currently, 95% of DIT commercial staff have completed this module.[footnote 8] HM Government has now identified this as a best practice training tool for government commercial staff on modern slavery.
DIT Commercial has revised the department’s modern slavery policy, ensuring that it is clear, easy to understand and available for all commercial staff. Central policy team leads are available and regularly engaging with commercial leads to provide support and guidance on all aspects of modern slavery. This ongoing activity has helped prepare the department for the implementation of the next phase of our work.
In addition to the above approach to training, we have increased understanding of the range of modern slavery activity, processes and outcomes within our central commercial support functions. These include commercial policy and commercial capability. This expertise will support phase 2 of our activity, which will include increased focus on skills development for colleagues working on high and medium risk contracts. This will then be applied across the wider DIT portfolio.
We will further enhance this in 2021 to 2022 and will extend this offering to senior responsible owners (SROs) and contract managers assigned to tiered contracts.
Our Head of Policy and Commercial Capability has collaborated on the Cabinet Office led Contract Management Capability Programme (CMCP) e-learning. Specifically, they have contributed to the development of content on modern slavery and worked to ensure its inclusion in the next release of this e-learning. This will have a positive impact for both DIT and wider government in efforts to tackle and eradicate modern slavery from supply chains.
As outlined previously we have leveraged the cross departmental platform, CMTB, to educate directors operating across areas of critical spend on modern slavery policy. This secures their support for our work to build the capability required to deliver on our objectives to reduce the risk of modern slavery across our supply chains.
DIT has taken a phased approach in our work to tackle modern slavery across our supply chains. Work throughout 2020 to 2021 focused on raising awareness and building understanding of the risks of these practices occurring. Activity was focused around 3 main objectives, all of which were achieved.
These objectives were:
Our phase one activity indicated that the risk of modern slavery in much of our procurement activity and pipeline is low. We will build upon and learn from this in the next phase of our work. Our activity for 2021 to 2022 will be focused on the following KPIs and goals:
To drive the completion of MSAT within 60 days for 100% of new, in scope procurements (over £10,000) found to be of medium or high risk of modern slavery.
To include terms in our standard contracts to oblige all tier one suppliers, for those new contracts identified as high risk, to provide supply chain maps within 6 months of contract award, where appropriate.
To maintain completion of the CIPS ethical procurement e-learning (or recommended equivalent) at a minimum of 90%.
To extend our modern slavery awareness offering to all DIT Contract Managers and SROs for gold, silver, and bronze tiered contracts.
To establish regular contract management fora (by Autumn 2021). This will support the education and skills of contract managers as we seek to improve DIT’s work with our supply chain in this area.
To implement a strengthened assurance and reporting framework, based on continuous improvement of our usage of systems and data, by 31 March 2022. This framework will underpin all our work and progress on modern slavery
To refresh our modern slavery policy and training for all commercial staff and ensure that this is part of the commercial team induction process.
DIT’s aims and objectives for financial year 2021 to 2022 are:
This statement was approved by DIT’s executive committee, 1 September 2021, and by Minster Jayawardena, 5 October 2021.
Signed: 1 September 2021
James Bowler, Permanent Secretary for the Department of International Trade
CIPS is the global, independent organisation supporting the procurement and supply chain profession. ↩
In-scope contracts include all new DIT contracts over £10,000 in value, and any existing DIT contracts over £10,000 in value with a contract life of 6 months or more. ↩
Case Study Section 3: Dubai Expo 2020 – Setting the standard for workers welfare in global events. ↩
Cabinet Office tiering criteria refers to all contracts with a value over £100,000. ↩
Figures are from the data contained in the DIT Commercial’s eSourcing platform ↩
This is where the supplier is registered. Tier 1 are primary suppliers with whom DIT engages directly. Tier 2 are sub-contractors and suppliers whom the primary supplier engages with for the purpose of contract delivery. ↩
This cross-government group meets regularly to consult on HM Government’s strategy and policies to address modern slavery risks in commercial spend and co-ordinate activity. ↩
DIT commercial staff must complete within one month of joining the commercial team. This figure reflects the percentage of new starters who joined the team in March 2021. ↩
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