Anti-slavery and human trafficking statement

Modern slavery is the illegal exploitation of people for personal or commercial gain. Victims are controlled by force, threat, coercion and deception. It can take various forms including trafficking of people, forced labour, sexual or criminal exploitation or domestic servitude.

We have published this statement in accordance with the Modern Slavery Act, 2015. The Act requires any organisation with a global annual turnover of £36million or above which operates in the United Kingdom to produce an annual statement. This should detail the steps taken during the financial year to ensure modern slavery isn’t taking place within any part of that organisation’s business or in its supply chain.

Our commitment

Modern slavery is a criminal offence and a violation of fundamental human rights. National Highways will not tolerate this, and we are committed to doing business in a responsible and sustainable way. This includes a commitment to do all that we reasonably can to prevent all forms of modern slavery in any part of our own business and our supply chain. 

We manage the strategic road network in England, comprising motorways and some A roads. We recognise that this gives us significant reach, with the potential to empower our colleagues, suppliers and customers. As such, we look to identify ways in which we can empower our operational colleagues, traffic officers and customers to identify signs and risks of modern slavery, and the routes for reporting any suspicions or evidence. 

We expect our people, customers and supply chain to share and uphold these ethical values and principles.

Reports and issues dealt with in 2023-24

We monitor and categorise concerns reported to us either via our Whistleblowing Speak Out Facility service, or any other channel. 

There were no allegations of potential modern slavery in 2023-24.

This statement describes the steps that we have taken during the year ending 31 March 2024 to prevent modern slavery and human trafficking in our organisation and our supply chain.

Our business, people and supply chain

We directly employ over 7,000 colleagues across England and support an extensive supply chain. We operate, maintain and improve England’s strategic road network - more than 4,500 miles of motorways and major A roads. Our network drives economic growth across the country, creating jobs, supporting businesses and opening areas for development. 

Our priorities

We believe that no one should be harmed when travelling or working on our roads. Everything we do focuses on improving the safety of the strategic road network, our customers’ experience, and the successful delivery of the Government’s investment programme. These underpin all we do and are supported by our company values of Safety, Ownership, Passion, Integrity and Teamwork. They describe how we treat each other, how we want to be viewed as an organisation and how we do business.

We are committed to creating and ensuring a non-discriminatory and respectful working environment for our colleagues. We want all our colleagues to feel confident that they can expose wrongdoing without any risk to themselves, and as such the company has an established whistleblowing policy which all colleagues can access alongside all other company policies on the employee intranet.

We do not enter business with any organisation which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Policies and contractual provisions

Anti-Slavery and Human Trafficking policy

This incorporates legislation and good practice principles from across the sector. The policy is published on our internal intranet for our people and is readily accessible and easy to refer to. It provides a clear statement on the definition of modern slavery (including its component parts), our commitments as an employer, our expectations of any third parties we work with, the warning signs to look out for and how to report concerns.

Whistleblowing (Raising Concerns at Work) policy

We ask anyone – our people, our supply chain, or members of the public to bring to our attention anything that looks or feels wrong (including human rights violations) taking place in National Highways. We offer an externally hosted platform that provides a confidential 24/7 reporting service by phone or email. Reports can be made to this service anonymously should the discloser feel more comfortable reporting in this manner. 

Contracts and procurement policies

These policies focus on developing a sustainable supply chain and creating lasting social value to establish a more inclusive and diverse industry. Within this our policies heighten awareness of human rights and use the insight gained to drive further change.

Our procurement contracts require suppliers to comply with the Modern Slavery Act 2015, the National Highways Anti-Slavery and Human Trafficking Policy and other relevant policies. We also require our suppliers to implement due diligence procedures for their own supply chains and use reasonable endeavours not to purchase raw materials, resources or products from organisations using forced labour.

Ownership

Responsibility for our Anti-Slavery and Human Trafficking policy and programme sits with our Commercial and Procurement Executive Director. He reports directly into our Chief Executive Officer.

Our Business Ethics Committee, chaired by our Executive Director, Human Resources and Organisational Design:

• oversees the annual anti-slavery risk assessment (through our Economic Crime Risk Assessment process)
• monitors completion of our annual anti-slavery programme of work
• agrees the anti-slavery (and associated policies) and any annual updates, prior to approval by our Executive and endorsement by our Board
• provides leadership for any investigation into any allegations of modern slavery or human trafficking

Updates are provided via our Business Ethics Committee to the company’s Audit and Risk Committee through the Corporate Assurance Director’s quarterly report.

Risk assessment and management

The possibility of modern slavery being found within our business or in any part of our supply chains is tracked as part of our Enterprise-wide Risk Management process. This is supported by our Economic Crime Risk Assessment, which assesses key areas of potential vulnerability. For any risk identified, appropriate controls and mitigations are identified, assessed and monitored regularly. 

Our people

The company makes appropriate pre-employment checks on all directly employed colleagues. Only agencies on approved frameworks are used for temporary employment and a standard requirement of these are to provide assurance that pre-employment checks are conducted.

There is a range of policies and procedures designed to protect our colleagues from poor treatment or exploitation. These comply with all relevant employment law and the Advisory, Conciliation and Arbitration Service code of practice. They include the provision of fair pay rates based on nationally negotiated terms and conditions of employment. There is also a range of benefits, including health and wellbeing support, and access to training and development opportunities.

Where changes to employment, work, organisation and policies and procedures are proposed, there is communication and negotiation with the Trade Unions, as appropriate. Efforts to engage and involve colleagues in matters which affect them include regular colleague briefings and consultation with a range of colleague networks, including but not exclusively Embrace (our race quality network) and Rainbow Roads (LGBT+).

Because of this, we believe that the risk of forced or trafficked labour being directly employed by National Highways is low.

Due diligence processes

For procurement activity for which a competitive tender process is required, we ensure that the modern slavery risk is considered throughout this process by:

• signposting our procurement teams to our guidance to help them understand if their procurement activity may be high-risk for modern slavery. This guidance aligns with the latest Tackling Modern Slavery in Government Supply Chains guidance
• using standard contract clauses across most new contracts which require suppliers/consultants to adhere to the National Highways Anti-Slavery and Human Trafficking policy in addition to the Modern Slavery Act 2015 in all its activities, and throughout its supply chain
• asking relevant questions via the Supplier Qualification process, regardless of whether modern slavery is deemed to be a high risk in the procurement of a specific product or service

While we believe that the risk of modern slavery is low, as a matter of course we ask for more information about the steps the supplier is taking to mitigate this risk at the Invitation to Tender stage. These responses provide us with confidence that the supplier is committed to tackling modern slavery within their organisation and their supply chain.

Once contracted, and particularly in cases where modern slavery is assessed to be high-level risk, we embed anti-modern slavery considerations into our post-contract supplier management process.

Through building strong working relationships with our suppliers, we're confident that they will report any concerns they may have openly and honestly to us.

Procurement and our supply chain

We believe the highest potential risk sits within our supply chain. Most of our products and services are purchased from UK or EU based firms who are also required to comply with the requirements of the UK Modern Slavery Act, 2015 or similar legislation in EU states. A significant number of products are purchased through our supply chain, whose Supplier Code of Conduct includes a provision around forced labour.

Where possible, and consistent with the Public Contracts Regulations, we build longstanding and collaborative relationships with our suppliers.

We build relationships with our strategic suppliers to ensure they comply with our values and that they are aware of our commitment to protect human rights. As part of our procurement processes, we require all our suppliers to comply with the requirements of the Modern Slavery Act and include appropriate contractual obligations within all our commercial agreements.

Training and awareness-raising activity

Over the last few years, we have built awareness of the risk of modern slavery across our business and supply chain. Advice and training on all aspects of modern slavery and human trafficking is available to colleagues through our Counter-fraud team and supported by our Anti-Slavery and Human Trafficking policy and procedure.

Our company’s anti-economic crime training and modern slavery training modules are available to all our people through our Thrive platform, and contain specific content as to what modern slavery is and what signs to look for. This training is mandatory for all Commercial and Procurement colleagues and our delivery teams are strongly advised to complete it. 

Recognising that there may be a risk where subcontracted operational colleagues are involved, we can provide additional tailored training to our operations, major projects, and commercial and procurement teams. These teams will often work alongside subcontracted, potentially temporary, labour from multiple tiers of the supply chain. Therefore, this training explains what modern slavery is, why it may be relevant to anyone working on site, the warning signs to look out for and how to report concerns.

Our Regional Delivery Programme has developed a suite of learning and monitors its supply chain, setting target objectives in each topic area, including modern slavery, as a key subject matter for supplier development.

We seek opportunities to improve our processes through sharing valuable experiences and insights with these organisations as well as our wider supply chain.

2023-24 progress

Training and raising awareness

We've developed our learning modules taking a tailored approach and reflecting changing standards, which gives our people the latest knowledge and tools to identify and manage the risk of modern slavery in our contracts and operations.

We've ensured colleagues were aware of the risks of modern slavery at the earliest opportunity so that we can identify and act on any potential risk immediately through internal comms and creation of the working group.

We're continuing to give our Commercial and Procurement people training from induction to incorporate best practice and ensure they have the tools required to identify and act on any potential risk.

We've promoted modern slavery week business wide, sharing case studies and informative workshops to increase awareness of the issue, how to spot the signs and highlighting the routes to raise potential concerns.

We've worked more closely with suppliers delivering introductory modern slavery workshops in collaboration with the Supply Chain Sustainability School to align to the most up to date legislation and to our requirements.

We've created a working group with representation throughout the business which supports in sharing knowledge and best practice to the parts of the business closest to modern slavery risk.

In collaboration with the working group we monitor progress against our modern slavery action plan taking steps to proactively address risks ensuring consistency of approach and pushing knowledge business wide.

Strategic activities

We've strengthened our relationship with Department for Transport (DfT) and strategic partners within working groups by becoming key contributors and sharing good practice.

We've updated our contractual models to reflect updated guidance and continue to review them quarterly.

We’ve begun to assure our key suppliers on their modern slavery maturity and including their compliance with latest legislation and obligations set out in our contracts.

Clarified our corporate response processes in the event of modern slavery and communicated more regularly and widely how to spot the signs of modern slavery and how to report it.

Key actions in 2024-25

Training and raising awareness

For the coming year we will:

• further drive awareness in the supply chain by reviewing and broadening the availability of our learning and policies through the Supply Chain Sustainability School platform which will give our suppliers free resources to upskill their workforce
• work with our supplier relationship management team to raise the profile of modern slavery and discuss the management of risk in their businesses
• encourage our supply chain to use the self-assessment tool on the supplier development system to help them measure their maturity and identify areas for improvement
• expand on the working group initiatives to ensure that our focus encompasses all aspects of our business to effectively navigate and mitigate risk across the organisation, fostering a comprehensive approach to combat modern slavery within our organisation

Strategic activities

For the coming year we will:

• carry out an internal assurance to give us confidence that we are doing all we can to mitigate risk and support continuous improvement across the business
• continue to work collaboratively with Government, DfT and stakeholders to share best practice and to improve our approach to modern slavery
• further develop our contractual models to meet policy and legislative requirements by introducing risk-based assessments into our procurement processes
• continue to work with our supply chain to ensure they meet the requirements that are set out in our contracts to give us confidence that they have the appropriate processes, risk management and policies in place
• develop our procurement processes for medium or high risk tenders (as per prioritisation tool) to ensure the appropriate legislative requirements to manage modern slavery risks are incorporated

Declaration

This statement refers to the financial year ending 31 March 2024 and was approved by our Board on 22 May 2024.