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.
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 (SRN) in England, comprising motorways and some A roads. We recognise that this gives us significant reach, and that we have the potential to empower our colleagues, suppliers and customers. As such, we aim to add focus on identifying 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 2022-23
We monitor and categorise concerns reported to us (either via our Whistleblowing (Raising Concerns) service, or any other channel).
There were no allegations of potential modern slavery in 2022-23.
This statement describes the steps that we have taken during the year ending 31 March 2023 to prevent modern slavery and human trafficking in our organisation and our supply chains.
Our business, people and supply chain
We directly employ over 6,600 colleagues across England and support an extensive supply chain. We operate, maintain and improve England’s strategic road network - 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.
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 staff. We want all our staff 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 staff can access alongside all other company policies on the staff 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 heightens awareness of human rights and uses 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.
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. Reporting on their effectiveness is completed by managers on a quarterly basis.
The company makes appropriate pre-employment checks on all directly employed staff. 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 staff 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 staff in matters which affect them include regular staff briefings and consultation with a range of staff networks, including Embrace (our race quality network), LGBT+ and Allies.
Because of this, we believe that the risk of forced or trafficked labour being directly employed by National Highways is low.
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 all our 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.
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
- 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
- using standard contract clauses across most new contracts which require suppliers/consultants to adhere with the National Highways anti-slavery policy in addition to the Modern Slavery Act 2015 in all its activities, and throughout its supply chain
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. Using the Home Office Modern Slavery Assessment Tool, we assure that the supplier is continuing to manage and mitigate risk effectively. Through building strong working relationships with our suppliers, we are confident that they will report any concerns they may have openly and honestly to us.
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 staff 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 LEARN 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 staff 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.
Key actions in 2022-23
This year we have improved our understanding and approach to minimising the opportunity for modern slavery to occur through completing the following:
We maintained a focus on learning and development (both within National Highways and the supply chain) by delivering a formal programme of training and awareness to staff in key commercial and operational roles. This drives a consistent and professional approach to embedding awareness of Modern Slavery risks into our business.
We have met the government standard of 90% of our commercial workforce trained in modern slavery awareness. This ensures our commercial teams have the skills and knowledge required to embed modern slavery into our commercial activities.
We used our partnership with the Supply Chain Sustainability School to share training modules and self-assessment tools with our supply chain. These provide additional toolkit for suppliers to identify risks and benchmark capability within their own organisations.
We have delivered interactive and tailored activities to empower our operational colleagues, traffic officers and stakeholders. This focused on how we identify, and report suspected or known incidents of human trafficking and modern slavery.
We have kept modern slavery visible to colleagues with regular articles and activities, using our internal communications forums. We used modern slavery awareness week to promote the topic across the business and highlight the potential warning signs and ways to report concerns.
We have benchmarked ourselves against similar organisations across and beyond our sector. The information collected from this has helped to develop our strategy and action plan for 2023-24.
Our relationship with our stakeholders within the Department for Transport (DfT) is important. Working collaboratively with the DfT Modern Slavery Group (comprising the DfT, its agencies and other arm’s-length bodies) we are promoting a culture of continuous improvement through learning and sharing best practice. This provides consistency of approach and drives a strong common message across the DfT family.
Key actions in 2023-24
For the coming year we will focus on the following:
Develop our learning modules to reflect changing standards. This will ensure our staff have the latest knowledge and tools to identify and manage the risk of modern slavery in our contracts and operations.
Further drive awareness in the supply chain by broadening the availability of our learning and policies through the Supply Chain Sustainability School platform.
Create even more opportunities to empower our operational colleagues, traffic officers and stakeholders in identifying and reporting suspected or known incidents of human trafficking and modern slavery, by raising awareness of the symptoms and highlighting how concerns can be raised.
Work with suppliers through supplier relationship management to consider and mitigate modern slavery risks while collaborating to share best practice and identify opportunities to strengthen our approach.
Embed the Modern Slavery Assessment Tool into our commercial end-to-end process models to further reinforce a consistent approach across our commercial activities.
We will continue to work collaboratively with Government, DfT and stakeholders to share best practice to improve our approach to modern slavery.
We will further develop our contractual models to meet policy and legislative requirements by introducing risk-based assessments into our procurement processes. This will provide greater assurance that our supply chain can evidence compliance.
We will continue to audit our supply chain to ensure they meet the requirements that are set out in our contract to give us confidence that they have the processes and policies in place to address Modern Slavery.
This statement refers to the financial year ending 31 March 2023 and was approved by our Board on 10 May 2023.