Modern slavery statement

This first Modern Slavery Statement sets out steps DWP has taken to understand where slavery could occur in its supply chains and actions to mitigate and manage this, to help ensure that taxpayers’ money does not inadvertently fund this cruel and criminal activity.

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Department
for Work &
Pensions

Foreword

Modern slavery is an abhorrent criminal practice that treats men, women and children as nothing more than commodities for exploitation, often by organised criminal gangs. While I am sure we all like to think that slavery happens in other, faraway, perhaps more deprived countries, the sad fact is that modern slavery is far more prevalent than that and exists within most modern global supply chains, including sadly here in the UK.

Improving people’s lives is at the heart of what we do in the Department for Work and Pensions and we therefore have zero tolerance to modern slavery. Evidence tells us that there are around 40 million global victims of modern slavery and DWP is fully committed to the government’s objective to eradicate slavery and human trafficking wherever it exists.

We have already embedded Cabinet Office policies for Tackling Modern Slavery and the inclusion of Social Value within our processes, and by continuing to take proactive action to identify and address the risk of slavery and using the reach and influence of our contracts we are committed to the elimination of the risk of slavery in our supply chains. This statement sets out steps we have taken to ensure we understand where the risk of slavery could occur and actions we are taking to mitigate and manage those risks and ensure that taxpayers’ money does not inadvertently fund this cruel and criminal activity.

Eliminating modern slavery will take time and we are at the beginning of our journey, but the steps we’ve taken including a strong focus on training and raising awareness will continue, with further goals developed as our experience evolves. These are the solid foundations we have built to start to tackle slavery and make a real difference to people’s lives through our contracts and protect vulnerable workers anywhere in our supply chains from exploitation or harm.

This, our maiden Modern Slavery Statement, not only describes the steps we have already taken but also the areas upon which we will focus in our ambitious future goals to eradicate modern slavery from our supply chains, and will be updated annually both to share our progress as well as outline how our approach will develop in the future.

The work we are undertaking to tackle modern slavery in our supply chains embodies our overriding mission in DWP: to improve people’s quality of life and the things that really matter to people, today, every day – to make someone’s tomorrow better than their yesterday.

The Rt. Hon Thérèse Coffey MP
Secretary of State for Work and Pensions

Baroness Stedman-Scott
Parliamentary Under-Secretary of State for Work and Pensions (in the Lords)

Peter Schofield CB
Permanent Secretary

Executive summary

The Department for Work and Pensions (DWP) mission is to improve people’s quality of life, both now and in the future. We do that by focussing on delivering excellent services that make a difference to millions of people’s everyday lives, thinking of our citizens we serve directly and taxpayers. Our inherent mission is incompatible with the misery caused by modern slavery and we will use the power of our contracts to examine where slavery could happen in our supply chains and take steps to eradicate, reinforcing the DWP aim to make someone’s tomorrow better than their yesterday.

DWP is fully committed to supporting the governments objectives to eradicate modern slavery and human trafficking and we are taking steps to identify and mitigate the risk in our supply chains of goods and services, to protect vulnerable workers from exploitation and ensuring taxpayers’ money does not inadvertently fund criminal activity.

The UK government published its first modern slavery statement in March 2020, which DWP supported and contributed to, and the joint statement committed all government departments to publish their own annual modern slavery statements.

This statement will help explain the initial steps we have taken to prevent modern slavery in DWP supply chains, and to be transparent about the areas where we need our suppliers to improve. Tackling the risk of modern slavery is not a quick process and will require sustained commitment and effort over time. We have set ourselves challenging goals and we will report our progress in future statements and update as our strategies evolve and we learn more about the risk of modern slavery in our supply chains.

From the outset we are focusing on our most important contracts, as defined by Cabinet Office criteria, and with the support of our strategic suppliers, building on our existing relationships we will tackle modern slavery by improving transparency in our supply chain. We have invited suppliers to complete the government developed Modern Slavery Assessment Tool (MSAT) which is the starting point in helping understand their current approach to mitigating risks of slavery and will form the basis for identifying actions required in improvement plans. This approach will be expanded to other contracts in the coming year.

We are also incorporating risk assessments into new procurements to enable us to understand where there might be high risks at the outset and ensure we can monitor and reduce the risk of slavery occurring. We will continuously review and improve our policies and process guidance with input from stakeholders across DWP, suppliers, central government and other external stakeholders. This will help us shape our future strategy and prioritise our approach, helping identify where we should focus on more detailed mapping of the supply chain or address specific high risk criteria.

Training has been and will continue to be a key focus for both commercial staff and stakeholders, promoting wider social value and modern slavery awareness.

DWP are members of both the cross government Anti-Slavery Advocate network and Modern Slavery Procurement Implementation Group, sharing best practice and collaborating with other departments to present a joined up approach to suppliers.

Section 1 – Organisation structure, commercials and supply chains

What DWP Does

The Department for Work and Pensions (DWP) is a ministerial department, with The Secretary of State for Work and Pensions, the Rt. Hon Therese Coffey MP having overall responsibility for the Department and its arm’s length bodies (ALBs) and Peter Schofield is the DWP Permanent Secretary. Read more information about our ministers and management team.

We are responsible for welfare, pensions and child maintenance policy. As the UK’s biggest public service department we administer the State Pension and a range of working age, disability and ill health benefits to around 20 million claimants and customers, paying £220 billion each year.

We provide our services in a number of ways, for example through Jobcentre Plus, The Pension Service, the Child Maintenance Service and partner organisations.

Our overriding mission is quite simple: to improve people’s quality of life and the things that really matter to people, today, every day – to make someone’s tomorrow better than their yesterday.

To deliver this mission we have 3 underpinning strategic priorities – maximising employment and in-work progression, improving people’s quality of life and delivering excellent services for citizens and taxpayers.

Our priorities

Improving people’s quality of life

Address poverty through enabling progression into the workforce and increasing financial resilience.

Maximising employment and in-work progression

Maximise employment across the country to aid economic recovery following COVID-19.

Improve opportunities for all through work, including groups that are currently under-represented in the workforce.

Developing excellent services for citizens and taxpayers

Deliver a reliable, high-quality welfare and pensions system which customers have confidence in.

Contracts and supply chains are essential to enabling us to deliver our priorities and by adopting a zero tolerance approach and taking action to tackle the risk of modern slavery in our supply chains, our commercial function will continue to support and advance our mission while ensuring we improve quality of life for everyone.

DWP organisation facts and figures

• DWP employs circa 94,000 staff – view the workforce management information for the period 2020 to 2021
• our headquarters are in Caxton House, London and we have staff in 1,000 nationwide locations including local offices and corporate hubs distributed around the country
• read further information about DWP

Arm’s length bodies (ALBs)

Eleven ALBs and non-departmental bodies are affiliated with DWP. [Find out more information in our Outcome Delivery Plan and more information on their dedicated websites.

Reporting period

This statement covers the period 1 April 2020 to 31 March 2021.

Commercial structure and supply chains

DWP Commercial Directorate (CD), part of Finance Group, is responsible for commercial activities that support the department’s strategic objectives. CD is organised into 5 category teams providing an end-to-end category management model for each specialism, which means categories ‘own’ the procurement lifecycle from Pre-procurement, through Sourcing to In-Life Management of contracts. CD is headed up by our Chief Commercial Officer, Matthew Bradley.

Facts and figures:

• 590 contracts
• 33 strategic suppliers
• £2.45 billion spend in 2020/2021
• 285 commercial staff

Categories

The specialist category teams are Corporate Services, Digital, Employment, Estates, Health and a separate team provides commercial operational and strategic support across CD.

Resources and locations

CD has 285 staff responsible for commercial activities and based in 5 hub locations; Blackpool, Leeds, London, Manchester and Sheffield.

Spend

DWP Commercial Spend in 2020 to 2021 was approximately £2.45 billion across the 5 commercial categories.

How we buy goods and services

DWP contracts are awarded by competition between potential suppliers, unless there are compelling reasons why competition cannot be used. Routes to markets include use of Crown Commercial Service Frameworks and GCloud, in-house Frameworks, Open Competition and utilisation of other government services. DWP procurements are based on providing value for money and also include added value by inclusion of social value criteria to benefit citizens, communities and the environment which we can use to assess modern slavery risk.

CD has robust governance measures in place and all commercial vehicles with a value above £100,000 are subject to a four stage assurance process. Transactions exceeding £5m require Secretary of State and Ministerial approval and those greater than £10 million are subject to Cabinet Office Commercial Spend Controls.

In accordance with the Public Contracts Regulations, DWP aims to publish details of new contracts above £10,000 on Contracts Finder with 30 calendar days of award.

Strategic contract assurance and monitoring

DWP contracts are segmented using Cabinet Office assessment criteria to identify governments most important contracts and considers factors including value, risk and criticality of continuity of service. This assessment determines a category for the contract (Gold, Silver, or Bronze) with Gold being the most important and used to identify which assurance processes are applied during the contract management phase commensurate with the level of risk.

Gold contracts are essential for delivery of DWP’s key services therefore subject to enhanced assurance and reporting requirements. We have developed a detailed treatment strategy for the management of Gold contracts including actions to mitigate risks of modern slavery, with regular compliance checks undertaken by contract managers and assured by each Head of Category. A similar contract assurance framework is being developed for use with our Silver contracts which is due to be implemented during 2021 to 2022.

At March 2021, we had 33 Gold contracts delivered by 25 suppliers. Contract numbers can change during the year as contracts expire and activities are subject to reassessment.

Gold contract supplier locations; our Gold contract suppliers are all registered in the UK but as the Government statement advises “Over 90% of our tier 1 suppliers are registered in the UK but many of their operations and supply chains are global”. Mapping the geography of our supply chain is a key part of our future objectives.

ALBs

It is not mandatory for ALBs to be part of departmental statements but we offer awareness training to all our ALBs and two non-departmental public bodies have asked to be part of DWPs statement, the Money and Pensions Service (MaPS) and The Pensions Regulator (TPR).

MaPS and TPR will be undertaking the same actions as DWP during 21/22 including staff training, inviting strategic suppliers to complete the MSAT and completing contract risk assessments. We will continue to offer support and guidance to all our ALBs and progress will be reported in the next statement.

About TPR and MaPS

TPR has:

• 16 commercial staff
• 16 strategic contracts
• £35 million spend in 2020 to 2021

Find out more information about TPR on their website.

MaPS has:

• 11 commercial staff
• 17 strategic contracts
• £150 million spend in 2020 to 2021

Find out more information about MaPS on their website.

Section 2 – Policies in relation to modern slavery

Government policy and Implementation

In September 2019, the Cabinet Office published guidance for Tackling Modern Slavery in Government Supply Chains in PPN 05/19, setting out action to help departments identify and mitigate modern slavery risks throughout the commercial life cycle, from defining contract requirements and procuring goods, to managing supplier relationships and remediation where exploitation has been uncovered.

We have used this guidance in the development of our modern slavery policy, which is described in section 3, and will continue to be reviewed and updated to reflect our progress and embed best practices. We will continue to use PPN05/19 and any further guidance published where relevant in the updates of our modern slavery guidance and our next focus on high risk areas as described in Section 3.

PPN05/19 implementation was supported by modern slavery masterclasses led by a Cabinet Office subject matter expert and subsequent activities have included awareness sessions, MSAT technical training sessions and mandatory eLearning for commercial staff.

Anti-slavery advocate

CD has appointed a senior anti-slavery advocate to develop and champion policies addressing slavery in our procurements; fostering a culture in which our commercial colleagues, and business stakeholders, understand the potential risks. The advocate also acts as the primary escalation route for our staff if there are concerns or reports of slavery and is supported by a senior commercial policy manager and an overall social responsibility policy lead. The advocate is a member of the cross-government Modern Slavery Advocate Group, supporting collaboration on policy development and awareness opportunities with senior representatives from other departments.

As part of our social responsibility strategy we aim to build a forum of champions by March 2022 to further promote anti-slavery activities within the categories.

Modern slavery is a sickening practice that frequently impacts upon and exploits the most vulnerable in our society and around the world. Only by working closely with our peers in government, the private sector and our supply chain in a unified effort will we be able to take real steps towards eliminating the damage modern slavery does.

This is only the start of our journey and we are committed to concrete action, particularly upskilling those in a position to identify where modern slavery may exist and will continue to take and report on the actions we take towards addressing this evil practice.

Shaun Evans - Modern Slavery Advocate

Other policies that we use to support anti-slavery measures include:

Prompt Payment

DWP is committed to the government’s prompt payment policy and aim to pay our own undisputed, valid invoices within 30 days and 90% of undisputed, valid invoices from SMEs within 5 days. We publish our payment performance data. Prompt payment policy relevant to suppliers is explained in section 3.

DWP HR policies

In recruiting our own staff, DWP adheres to policies implemented across the UK government including rigorous pre-employment checks, which are relevant to the prevention of slavery in our own workforce.

Whistle blowing

DWP staff must follow the Civil Service Code but if wrongdoing has occurred, staff are encouraged to raise any concerns as soon as they notice it. We have a whistle blowing policy available to every member of staff, published on our intranet, giving clear and comprehensive guidance ensuring employees know how to raise issues of concern and are treated properly and protected from detrimental treatment when they do.

Section 3 – Risk assessments and due diligence

DWP has adopted the government developed Modern Slavery Assessment Tool (MSAT) to gain more transparency in our supply chains and help reduce the risk of modern slavery occurring. Suppliers are scored based on their responses to the MSAT and we will use the responses to benchmark improvements over the life of the contract. We have also utilised a prioritisation tool developed by the Home Office which is based on the guidance in PPN 05/19, and used to give an indicative risk rating based on the contract provision, taking into account high risk factors identified by the International Labour Organisation (ILO) such as industry type and location of workforce.

Existing contracts

Suppliers of our most important contracts, with at least 6 months left to run at March 2021, have been asked to complete the MSAT. The results of these assessments enable the start of the journey, providing greater visibility of where risks might exist in our key supply chains and help contract managers work with their suppliers to develop and monitor improvement plans to mitigate those risks. The MSAT assessments are ongoing but for other contracts, we are taking a risk-based approach to inviting suppliers to complete the MSAT. This means the contract managers initially assessing the risk level using the prioritisation tool and PPN guidance and for High or Medium risk levels considering requesting the supplier to complete the MSAT. As our strategy evolves during 2021 to 2022 a mandated approach may be applied depending on contract strategic risk.

New procurements

Since the introduction of PPN 05/19, sourcing teams have had autonomy to risk assess at planning stage in line with the guidance and risk tool, but an incremental approach to introducing mandatory risk assessment and MSAT requirements in new procurements has been introduced during 2021 to 2022 based on a value threshold. After completing an initial risk assessment, sourcing teams can choose to include extra slavery related questions in the procurement criteria and/or include a requirement for suppliers to complete an MSAT within 90 days of the new contract start date. For high value or strategically important contracts, the expectation is the MSAT requirement will be included.

Summary MSAT findings

23 suppliers provisioning strategic contracts have been invited to complete the MSAT with the activity to invite the remaining ongoing during 2021 to 2022 as part of our Gold contract assurance management plan.

The MSAT scores supplier responses using a Red-Amber-Yellow-Green scorecard in its 6 theme areas: Governance, Policies & Procedures, Risk Assessment & Management, Due Diligence, Training, KPIs. The MSAT also gives an overall score and improvement recommendations.

Findings from the MSAT completions to date are set out below. There is insufficient data to identify trends in this first reporting year but as contract managers hold follow-up discussions with suppliers we expect to see improvement in the scores, with focus in any areas our key suppliers scored less than Green.

Summary of key findings from supplier MSAT responses

MSAT key findings included:

• number of supplier MSATs completed: 14 Pending: 9
• the majority of suppliers, 12 out of 14, completing the MSAT were assessed green overall
• no suppliers have been rated Red overall
• assessment areas identified for improvement:
  • due diligence
  • KPIs
• areas of strength identified in the assessments
• governance
• policies and procedures

Table: average scores from supplier completed MSATs at September 2021

Assessment criteria	Average score
Due diligence	63%
KPIs	76%
Risk assessment and management	79%
Training	82%
Policies and procedures	87%
Governance	94%

Plans to strengthen risk assessment process

Increasing number of contracts risk assessed during 2021/ to 2022 e.g. Silver contracts mandated or assessed High or Medium risk by contract managers.

Risk assessment level confirmed as part of our governance process for new procurements.

Risk assessments/MSAT action recorded in our eProcurement system.

Risk register to be developed to monitor MSAT outcomes to ensure follow-up actions and improvement plans completed.

Specific focus on high risk areas:

• office cleaning and service staff
• logistics
• ICT hardware

Due diligence

DWP contracts are let in accordance with the Public Contracts Regulations 2015. We have also developed an in-life contract management strategy for our most strategically important (Gold) contracts that includes ongoing assurance checks during the contract lifetime, this will be rolled out to other contracts during 2021 to 2022.

Procurements checks related to modern slavery include:

• potential suppliers must confirm if their organisation (or anybody working in it with decision making powers or control) has been convicted of child labour or human trafficking offences or any other crimes, as part of the selection process
• bidders for contracts who have been convicted of certain modern slavery offences under the Modern Slavery Act within the last 5 years must be excluded from procurements, unless they can demonstrate that they have taken measures to remedy the failures and prevent recurrence
• compliance checking that bidders obligated to, under the Modern Slavery Act (2015), have published an annual modern slavery statement on their website
• risk assessments for new procurements to identify where additional checks may be required
• assurance checks are maintained during the lifetime of Gold contracts including supplier modern slavery statement publication, personnel checks, and payment performance

Social value

New procurements in DWP include a minimum 10% social value award criteria, which support government ‘social value’ policy outcomes, including reducing modern slavery risks (where relevant to the contract as assessed jointly by our commercial experts and business leads). Successful introduction of the social value policy PPN06/20 was achieved by

• securing senior civil servant sponsorship to maintain visibility of implementation
• mandating Social Value eLearning for all commercial staff
• masterclasses offered to all staff and ALBs
• incorporating into governance process for visibility
• configuring our eProcurement system to capture social value MI and KPIs

Prompt payment

“Paying suppliers promptly and within the agreed payment terms is not only an ethical responsibility but economically beneficial for all parties and the wider economy.” - The Prompt Payment Code

Payment performance - how bidders pay their supply chains - is reviewed for all major procurements, to help avoid exploitive situations and lessen the risks of slavery in the supply chain. DWP follows government policy guidance as laid out in PPN07/20 and monitor effectiveness for Cabinet Office reporting.

For in-life contracts, DWP suppliers are required to pay undisputed invoices for supply chains provisioning the contract within 30 days and assurance checks undertaken during the life of the contract.

Section 4 – Training and awareness

To ensure a high level of understanding of the risks of modern slavery and wider social value awareness, we are committed to promoting learning by offering training and workshops to all our commercial colleagues. Training is not wholly focussed on commercial teams however, we promote learning to our wider stakeholders including ALBs and colleagues responsible for commissioning procurements and managing operational contracts by:

• completion of modern slavery eLearning; already mandated for all commercial staff, our stakeholders are encouraged to complete to help them identify any potential risks or issues
• commercial staff who are members of the Chartered Institute of Procurement and Supply (CIPS) are strongly encouraged to complete the CIPS Ethical Procurement and Supply learning module annually in addition to the eLearning
• MSAT technical training sessions led by NQC offered to all commercial staff and ALBs
• social value masterclasses led by a Cabinet Office expert offered to commercial staff, key stakeholders and ALBs
• social value eLearning mandated for all commercial staff to complete and stakeholders encouraged to complete
• modern slavery and social value eLearning incorporated into induction training for new commercial staff
• collaboration opportunities to share lessons and best practice with other government departments
• all products and training guidance readily available along with details of external products and webinars through our commercial SR SharePoint pages

Section 5 – Goals and key performance indicators

We have started our early focus on staff awareness to gain transparency and insight in our most important contracts. The next stage is about working with our suppliers and analysing MSAT results, including monitoring improvement plans and expanding the assessment approach to other contracts. Our strategy is evolving as our knowledge of our supply chains and best practice develops and future goals and KPIs will be updated or developed to reflect.

We have started to take action to identify, mitigate and mange modern slavery risks in supply chains in year 1 and KPI’s have been developed for year 2 based on this initial activity.

Key Performance Indicators (KPIs)

To measure effectives, KPIs have been developed, including staff training, action plans developed for monitoring MSAT risks and checks on supplier and DWP payment performance.

KPIs – top 2 KPIs in each category

Risk assessment and management

KPI: Risk Assessments for all new procurements above £5 million/£1 million threshold by Q4/21.

KPI: Mapping of Gold contract supplier operations complete by 31/03/22.

Due diligence processes

KPI: An MSAT will be completed for new contracts within 3 months of contract start above PCR thresholds and at medium or high risk of modern slavery.

KPI: DWP commits to the government’s prompt payment code to pay 90% of undisputed and valid invoices from SMEs within 5 days and 100% of all undisputed and valid invoices within 30 days.

Training and awareness

KPI: All commercial staff to have completed Modern Slavery eLearning by 30/11/21.

KPI: All new staff to complete Modern Slavery and Social Value eLearning within six weeks of induction.

Assurance

KPI: Gold contracts to have completed required slavery actions by 30/09/21.

KPI: Risk register of actions to be developed to show MSAT improvement plans within SR strategy 21/22

Strategic contract monitoring

Actions to monitor and mitigate risks of modern slavery are also incorporated in our gold contract management assurance programme, with compliance checks undertaken by contract managers and assured by each Head of Category.

Goals

This section provides an overview of our performance against the goals set out in the government’s Modern Slavery Statement. Some goals are completed and some will be monitored and ongoing during 2021 to 2022 and beyond as we see our Goals and KPIs as evolving.

Goal	What we’ve done
Appoint an anti-slavery advocate at director level to help oversee activity and increase awareness of action to take.	Complete Champions forum also planned as part of SR strategy during 2021 to 2022
Develop KPIs to help us understand whether the action we are taking is working well and where we need to improve	Complete Initial action complete but we expect new KPIs to be identified as our strategy evolves.
Review, and where relevant, amend procurement policies following publication of PPN 05/19.	Complete Initial action complete but we expect our strategy to be regularly reviewed and updated as our understanding evolves.
Begin or continue contract risk assessments to ensure action plans are targeted.	Underway – risk assessments underway for Gold contracts and for new procurements during 2021 to 2022. Contract management strategy including slavery related actions to be extended to other contracts during 2021 to 2022.
Invite all major suppliers in medium or high risk areas to complete the MSAT with follow up meetings to help better understand the anti-slavery activity they should be undertaking.	Underway. Some action has been taken as detailed earlier in the statement. This goal will be managed in line with KPI’s above.
Begin mapping tier 2 suppliers to identify high-risk supply chains.	Underway. The contract management assurance approach for gold contracts is currently being revised for wider use.
Participate in training (to build capacity internally) and cross Government working groups to collaborate on common interests.	Ongoing commitment to training and upskilling commercial staff, business stakeholders and ALBs including: Mandating: - Modern Slavery eLearning - Social Value eLearning Promoting: - CIPS Ethical Procurement & Supply - Awareness sessions - MSAT technical training A new internal SharePoint site providing guidance and supporting MS awareness due to launch in Autumn 21. DWP are members of the cross-government Modern Slavery Advocate Group and the MS Procurement Implementation Group.
Launch the social value in procurement model, including evaluation criteria on modern slavery.	Social Value model integrated into DWP procurement processes including: - Senior sponsor appointed - eLearning mandated - Masterclasses offered - eProcurement system configured to capture MI - New governance processes introduced

New goals include:

In 2021 to 2022 we will undertake further work to map operational locations within our supply chains for commercial activity at medium or high risk of modern slavery.

Champions Network - A network to be established within the commercial team to promote modern slavery activities in each category as part of new social responsibility strategy.

Collaboration opportunities - we plan to offer contract managers opportunities to collaborate with contract managers from other departments to share best practice.

Section 6 - Wider anti-Slavery initiatives in DWP

Addressing the risk of modern slavery goes wider than commercials and DWP is uniquely placed as a department through its contact with citizens to identify risks. An internal group, the Combatting Modern Slavery and Human Trafficking Steering Group, has been set up and CD is a key stakeholder of the group, the goals include;

• provide wider visibility of MS&HT activities x-DWP and development of an overarching policy and strategy
• to understand the interactions with OGDs, Police and National Crime Agency, local agencies, charities and other organisations in combatting MS&HT
• training e.g. role of Safeguarding Leads and training for frontline customer facing staff

This work is underway and we expect to be reporting progress and actions in our future statements.

Approvals

This statement has been approved on behalf of the Department for Work and Pensions by the DWP Chief Commercial Officer and DWP Permanent Secretary in September and October 2021 for the financial year ending 31st March 2021.

Signed:
Date: 21 September 2021

Signed by Matthew Bradley
DWP Chief Commercial Officer

Signed:
Date: 18 October 2021

Signed by Peter Schofield
DWP Permanent Secretary