Modern slavery statement
Modern slavery and human trafficking annual statement, financial year 2023 to 2024
Our modern slavery and human trafficking statement, financial year 2023 to 2024
This statement is made on behalf of Nuclear Waste Services (NWS) pursuant to section 54(1) of the Modern Slavery Act 2015. The Modern Slavery Act (MSA) requires any organisation with a global turnover of £36 million or above and that is operating in the United Kingdom to produce an annual statement.
In alignment with Nuclear Waste Services becoming a single legal entity on 1 April 2024 we have consolidated the LLW Repository Ltd (LLWR) and Radioactive Waste Management’s (RWM) statements to form one harmonised statement which sets out our NWS approach. We are committed to preventing modern slavery and human trafficking in any part of our business or supply chain; we will take sustained and concerted action against such acts.
In addition, as an employer, NWS is committed to Equality, Diversity & Inclusion and we aim to create and ensure a respectful and non-discriminatory working environment for our staff. We want all our employees to feel confident that they can expose wrongdoing without any risk to themselves.
This statement offers NWS the opportunity to report on progress of activities previously identified alongside planned next steps, it also describes NWS’ business and supply chain along with the systems in place to identify and manage potential modern slavery risks related to its business.
This statement is reviewed and approved by the NWS Board of Directors prior to publishing.
Our business
Nuclear Waste Services (Company Registration No 5608448), registered office is at Pelham House, Pelham Drive, Calderbridge, Cumbria CA20 1DB.
We have integrated the expertise of LLWR, RWM and the Nuclear Decommissioning Authority (NDA) group’s Integrated Waste Management Programme (IWMP). This creates an organisation focused on the management of the UK’s nuclear waste, safely and securely for generations to come.
We are part of the NDA group, which is undertaking one of the largest nuclear decommissioning and remediation programmes in Europe over many decades. Nuclear Waste Services is integral to this environmental clean-up mission, as we work to provide safe, secure, and permanent solutions to the UK’s nuclear legacy.
Our supply chain
NWS’ priority is to develop a supply chain which works with us in the delivery of safe, sustainable nuclear waste solutions which provide value for money for the UK taxpayer throughout the commercial lifecycle.
Our supply chains include large multinational organisations, publicly owned bodies and universities as well as a range of small and medium sized suppliers. In line with the government’s SME agenda, we remove barriers for Small and Medium-sized Enterprises (SMEs) and boost SME participation in our contracts wherever possible.
Our supply chain currently provides site programmes and operations, waste management services, professional and business services.
NWS takes a proactive approach to combatting modern slavery and human trafficking risks that arise in the sectors in which we operate. This is reflected in our plans below through the development of risk assessment tools to identify future procurements that may be high-risk in relation to any form of slavery or human trafficking and the creation of toolkits to equip staff to manage these risks.
Our policies and guides relating to modern slavery
NWS operates the following policies and training in support of preventing modern slavery and human trafficking.
Modern Slavery and Human Trafficking Policy
NWS commits to engaging with internal and external stakeholders to highlight the risk of modern slavery in our operations and supply chain and the prevention, detection and reporting of modern slavery in any part of our organisation or supply chain. The policy outlines that we must provide a clear means by which stakeholders can flag concerns or activities that might lead to, or suggest, an occurrence of modern slavery or human trafficking. Concerns can be raised either directly or by using our Safecall service to the NDA Group Ethics and Compliance team, this is a free, safe 24/7 service.
Whistleblowing Policy
Our modern slavery statement also aligns to our whistleblowing and grievance policies which provide a reporting method for our staff and others to alert us to any concerns they may have in relation to modern slavery.
Code of conduct
Our commitment is further reinforced through our code of conduct which is issued as part of the NWS Standards and Expectations Handbook, it reinforces NWS’ expectation that individuals report all observations and abnormal events.
NDA Supply Chain Charter
NWS will be aligned to the Charter for Nuclear Decommissioning Sites to reflect the transition to Nuclear Waste Services. The Charter includes a clear commitment to prohibit, and drive to eliminate, any modern slavery found in the supply chain.
Modern Slavery Training
Government Commercial College modern slavery awareness training is mandatory for all members of NWS commercial, which has been implemented since becoming a single legal entity. Whilst we closely monitor adherence to this requirement, commercial staff attrition (starters and leavers) has impacted our ability to achieve 100% over the full financial year. This is being proactively managed and this mandatory training will be completed at the earliest opportunity.
| Financial Year | Commercial Completed |
|---|---|
| 2023 to 2024 | 86% |
Figure 1: Mandatory Training Completed
Due diligence processes
To fulfil the commitments made within our policies, NWS operates the following business processes.
Internal focus
NWS are working to complete the Annual Information Check which requires all personnel to confirm that they have read specific policies within the last 12 months. These policies include the Whistleblowing Policy, which defines the mechanism for reporting serious concerns regarding potential policy breaches, including Modern Slavery.
As stated above, we also monitor completion of mandatory training for the NWS Commercial team.
External focus
Pre-contract Procurement and Purchasing
- NWS has adapted the Modern Slavery Assessment Tool (MSAT), recommended by the Government’s Modern Slavery Act 2015, to make an initial assessment of our supply chains’ compliance with modern slavery and human trafficking legislation.
- For contracts that score as medium or high risk for modern slavery, we have also developed a set of Supplier Audit Questions (SAQs), that the supplier will then need to complete. This is a self-assessed set of questions that requires proof of compliance. Both documents and the relevant processes are embedded into the Intelligent Client Toolkit procedure.
- The risk of slavery and human trafficking is considered when appointing and registering every new supplier. Suppliers must demonstrate they have appropriate policies and procedures in place and provide safe working conditions, treat workers with dignity and respect and act ethically in their use of labour.
- Supplier onboarding includes review of the latest reports from external rating agencies, including Dun & Bradstreet. Concerns or risks identified at this stage are escalated to senior management for further action where applicable.
Post-contract Delivery and Management
- Inclusive of Modern Slavery policy and procedures, any commitments and requirements agreed at procurement stage must be maintained for the duration of the contract. Contract Leads will define the requirements associated with quality assurance within the contract management plan, which will be utilised, reviewed and revised throughout the duration of the contract as applicable.
- Where planned as part of the contract management plan or required as part of risk mitigation, NWS will visit supplier premises and assess working conditions and practices as part of mobilisation and assurance activities. We also work collaboratively with the NDA who are also able to conduct modern slavery audits on suppliers if necessary.
- Any serious concerns, observed violations, investigations or alleged offences in connection with slavery of human trafficking would be raised within NWS’ event reporting system and shared across the NDA Group.
- We conduct horizon scanning on our suppliers which captures any potential modern slavery concerns. In addition, as part of our ongoing monitoring of our critical suppliers and work to map our entire supply chain beginning with tier 1, we will create alerts relating to any modern slavery risks in order to identify areas of concern which require further investigation.
Key goals and key performance indicators (KPIs)
This year a compliance check has been conducted on our supply chain. We will continue to check this on an annual basis to monitor any changes in compliance.
| Financial Year | Top 80% Spend Number of Suppliers | Suppliers Qualified To Publish a Modern Slavery Statement | Qualified Suppliers That Have Published a Modern Slavery Statement |
|---|---|---|---|
| 2023 to 2024 | 24 | 12 | 100% |
Figure 2: Top 80% Of Supplier Spend: Modern Slavery Statement Publication Check
Our effectiveness in combating slavery and human trafficking
Currently identification and assessment of risks or potential occurrences of modern slavery and human trafficking are covered as part of our general supply chain management and monitoring activities. As part of these activities, during financial year 2023/2024, NWS identified no evidence of modern slavery.
| Financial Year | Incidences |
|---|---|
| 2023 to 2024 | 0 |
Figure 3: Number Of Modern Slavery Incidents
Further steps planned for financial year 2024 to 2025
As NWS progresses with mapping our Supply Chain we will consider the potential risks with regards to Modern Slavery and ensure these considerations are included within our commercial management processes. We will target the mapping of categories where we feel the most risk lies and seek to include additional assurance activities where deemed appropriate, identifying and utilising key stakeholders.
NWS Commercial has engaged in an analysis of the processes and procedures currently utilised across the organisation. We aim to use these findings to provide a harmonised process, bringing best in class elements of the processes currently employed to demonstrate a cohesive, robust approach to our compliance with Modern Slavery legislation.
We will continue to provide mandatory training programmes to our employees as well as in house education on implementing corrective plans with our suppliers if necessary. We also aim to extend modern slavery training beyond the commercial function to give a heightened awareness throughout the entire organisation.
The Procurement Act 2023 has also extended the type of offences covered by the mandatory exclusion ground based on the Modern Slavery Act 2015. The entire NWS commercial function must complete the new procurement act training before it is implemented. This mandatory training will ensure these considerations are appropriately addressed.
We are confident that the actions NWS are taking are effective and appropriate to meet our commitments in preventing modern slavery and human trafficking in our business.
Signed:
Steve Glasson, Commercial Director