Corporate report

LLW Repository Ltd's Modern Slavery and Human Trafficking Statement 2019/20

Published 24 September 2020

1. Introduction

This statement is made on behalf of LLW Repository Ltd (LLWR) pursuant to section 54(1) of the Modern Slavery Act 2015. LLWR is absolutely committed to ensuring that its business and supply chains are free from slavery and human trafficking.

This statement describes LLWRs business and supply chain along with the systems in place to identify and manage potential modern slavery risks related to its business. The statement also highlights any specific risks encountered during financial year 2019-20 and sets out further steps LLWR will be taking in financial year 2020-21. This statement is reviewed and approved by the LLWR SLC Board of Directors prior to publishing.

2. Our Business

LLWR is the Site Licence Company (SLC) established to hold the Nuclear Site Licence for the Low Level Waste Repository Site (the Site) in West Cumbria. Whilst LLWR operates and manages the Site, the Site itself is owned by the Nuclear Decommissioning Authority (NDA). The Site is the UK’s principal disposal facility for Low Level Waste (“LLW”) and is the only facility that is permitted to receive all categories of low level radioactive waste.

LLWR is structured into the following primary business units:

• Site Programmes and Operations – Maintains and operates the Site, including management of all waste disposal and nuclear site operations and infrastructure. This group includes all Site based programmes and projects to manage decommissioning, legacy waste liabilities, and Site development for new vaults or disposal capability.

• Waste Management Services – Manages and delivers a portfolio of waste management services for use by LLWRs customers across the UK nuclear industry. The service delivery model is a combination of LLWR performed services and supply chain capability. Waste Management Services manage an extensive supply chain across the UK and includes access to treatment facilities in the EU.

• Business Functions – Comprises all business and technical functions that support the Programmes, Operations, and Services units. These functions include Quality, Finance, HR, Commercial and Contract Management, Science and Engineering, and Project Controls.

LLWR operates within the wider NDA Group of companies and have a range of reporting, management, service and collaboration activities undertaken as part of day-to-day business. As part of the NDA Group, LLWR regularly shares and receives business and operational learning and briefings to improve business performance. This includes any indicators or warnings of Modern Slavery and Human Trafficking.

3. Our Supply Chain

This section describes the types of works, goods and services LLWR procures, including the geographic regions where our suppliers are based. LLWR contracts with a wide range of organisations in support of delivering our business operations and services. LLWR is classed as a Contracting Authority as defined under the Public Contracting Regulations (PCRs) and must comply with the PCRs and Government procurement and contract policies. Where appropriate LLWR also adopts Government best practice for supply chain management.

The majority of LLWR’s contracts are with UK registered companies who are based and operate in the UK.

Using the business unit structure previously describe, LLWR’s supply chain can be summarised as follows:

• Site Programmes and Operations – In support of programme delivery and Site operations, a broad range of construction works and industrial goods and services are provided via a small number of higher value, longer term contracts and framework agreements. In some cases, these contracts involve a portfolio of specialist subcontractors managed by the prime contractor. The main areas of spend are on construction works, engineering and infrastructure services, and hard and soft facilities management. LLWR retains its own capability to deliver most site operations and maintenance activities.

• Waste Management Services – LLWR manages a portfolio of around 30 suppliers in the provision of waste management services to UK customers. Except for metallic waste treatment, which includes access to facilities based within the EU, all services are provided from UK facilities. The majority of goods for Waste Management Services are manufactured by British businesses in the UK. Services provided include packaging, transport, incineration, metallic waste treatment, and alternative waste disposal. The services support the application of the waste hierarchy across the UK nuclear industry and to avoid the disposal of waste and usage of limited space within the Site disposal vaults.

• Business Functions – Spend within this business area involves predominantly professional services providers. The majority of these suppliers are UK based. LLWR sources a range of IT services and some consultancy and software capability is based within the EU and India.

4. Company Policies and Procedures

LLWR operates the following policies in support of preventing modern slavery and human trafficking.

4.1 Code of conduct

The code which is issued as part of the LLWR Standards and Expectations Handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when working at home or abroad and managing its supply chain.

4.2 NDA Supply Chain Charter

LLWR is a signatory of the Charter for Nuclear Decommissioning Sites. The Charter includes a clear commitment to prohibit and drive to eliminate any modern slavery found in the supply chain.

4.3 Whistleblowing Policy

The Company encourages all its workers, customers and other business partners to report any concerns related to the LLWR or supply chain activities which may be in breach of any UK legislation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Personnel are provided with several means by which to raise concerns depending on their nature and sensitivity. For anyone involved with the business, LLWR actively promotes the raising of concerns in good faith and without fear of retaliation.

4.4 Procurement and Supply Chain Policy

LLWR commits to procuring sustainably and in a responsible manner that recognises, in a proportionate way, the social, economic and environmental impact of our supply chain expenditure. This includes consideration of the human impact of our procurement activities and how funding is spent.

Modern Slavery and Human Trafficking Policy – To highlight the importance of this risk, LLWR is drafting a standalone policy for publication and implementation during financial year 2020-21.

5. Due Diligence Processes

To fulfil the commitments made within our policies, LLWR operates the following business processes.

5.1 Internal focus

The Human Resources team conduct an Annual Information check each year which requires personnel to confirm that they have read specific policies in the last 12 months. These policies include Policy 024 – Whistleblowing, which defines the mechanism for reporting serious concerns, such as Modern Slavery.

5.2 External focus

Pre-contract Procurement and Purchasing

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 where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. Supplier appointment includes review of the latest reports from external rating agencies. These reports include details of any reported regulatory violations across the supplier’s operations. Concerns or risks identified at this stage are escalated to senior management for further attention.

LLWR works with suppliers to ensure that they meet the standards expected. However, serious concerns or observed violations against required standards would be notified to the supplier and lead to exclusion from the procurement.

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 and Quality Assurance will confirm this from time to time depending on the risk profile of the contract or if information is received that prompts inquiry.

LLWR will often visit supplier premises and assess working conditions and practices as part of mobilisation and assurance activities.

Within each higher value contract placed, LLWR requires the inclusion of Modern Slavery Act compliance contract conditions. These terms require suppliers to: • Maintain Modern Slavery Policies and Procedures; • Not engage in any activity that if conducted in the UK would constitute an offence under the Modern Slavery Act; • Notify LLWR of any investigation or alleged offence by any formal body in connection with slavery of human trafficking; and, • Implement due diligence procedures for ensuring there is no slavery or human trafficking within their own supply chain.

Any serious concerns, observed violations, investigations or alleged offences in connection with slavery of human trafficking would be raised within LLWRs event reporting system and shared across the NDA Group.

6. 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 2019/20, LLWR only had cause to investigate one potential risk within supply chain regarding an overseas manufacturer of soft-sided packaging. LLWR sought and received assurances regarding worker conditions and welfare.

7. Further Steps Planned for FY2020/2021

Following a review of our effectiveness in combating slavery and human trafficking, we intend to take the following further steps during financial year 2020/21: 1. Publish and implement a LLWR Modern Slavery and Human Trafficking Policy. 2. Provide training to key employees to raise awareness of modern slavery and human trafficking. 3. Complete a supply chain assessment of the nature and extent of our exposure to the risk of modern slavery. The assessment will consider Country, Sector, and Business relationship risks. 4. Follow up on concerns raised in previous financial years regarding our PPE glove supplier and a transport packaging manufacturer to confirm their modern slavery awareness, risk assessments, and supply chain worker conditions continue to be monitored.

8. LLWR SLC Board approval

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2020. It was approved by the board on 19 August 2020.