Corporate report

Crown Commercial Service Modern Slavery Statement 2020 to 2021

Published 22 November 2023

1. Crown Commercial Service Modern Slavery Statement 2021

2. Foreword from Crown Commercial Service (CCS)

CCS is the largest public procurement organisation in the UK. We create and manage commercial agreements for Government Departments and the wider public sector to access and buy common goods and services.

During the financial year 2020/21 public sector organisations spent £22.7 billion through our commercial agreements.

Reputation matters in attracting public sector customers to make use of our commercial agreements. Public service organisations want to work from the principle that every pound spent is an investment in the quality of life in our society, and not just a financial transaction.

Managing modern slavery risk effectively is a huge challenge that will require a sustained effort over time. We are committed to doing everything in our power to reassure the general public and our central government and wider public sector customers that public spending on goods and services is not funding modern slavery and human rights abuses.

We are placing ever stronger emphasis on social value and modern slavery prevention in designing and developing our commercial agreements. We have also established appropriate governance and risk management policies and processes to monitor and manage compliance and ensure action is taken where necessary.

This statement explains the actions we have already taken to identify, prevent and mitigate modern slavery risk in our existing and new commercial agreements.

It covers the work we have undertaken with other government departments, private and third sector organisations to build better protections and strengthen our risk management processes. It also sets out our future goals and plans to tackle modern slavery in our supply chains.

Simon Tse, Chief Executive and Accounting Officer

3. Section 1: Organisation structure and supply chains

3.1 Background on department’s function

Crown Commercial Service (CCS) is an executive agency of the Cabinet Office and operates as a trading fund under the Government Trading Funds Act 1973. It is also a key constituent of the Government Commercial Function (GCF).

We create and manage commercial agreements for common goods and services for the UK public sector (including central and local government, health, education and emergency services) and we use our commercial expertise to help over 18,000 buyers to buy everything from locum doctors and laptops to police cars and electricity.

Our purpose is to help the UK public sector get better value for money from its procurement of goods and services. Further information about who we are and what we do can be found on the CCS website.

3.2 Internal governance

You can find details about CCS’s governance arrangements on the gov.uk website.

3.3 Internal governance of anti-slavery work

Anti-slavery advocate

Governance of modern slavery risk is sponsored and overseen by our Anti-Slavery Advocate, Colin Morrow, a director who reports into the executive board.

The Anti-Slavery Advocate role was created in September 2020 and it is their responsibility to ensure that CCS is taking a strategic approach to prevent modern slavery risks in its supply chains and producing meaningful, transparent statements that will stand up to public scrutiny.

The Anti-Slavery Advocate also acts as an escalation point for the reporting of risks and issues, for example if there are reports or allegations of modern slavery risks in any of our commercial agreement supply chains.

3.4 Commercial Policy Implementation Team

Creating and managing commercial agreements is CCS’s core business. Day-to-day modern slavery risk management is handled by our category and contract management teams, supported by the Commercial Policy Implementation team (who report into the newly appointed Anti-slavery Advocate).

The Commercial Policy Implementation team is a small cross-site team of policy implementation specialists who work closely with commercial and contract managers to ensure modern slavery risks are fully considered and effectively identified throughout the procurement lifecycle.

The team produces guidance and provides advisory support to ensure responsive operational processes are created to mitigate identified risks. This work is ongoing at the time of writing and is being embedded into business as usual activities.

Training has also been delivered by the Commercial Policy Implementation Team to help colleagues better understand what modern slavery is, identify the signs of modern slavery and use the Home Office’s Modern Slavery Assessment Tool (MSAT) to risk assess their high and medium risk contracts. See Section 4: training and awareness raising.

Our Commercial Policy Delivery team receive many external enquiries and presentation requests from public sector organisations, who frequently seek advice and guidance on how to manage their own modern slavery risks. The team provides practical advice and guidance, and shares lessons learned from our previous modern slavery risk prevention campaigns.

3.5 Commercial Agreement and Approvals Board (CAAAB)

Business cases for new framework agreements are also scrutinised by the Commercial Policy team to ensure modern slavery risks have been fully considered from the outset of the agreement’s development and will be addressed post-contract award before they are submitted to the Commercial Agreement and Approvals Board (CAAAB) for approval.

3.6 Reporting Period

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

3.7 Organisation facts and figures

Number of employees and description of the nature of the labour force

CCS does not directly employ industrial and manual staff.

All salaried staff are employed on full-time contracts, although some may be for fixed periods of time. All temporary staff are employed on formal contracts, either directly or through agencies.

At the end of the 2020/21 financial year CCS had the following staff complement (excluding Fast Streamers and loans out):

Salaried staff	702
Government Commercial Office (GCO) deployed staff	146
Agency and contract staff	57

Countries and regions of department operation

CCS is the largest public procurement organisation in the UK. We operate from four UK regional offices, which are located in Liverpool, London, Newport and Norwich. We also share office accommodation in Birmingham, Leeds and Bristol.

3.8 Supply chain facts and figures

Numbers of suppliers and contracts

CCS manages over 100 commercial arrangements for the purchase of common goods and services. Each agreement sits within a category of spend, which in turn sits within one of four wider groups, called “Pillars” (see below).

CCS commercial agreements by pillar:

Buildings

● facilities management

● estates and project management

● permanent and modular construction

● building materials

● energy

● water

● fuels

Corporate Solutions

● travel

● fleet

● office solutions

● print

● post and storage

● marketing, Communications and Research

● financial services

People

● workforce solutions

● professional services

● contact centres

● people services

Technology

● cloud hosting and digital services

● network services

● software

● cyber security

● technology products and services

3.9 Annual spend

Our customers across the public sector spent over £22.71 billion through CCS commercial agreements in the 2020/21 financial year.

Table 1: Annual Spend Breakdown by Pillar (2020/21)

Pillar	Annual Spend (2020/21)
Buildings Pillar	£3.56 billion
Corporate Pillar	£6.24 billion
People Pillar	£4.78 billion
Technology Pillar	£8.13 billion
Total annual spend	£22.71 billion

Source: CCS Annual Report and Accounts 2021

3.10 Top categories of spend 2020/21

Across all CCS agreements highest spend figures were for cloud computing services within the Technology Pillar at £2.4 billion, and business payment solutions within the Corporate Pillar (at £2.3 billion).

Table 3: Spend and modern slavery risk rating by category

Before carrying out our first MSAT campaign, we used the Tackling Modern Slavery Risk in Government Supply Chains guidance to help us identify our highest risk commercial agreements. Of the agreements identified as being at high or medium risk of modern slavery, those with the highest spend are shown in the table below:

Pillar	Commercial agreement	Annual Spend	Modern Slavery Risk Rating
People	Public Sector Resourcing	£800 million	High
Buildings	Facilities Management Services	£648 million	Medium
Corporate	Postal Services	£318.5 million	High
Technology	Technology Products and Services	£1.4 billion	High

3.11 How customers buy goods and services through CCS

Customers can access CCS commercial agreements in two main ways: catalogues and running a competition. Different buying routes are available for each of our commercial agreements and these are described in further detail on our buy through CCS web page.

Tier 1 Supplier locations

Tier 1 suppliers essentially supply goods/ services directly to the customer and may have a wide range of consultants and subcontractors working for them, creating additional tiers in the supply chain. For CCS, our Tier 1 suppliers are those who are the prime contractors on our commercial agreements.

Approximately 10,000 Tier 1 suppliers were registered under our commercial arrangements in 2020/21, however this number varies within the year as agreements expire and new ones are created.

Key ‘unknown’ supply chain data (For example, overseas supply chains)

Most CCS suppliers are UK registered. However, in 2020/21 CCS had over 400 suppliers registered outside the UK. Over 80% of these were registered in the: * United States

• Ireland
• Netherlands
• Canada
• Australia
• Germany
• Sweden
• India
• Denmark

However, with such an extensive portfolio of goods and services some of our suppliers have global supply chains.

CCS has not routinely collected information from suppliers about their global operations in the past. In future years CCS will work in partnership with our suppliers to better understand the supply chains in our highest risk sectors, such as Technology Products and Services.

4. Section 2: Policies in relation to modern slavery

4.1 Promotion, implementation and enforcement of PPN 05/19

CCS has been playing an active role in developing the Government’s strategy and policies to tackle modern slavery in government supply chains since 2016. We have jointly developed these with the Home Office and Cabinet Office, in consultation with the cross-government Modern Slavery and Procurement Implementation Group.

Together, we have developed the Tackling Modern Slavery in Government Supply Chains guidance and the Modern Slavery Assessment Tool (MSAT) to tackle and eliminate potential modern slavery abuses in our supply chains.

In line with government policy (Procurement Policy Note (PPN) 05/19), we have been developing our risk management approach, using the Tackling Modern Slavery in Government Supply Chains guidance and MSAT to identify and manage potential modern slavery risks since 2019.

CCS uses all the reasonable means available to us to manage and reduce risks in our commercial agreement supply chains. Most of our recent and current efforts are focused around the use of the Modern Slavery Assessment Tool (MSAT) (see Section 3: Risk Assessment and Due Diligence).

We are also taking steps to ensure that suppliers who fall in scope of the Modern Slavery Act are publishing an annually updated modern slavery statement on their web site, through our contract compliance and supplier management processes.

4.2 Our Contract terms and conditions

Our Public Sector Contract terms and conditions include a Corporate Responsibility Schedule (Joint Schedule 5), which requires suppliers to:

1. meet the standards set out in the Government Commercial Function’s (GCF) Supplier Code of Conduct

2. include anti-slavery and human trafficking provisions in its contracts

3. implement policies and procedures to identify and prevent modern slavery

4. prepare an annual modern slavery statement

This schedule is being updated to make it more flexible and effective in how it can be applied. It will do this by enabling CCS and public sector buyers to request reports from suppliers which detail the steps they have been taking to tackle modern slavery risk (even in market sectors which are considered to be low risk).

4.3 Our tenders

Before going out to tender, all of our new contracts go through an approvals process with several pass / go gateways (Commercial Agreement and Approvals Board or CAAAB).

Our approvals board looks for evidence that modern slavery and other relevant government policies have been fully considered during the commercial agreement development phase and included in every business case.

Commercial teams must clearly demonstrate that they have undertaken a full assessment of modern slavery risks and include their reasoning for their risk rating.

Where contracts are rated as being at high or medium risk, we will consider making completion of an MSAT return a contractual requirement post-award.

The standard selection questionnaire is used in all of our procurements.

All bidders must confirm whether their organisation and anybody working in it has been convicted of child labour or human trafficking offences or any other modern slavery crimes.

If bidders have been convicted of certain modern slavery offences under the Modern Slavery Act within the last 5 years, they can be excluded from public procurements, unless they have clearly demonstrated that they have taken measures to remedy these failures and prevent their recurrence.

The standard selection question also asks bidders to confirm whether they are in scope of Section 54 of the Modern Slavery Act 2015. This requires suppliers who have a turnover of over £36 million to publish an annual modern slavery statement on their web site. Any bidder who is in scope is required to provide CCS with a link to this.

CCS will disqualify any supplier or bidder from a place on its framework agreements for modern slavery convictions. For the period covered by this Modern Slavery Statement, CCS has neither suspended nor removed a supplier for reasons connected with modern slavery. We may also suspend or remove suppliers for persistent performance failures and failure to respond to reasonable requests for information.

CCS will take reasonable and proportionate steps where in-scope suppliers have failed to update their modern slavery statement on their web site following the initial tender process.

4.4 Implementation of Social Value in procurement policy

Procurement Policy Note 6/20 (Taking Account of Social Value in the Award of Central Government Contracts) enables social value to be used to identify and manage the risks of modern slavery in supply chains.

Our new Construction Professional Services Framework demonstrates how modern slavery prevention and social value can work in parallel to complement each other.

The procurement specification requires suppliers to actively manage the risk of modern slavery and exploitation in construction supply chains at framework contract level and in the delivery of each project contract. This includes making proper background checks on the agencies who supply labour, and requires suppliers to report the discovery or suspicion of any slavery or trafficking to CCS and the commissioning client.

We also require suppliers to agree to several universal principles in their own company and supply chains. For example, employment by choice, free association, safe and hygienic working conditions, no child labour, wages not lower than minimum wage, working hours not excessive, no discrimination, regular employment and no harsh or inhumane treatment.

Social value has been specifically used to ask award questions about a company’s commitment to value, train and develop its own staff, and support smaller businesses in their local areas or supply chains. We think this will support responsible practice in the sector, and has drawn some positive bidder responses.

4.5 Implementation of responsible purchasing practices

Prompt payment

Government has recently published two policy procurement notes on prompt payment (PPN 04/19 and PPN 07/20).

The effect of these notes is to require all suppliers to government for contracts in excess of £5 million each year to pay 95% of their supplier invoices within 60 days.

Any supplier not meeting this threshold will not be selected for any new CCS frameworks unless they can demonstrate that they have managed to pay at least 85% of their invoices within these timescales and have a plan in place to improve their performance.

These terms are being added to specifications for newly awarded framework agreements.

During the reporting period for this Modern Slavery Statement, CCS paid 97% of undisputed supplier invoices within five days and 100% of undisputed payments due within 30 days.

5. Section 3: Risk Assessment and Due Diligence

5.1 Approach to prioritising anti-slavery activity

CCS undertook its first risk assessment exercise using Modern Slavery Assessment Tool (MSAT) in 2019/20. We identified a total of 26 framework agreements in the Construction, Facilities Management, Recruitment and Technology sectors, which were at high or medium risk of modern slavery. 210 out of 229 suppliers (94%) working under these frameworks fully completed the MSAT assessment within the campaign time frame.

For this first campaign, in-scope suppliers were asked to complete MSAT on a voluntary basis, as there were no existing contractual requirements to complete an assessment.

5.2 Findings from risk assessments

Based on the most common risks disclosed by suppliers completing the MSAT, the following recommendations to suppliers were generated:

1. consider developing and using relevant key performance indicators to manage risks

2. develop internal processes to respond to modern slavery reports or suspicions

3. consider carrying out due diligence to avoid debt bondage in supply chains

4. assess buying practices that could increase modern slavery risks

5. consider modern slavery risk at every stage of the procurement process, for example by mapping supply chains

Follow-up conversations with suppliers who completed the first campaign started early in 2020. However, this was one of many areas of our work disrupted by the COVID-19 pandemic. In future years, CCS will use supplier performance review meetings to focus on improvements that need to be implemented to tackle any identified modern slavery risks.

5.3 MSAT Campaigns 2020 to 2021

Ten more MSAT campaigns have been run by our category teams since our first campaign. These have covered our vehicle hire, postal services, office supplies, document management, logistics, resourcing, contact centres, furniture and construction agreements. In many cases these are newer versions of earlier commercial agreements.

During 2021 stalled procurements are being restarted. MSAT follow-up work by our commercial teams has begun to take place, but is not yet fully integrated into business-as-usual supplier management processes.

In some cases we will expect suppliers from the first campaign to update their MSAT return. This also provides opportunities for suppliers who did not fully complete an MSAT assessment to submit one.

Priority will be given to contact low scoring suppliers. We will also be paying particular attention to suppliers with overseas supply chains.

5.4 Plans to strengthen risk assessment process

Reflecting on our work to tackle modern slavery, we have identified a mix of opportunities and challenges.

By applying a constructive and collaborative approach with suppliers, MSAT has been helpful in building a shared modern slavery prevention approach.

By completing an MSAT assessment, suppliers are made aware of risks that they may not previously have considered. It also sends a signal to them that we are serious about preventing modern slavery in public sector supply chains.

As modern slavery risk management is a long term commitment, we are working to mainstream what has been largely project-based work into business-as-usual ways of working. We have recognised that the application of MSAT to identify and manage modern slavery risk is a serious commitment that requires a significant investment of time and resources both from CCS and our own supplier base.

In the past year, we have made it compulsory for any new commercial arrangement to be risk assessed using the Risk Characteristics Table in the Tackling Modern Slavery in Government Supply Chains (page 19). We will also be looking carefully at how modern slavery risks are articulated and addressed in category team risk registers across our four pillars.

Outside of the MSAT process, we have been speaking to technological hardware suppliers about concerns relating to the treatment of ethnic minority groups at manufacturing sites in China. We are working to ensure that hardware manufactured under oppressive labour conditions is not supplied through our frameworks.

We have worked with the Management School at University of Liverpool to help build an understanding of how effectively modern slavery prevention is being put into practice.

An initial project in 2019 was a short review of the quality of modern slavery statements on company websites against the Ethical Trade Initiative’s evaluation framework.

In the past year we have supported the University’s research for the Modern Slavery and Human Rights Policy and Evidence Centre. We contributed to a study into the Implications of COVID-19 for modern slavery challenges in supply chain management.

We will continue to work with the university on research into the practical implementation of modern slavery prevention.

6. Section 4: training and awareness raising

CCS has sought to adopt a shared learning culture by developing internal guidance and running training workshops to share knowledge and information and improve our commercial colleagues’ ability to identify and tackle modern slavery risk effectively.

We recognise that effective prevention work needs more than ‘dry’ business processes and designed our training with this in mind.

Numerous awareness, introductory sessions and specific skills sessions have been run for our commercial staff during the year April 2020 to March 2021. We have also run knowledge transfer meetings and briefings for organisations across the wider public sector.

6.1 Training for staff

Although we have tried to ensure all our staff have some understanding of modern slavery risks, we have focused most of our attention on equipping CCS commercial teams whose supply chains are likely to be categorised as medium or high risk.

We have made it a priority for these teams to become competent users of the MSAT Tool. To date we have run at least 15 dedicated sessions with over 200 staff attendee hours.

Sessions are designed as follows:

Module 1: What is modern slavery and what are our legal and policy obligations

Module 2: MSAT campaign user skills

Module 3: Conducting supplier follow-up conversations

A basic knowledge of modern slavery and CCS’s responsibilities in this arena is becoming more embedded across our organisation. We have run workshops for senior management teams, buying teams, new starters and staff studying for chartered procurement qualifications to bring modern slavery prevention to life.

6.2 Commercial Policy Hub

We have developed and published a commercial policy hub on our intranet, which details what people need to know and do to effectively implement modern slavery, social value and other key policy areas.

The hub has become a major reference point for CCS, which helps colleagues consider key policy topics that need to be addressed and covered in new commercial agreements.

The modern slavery page contains comprehensive information, and is focused on the actions commercial teams need to take to risk assess existing contracts and the steps they need to take when developing new business cases and preparing for a new tender.

6.3 Customer facing guidance

We have published public-facing guidance and materials about our modern slavery prevention work on our web site. These can be accessed on our Making Responsible Buying Decisions web pages.

6.4 Broader awareness raising and training

CCS runs modern slavery eLearning workshops for its customers and encourages its own staff to attend relevant cross government training events. Those who are studying the Chartered Institute of Purchasing and Supply (CIPS) qualifications are required to undertake the CIPS ethical procurement and supply eLearning and assessment.

In the summer of 2021, CCS ran its first Modern Slavery webinar.

We also receive frequent requests for advice, guidance and support from our customer base and are often asked to support customer-led workshops.

7. Section 5: Goals and Key Performance Indicators (KPIs)

7.1 Goals

Finding and acting on modern slavery in our supply chains is a huge challenge that will require a sustained effort over time.

Our goals for 2021 to 2022 will build on the work that we have already undertaken during this reporting period and will be organised around the following themes:

Capability

We will continue to build knowledge, skills and confidence of staff to work with suppliers and manage modern slavery risks in effective ways by:

1. ensuring all staff complete mandatory training on modern slavery risks and CCS obligations and actions appropriate to their roles in the organisation (for example commercial staff will complete the annual CIPS Ethical Procurement and Supply eLearning course which includes a test).

2. delivering specific skills training for those commercial staff who need to conduct more formal assessments of risks and follow-up conversations with suppliers

3. ensuring joined up working across our policy, procurement and commercial staff to build effective modern slavery prevention measures and relevant social value themes into our specifications, and design award questions that test a bidder’s commitment to improving the wellbeing of their workforce, due diligence and anti-slavery activity.

4. continuing to improve our internal Commercial Policy Hub and guidance to supplement the training we deliver; enabling our commercial teams to confidently carry out due diligence and conduct more effective enquiries with suppliers operating in high and medium risk markets.

5. instilling confidence in our procurement and commercial staff to respond in timely, robust and effective ways if a CCS supplier is subject to an investigation for suspected crimes under the Modern Slavery Act

6. considering additional training opportunities to raise awareness of modern slavery risks across the organisation

Risk management

We will continue to ensure that all business cases for new procurements include an analysis of modern slavery risks using the Tackling Modern Slavery in Government Supply Chains guidance and commit to use an appropriate risk assessment tool post-contract award where the modern slavery risks are high.

Contractual protections

We will strengthen the contract provisions and mechanisms in Joint Schedule 5 (Corporate Social Responsibility) of the Public Sector Contract. This will include clauses that enable CCS and customers to require suppliers to report the steps they have taken to manage and mitigate modern slavery risk in their supply chains.

Compliance with the law

We will request that all suppliers in scope of Section 54 of the Modern Slavery Act provide a copy of their annually updated and easily accessible modern slavery statement on their web site.

Record Keeping

Record keeping will be strengthened and we will develop appropriate corporate data capture systems to track the progress of supplier follow-up conversations and the improvement plans that suppliers have agreed to implement to tackle identified modern slavery risks.

7.2 Key Performance Indicators (KPIs)

These are influenced by our goals.

Many of the KPIs (below) will be defined and implemented at a contractual level by category and commercial management specialists. The measures and timescales they include will be adapted to each commercial agreement according to the risk level associated with that particular product and service category, and market sector.

The Commercial Policy Implementation team will continue to work closely with these teams to help them refine and develop these into meaningful contract level KPIs with appropriate measures and timescales for their commercial agreements.

7.3 Internal capability

We will continue to equip our commercial and procurement teams with the skills and knowledge they need to recognise the signs of modern slavery, carry out effective due diligence and risk management, carry out follow-up conversations with high risk suppliers and critically interrogate the assurances that suppliers provide by:

1. encouraging all of our commercial staff to complete both the annual CIPS Ethical Procurement and Supply eLearning course and test.

2. continuing to develop our commercial policy hub and the guidance and resources we make available to our commercial and procurement staff during the 2021/22 financial reporting year

3. continuing to deliver tailored modern slavery training to all of our category and contract teams on a quarterly basis during the 2021/22 financial reporting year.

7.4 Managing modern slavery risk

We will continue to manage and mitigate the risk of modern slavery in our commercial agreements:

1. all new procurement Final Business Cases (FBCs) will include a modern slavery risk analysis using national guidance to determine whether the new agreement is at high or medium risk of modern slavery and include a commitment to use appropriate risk assessment tools.

2. we will request that all suppliers on high and medium risk contracts complete a labour risk assessment such as MSAT or other appropriate risk management tool post contract award. Follow-up conversations will be carried out with non-respondents to maximise risk assessment completions.

7.5 Improving contractual protections

We will implement changes to the protections built into our contractual terms and conditions by:

1. publishing an updated Joint Schedule 5 (Corporate Responsibility), which includes strengthened modern slavery risk management and reporting mechanisms will be published by the end of the 2020 to 2021 financial year.

2. continuing to peer review all commercial contract documents for all new agreements before they go out to tender to ensure sufficiently robust protections are included in specifications to mitigate modern slavery risk in high and medium risk contracts.

7.6 Operational protections

By Winter 2021 we will develop and implement a rapid response process for urgent concerns where law enforcement investigations or other disclosures raise immediate cause for concern about a supplier’s possible involvement in modern slavery activity.

By Spring 2022 we will implement operational procedures to ensure that all suppliers who fall in scope of Section 54 of Modern Slavery Act have published compliant, up to date modern slavery statements on their web sites. Non-compliant statements will be escalated to procurement and commercial teams for further action during the tender and post contract award stage.

By Summer 2022 we will complete internal discovery work towards developing a CCS-wide data collection and management information model for capturing modern slavery due diligence activities and follow-up actions. We will then look to develop and roll out the resulting solution in future reporting years.

7.7 Looking ahead

We recognise that we have taken initial steps to develop a modern slavery prevention culture. Over the past two years we have created an organisational environment where modern slavery is well understood, and can be openly discussed in planning and developing our commercial agreements.

We will continue to build on the progress we have made and lessons learned to date. Our staff are highly motivated to protect public sector supply chains and have learned new skills working in this area.

We want to establish CCS as an exemplar of best practice and leadership in preventing modern slavery in public sector supply chains in our customers, suppliers and the general publics’ minds.

Simon Tse

Chief Executive and Accounting Officer

Approved by the Crown Commercial Service Board on 21 September 2021