Corporate report

Coal Authority modern slavery statement for financial year 2023 to 2024

Published 18 April 2024

1. Forward

The Coal Authority is proud to support the UK Government’s objectives to eradicate modern slavery and human trafficking in all its forms and we remain fully committed to maintaining the highest standards of due diligence in this respect.

Over the past year, we have continued our focus through on-going dialogue with potential and current suppliers on how they can best use the UK Government standards to eradicate this abuse of human rights.

Over the next year, we are continuing our all colleague training on modern slavery awareness training to all our colleagues on the Modern Slavery Act. We are also engaging across our existing supply chain to help partners improve their Modern Slavery Assessment Tool scores as part of the annual assessment, as well as embedding the assessment tool into all future procurement activity.

As with last year, we invite you to help tackle modern slavery by sharing best practice and holding us to account where you think we could do better.

James Lowth, People and Resources Director, March 2024

2. Background

Modern slavery and human trafficking are crimes and an abuse of human rights. It is imperative that across our organisation that we embrace the opportunity to address the risks of modern slavery and human trafficking throughout our business activities.

This statement outlines the policies, processes, and actions that we have taken over the previous year to understand the potential impact to the Coal Authority from modern slavery and also future planned actions to further support our commitment to the eradication of modern slavery across our supply chains.

This statement relates to the financial year ending 31 March 2024 as well as a future look for the next financial year, and is in full accordance with the following legislation and guidance.

• Section 54 of Her Majesty’s Government Modern Slavery Act (2015)
• PPN 05/19 Tackling Modern Slavery in Government Supply Chains
• Transparency in supply chains: a practical guide, Home Office (updated April 2020)

3. Our commitments

The Coal Authority is committed to protecting and respecting human rights and have a zero tolerance approach towards modern slavery. We are committed to ensuring that there is no modern slavery and human trafficking in our supply chains or any part of our business. We do not enter into business with any organisation, which knowingly supports, or is found to be involved in slavery, servitude or forced or compulsory labour.

As an equal opportunities employer, we’re also committed to creating and ensuring a non-discriminatory and respectful working environment for our people. Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK.

We commit to adopting best practice approaches where possible to understand and eradicate modern slavery risk across our supply chains and foster positive working relationships with our suppliers to support this ambition.

In 2023, we furthered our commitment to support sustainable supply chain and business practice by employing a new specific member within our procurement team as a ‘sustainable procurement business partner’ with modern slavery eradication and due diligence being the forefront of their priorities and objectives.

4. Our business and supply chain

The Coal Authority is a non-departmental public body and partner organisation of the Department for Energy Security and Net Zero. We manage the legacy of the former coal mining industry on behalf of the governments across England, Scotland and Wales.

We also use our skills to provide services to other government departments and agencies, local governments and commercial partners as we deliver our mission of making a better future for people and the environment in mining areas.

Our purpose:

• we keep people safe and provide peace of mind
• we protect and enhance the environment
• we use our information and expertise to help people make informed decisions
• create value and minimise cost to the taxpayer

We will continue to focus on our mission of making a better future for people and the environment in mining areas. Our investment in coalfield areas and the use of local suppliers supports the levelling up agenda.

For further details on our business vision and ambitions, please see our business plan 2022 to 2025.

We engage with a range of suppliers from small and medium-sized enterprises to large corporations, the majority of which are UK based. Our main suppliers provide technical and specialist construction related services, which support our core activity. Whilst we assess ourselves to have a generally low risk of modern slavery in our business activity, we acknowledge that electronics, ICT hardware, construction and service staff are the highest risk areas for us and therefore focus on these appropriately.

In 2023 to 2024 we spent approximately £62m buying goods and services from our 620 direct suppliers.

Our suppliers are sourced through pre-qualified UK Government Crown Commercial Services and other public sector frameworks, as well as through competitive tender on the open market. Our sourcing activity is undertaken in compliance with the Public Contract Regulations 2015. 

5. Coal Authority policies in relation to modern slavery

We are committed to doing the right thing by ensuring we respect human rights and the environment. We manage a governance framework for all material focus areas within our sustainable framework and follow best practice guidelines provided by the Government Commercial Function, on which our policy and processes are based.

The following policies are available to all staff through our intranet:

• code of conduct
• whistleblowing policy
• bullying and harassment policy
• diversity and inclusion policy
• recruitment and selection policy

6. Due diligence within our supply chain

We follow the Government Commercial Function guidance and build appropriate measures into our sourcing, supplier on-boarding and contract management processes, therefore minimising our exposure to risk. Using supply chain due diligence principles enables us to make a judgement on transactions and the integrity of our supply chain.

We aim to build relationships with our suppliers to ensure they comply with our values and that they are aware of our commitment to protect human rights and the environment. As part of our procurement process, suppliers are required to comply fully with the Modern Slavery Act 2015, wherever it applies, as well as appropriate contractual obligations with contract termination as a potential sanction for non-compliance.

Any contractor who is identified as a cause for concern regarding modern slavery be referred for investigation via the National Crime Agency’s national referral mechanism.

Where possible, further modern slavery mitigation measures are embedded into medium and high risk contracts through the procurement exercise and measures such as Modern Slavery Assessment Tool (MSAT) requirements or assessing modern slavery practice through social value criteria theme 4.

7. Risk assessment and management

Following the guidance provided by the Government Commercial Function, in 2024, we have undertaken a full risk assessment review of our tier 1 supply base and categorised our contracts as low, medium or high risk by assessing these against key modern slavery risk indicators.

We have subsequently engaged with each of our medium and high category risk suppliers to further understand their modern slavery risk across their supply chains through the use of the Government Commercial Function MSAT in which those suppliers can share their MSAT score and improvement activity with us.

We will work closely with suppliers to ensure all of those modern slavery process and policy improvement activities identified, are progressed and remedied throughout 2024 to 2025. The MSAT campaign will be reviewed and updated annually across our supply chain.

If a supplier fails to adequately remediate the issue, the relationship would be re-evaluated and if necessary, terminated.

8. Key performance indicators

Where potential modern slavery impacts are identified within a contract requirement, we will work with our suppliers to develop appropriate key performance indicators to monitor and manage performance in regards to these risks.

Where the MSAT requirement has been embedded through procurement exercises, the improvement activity generated, will be transferred into key performance indicators through the contract life as well as the requirement to update their MSAT response annually.

9. Training on modern slavery and trafficking

All procurement team members are also required to undertake mandatory modern slavery awareness training. We will ensure our staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK.

In 2023 to 2024 all procurement business partners are mandated to complete the Government Commercial Function College ‘Tackling Modern Slavery in Supply Chains’ training modules as well as the Chartered Institute of Procurement and Supplies online course on ethical procurement and supply.

In 2024 to 2025 we aim to include the wider business in the requirement to complete modern slavery training on an annual basis.