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Barnardo’s Slavery and Human Trafficking Statement

Barnardo’s and the Modern Slavery Act

Barnardo’s welcomes the Modern Slavery Act 2015 and the duty it places on large organisations, including Barnardo’s, to disclose publicly the steps they are taking to prevent modern slavery organisationally and in their supply chains.  This Statement is made on behalf of Barnardo’s and its relevant subsidiaries.

The term Modern Slavery is used as an overarching term for an abuse of human rights in the supply chain in pursuit of profits.  It denotes human trafficking, forced labour and slavery-like practices such as debt bondage, and the sale or exploitation of children.

Barnardo’s is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking. Barnardo’s will require all direct suppliers, service providers and contractors to answer questions on modern slavery and are committed to preventing modern slavery within their own activities and through their supply chain, which includes manufacturers, and providers of services.

Barnardo’s structure and supply chain

Barnardo’s is a charity registered in England and Wales and Scotland. It is governed by its Articles of Association and its objects are to promote the care, safety and upbringing of children and young people and the relief of those in need by reason of age, ill-health, disability, financial hardship or other disadvantage.

Barnardo’s owns the whole of the issued capital of Barnardo Holdings Limited, which in turn owns the whole of the issued capital of the following subsidiaries, operating with the following principal activities:

  • Barnardo Developments Limited - Property development
  • Barnardo Events Limited - Sponsorship and special events
  • Barnardo Services Limited - Childcare services
  • Barnardo Trading Limited - Retail, online and direct marketing
  • Barnardo’s Garden Village Management Company Limited - Property management

Barnardo’s is also the sole member of AdoptionPlus – Family placement (direct subsidiary of Barnardo’s from September 2018)

Barnardo’s uses a large number of suppliers across all of its functions, to enable it to carry out its charitable purposes. These range from fundraising and retail suppliers to those used in property redevelopment and the provision of office facilities and recruitment services. In order to deliver our Children’s Services activity we also work in partnership with a wide range of organisations including other voluntary organisations and private companies.

Strategy for addressing the risk of Modern Slavery

Barnardo’s has continued to consider its strategy for addressing the risk of Modern Slavery. As covered in the previous Statement, we concluded that the work on procurement policies and procedures was key to this. We have therefore, reviewed our policies, processes and ways of working to ensure we have addressed and are reducing the risk of modern slavery across the charity.

Due diligence, auditing and risk assessment

In order to assess the risk of modern slavery in our existing supply chains and to understand the operating context of the charity, Barnardo’s has in place a plan to enable us to conduct a detailed audit and risk assessment of our current suppliers, which is a long-term project given the size of the organisation. All new suppliers are now checked as part of the procurement process. We will take action to eliminate and/or reduce the risk of modern slavery where appropriate.

We have produced amended procurement documents including a new procurement policy. The policy and strategy set out new due diligence, invitation to tender documents, supplier questionnaires, and a supplier risk assessment questionnaire. These will inform and underpin our other activities designed to address the risk of modern slavery.

We carry out due diligence with all partner organisations and expect our partners to have the relevant statements, policies and procedures in place and in line with the Modern Slavery Act. These partners include other charities with whom we deliver services. Where relevant we support these charities to develop their modern slavery statement.

Our own workforce and service delivery

We have ensured that all our managers understand modern slavery as a human rights issue. Our managers are responsible for ensuring our workforce understand their responsibilities and that our policies are implemented and appropriately discharged.   

Through our services Barnardo’s provides services to children and young people who have been trafficked and exploited due to modern slavery. We ensure our staff have the training and knowledge to work with these children. In line with our safeguarding policies statutory agencies are involved.

Barnardo’s is a first responder for the National Referral Mechanism (NRM) and where appropriate we refer children to the NRM.

Our policies and procedures

Barnardo’s has a suite of policies that govern its activities from recruitment to authorisation limits and procurement.

In order to address modern slavery, Barnardo’s is implementing a dedicated Modern Slavery (MS) policy that sets out the charity’s position in relation to modern slavery, indicates the requirements Barnardo’s and its subsidiaries have on entering into contractual relationships with others, and ensures that the charity, its managers and staff are aware of their responsibilities in working to ensure modern slavery has no place in Barnardo’s.

To complement the MS policy, we have updated a number of policies impacted by modern slavery, including recruitment, procurement, safeguarding and the employee code of conduct, as well as ensuring that our whistleblowing policy is clear on process and procedures for reporting any concerns about modern slavery.

Programme of continuous improvement

It is intended that the steps set out above will enable Barnardo’s to continue progressing the following work:

  1. Through our due diligence processes, ensure that all new partners and suppliers understand our expectations in relation to the Modern Slavery Act;
  2. Ensure that all our managers understand the requirements placed upon them by our Modern Slavery statement and policy;
  3. Continue to ensure that modern slavery is addressed in all key policies and procedures across the charity;
  4. Ensure that modern slavery is addressed throughout the procurement process, by evaluating all potential suppliers in relation to modern slavery risk before they enter the supply chain;
  5. Complete our risk assessments of all existing suppliers and ensure that risks identified are appropriately addressed;
  6. Carry out due diligence and set our expectations for those organisations we partner with in the provision of our Children’s Services;
  7. Maintain clear and transparent processes in place for the reporting of Slavery and Human Trafficking in line with statutory guidance;
  8. Implementing a working plan to enquire at the due diligence stage about Modern Slavery along with EDI, H&S, Environment and Sustainability.
  9. Cover Modern Slavery within our training sessions to be launched along with the new procurement policy and new suite of documents and templates early in 2019.
  10. In conjunction with the Audit team, carry out an audit of incumbent suppliers as a long term project, for their MSA statements and action plans, especially suppliers of promotional items and social services where we believe there is a bigger risk.

Read more about our work with trafficked children.

Wendy Becker

Chair of the Board of Trustees

December 2018