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 itself, 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 Barnardo’s business model 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 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.
Strategy for addressing the risk of modern slavery
Barnardo’s has considered its strategy of implementing the measures set out in its previous statement and has concluded that the work on procurement policies and procedures is key to this. We are, therefore, in the process of producing amended procurement documents (including invitation to tender documents, supplier questionnaires, a supplier risk assessment questionnaire and the procurement policy), which will inform and underpin the other proposed steps.
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 started to conduct a detailed audit and risk assessment of our suppliers, which is a long-term project, given the size of the organisation. We will take action to eliminate and/or reduce the risk of modern slavery where appropriate.
To embed an understanding of the issues of modern slavery across the charity, we have appointed Modern Slavery Champions in each department. These Champions will be key to ensuring that all staff and volunteers understand modern slavery as a human rights issue and as it might be relevant to their work. Champions will also ensure that appropriate policies are in place and relevant training is provided to staff and volunteers.
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 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 are updating 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 progress work on:
- providing specialist modern slavery training to supply chain managers and HR professionals
- rolling out awareness training to all staff and volunteers
- ensuring modern slavery is addressed in all key policies and procedures across the charity
- ensuring 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
- taking steps to ensure that all existing suppliers are risk assessed and that risks identified are appropriately addressed.