What we are doing to reduce the risks of modern slavery in our commercial supply chains.
Around the world, tens of millions of adults and children face unimaginable lives of cruelty and hardship in conditions of modern slavery. Slavery finds its way into the supply chains of the clothes we buy, the food we eat, the materials we use in our buildings and the components in our phones and computers. It also takes place within our communities, where individuals are forced into labour exploitation, sexual exploitation, domestic servitude, and criminal exploitation by organised criminal gangs, criminal networks, and individual perpetrators.
Wales is not immune to these abhorrent practices. We must continue to take steps to tackle modern slavery wherever it exists.
We are committed to doing everything in our power to prevent, tackle and eradicate this criminal behaviour and support survivors. We will nurture and promote multi-agency co-ordination and co-operation with our many partners in law enforcement, civil society and beyond to raise awareness, bring perpetrators to justice and make sure that survivors have the joined-up support that they need. Modern slavery does not take place in isolation. Survivors can often be victims of other forms of crime, such as violence against women, domestic abuse and sexual violence.
Ethical supply chains continue to be a focus for the Welsh Government. In 2017, we published our Code of Practice on Ethical Employment in Supply Chains. Since then, more than 500 organisations have signed up to the Code’s commitments on tackling unlawful and unethical employment practices in their supply chains. We are reviewing this Code to keep pace with latest developments and exploring further options to promote ethical and transparent supply chains.
Playing our part in rooting out modern slavery from supply chains is essential to our broader vision for economic, social, and environmental justice. As a globally responsible nation, we have a responsibility to make sure we are not reliant on exploited labour in other parts of the world through our supply chains.
This Modern Slavery Statement describes the steps we have taken to address the risks of modern slavery in our commercial supply chains, alongside action we plan to take going forwards. As we face continuing social and economic challenges, we must work hard to ensure we protect those who are most vulnerable. We recognise the commitment of organisations across Wales to addressing risks of modern slavery across our society. We will only succeed in our efforts to make our country hostile to modern slavery and supportive to survivors if we continue to work together.
Mark Drakeford MS, First Minister.
The Welsh Government is publishing this Modern Slavery Statement in accordance with our Code of Practice on Ethical Employment in Supply Chains. In developing and becoming a signatory to this Code of Practice, the Welsh Government has voluntarily committed to producing an annual Modern Slavery Statement.
As a large organisation, the Welsh Government is inevitably part of global supply chains where workers face exploitation. In publishing this statement, we are acknowledging these risks, accepting our responsibilities, and committing to improving our practices.
Our organisation and structure
The Welsh Government is the devolved government of Wales. Led by the First Minister, it works across key areas of public life, including health, education, and the environment.
The modern slavery portfolio is part of the Welsh Government’s Fair Work Division in the Social Partnership, Employability and Fair Work Directorate. This provides opportunities for aligning complementary work and enables a more integrated approach to addressing criminal and unlawful labour market abuses and encouraging and promoting fair work. Close partnership working with employers and trade unions in Wales contributes to tackling modern slavery and supporting survivors.
The Commercial and Procurement Directorate of the Welsh Government leads on developing procurement policy for the Welsh public sector, which includes ensuring public sector expenditure contributes to social, economic, environmental, and cultural well-being. This includes fair work and preventing modern slavery and human rights abuses in supply chains.
We must ensure public sector expenditure delivers even greater value in contributing to positive social, economic, environmental, and cultural outcomes. Effective, sustainable, procurement, and the successful delivery of works, goods, and services we all rely on, has never been more important.
Achieving this ambition relies on the effective identification and elimination of modern slavery and labour abuse risks within Welsh public sector supply chains.
Our supply chains
The Welsh Government has direct relationships with primarily Welsh and UK based suppliers offering a wide range of services to the organisation and the Welsh public.
In 2022 to 2023, the Welsh Government spent £748m on goods, services and works; £406m was spent on Welsh Government Commercial Delivery frameworks by the public sector in Wales. Please note these figures are subject to change.
The main supply chains of the Welsh Government relate to road maintenance and infrastructure delivery, construction, facilities management, media buying services, education and training services, research and consultancy services, and ICT goods and services.
Our policies on slavery and human trafficking
Modern slavery is the severe exploitation of people for personal or commercial gain. It is perpetrated through mechanisms including human trafficking, threats of violence, forced labour, debt bondage and confiscation of documents. It takes various forms including labour exploitation, which finds its way into the supply chains of our goods and services.
The Welsh Government is committed to acting ethically in all its relationships and taking action to identify and prevent modern slavery in areas within its direct control or influence.
The Welsh Government is committed to fair work practices and is a Living Wage Foundation accredited employer. In the Welsh Government, the relationship between the Welsh Government as an employer and the trade unions representing the Welsh Government workforce is based on social partnership. We believe our goals can best be achieved by management and trade unions working together to improve terms and conditions. As an employer, the Welsh Government adheres to its legal responsibilities and the commitments set out in the Code of Practice on Ethical Employment in Supply Chains.
The Welsh Government has put in place policies and processes to support our ability to tackle modern slavery, both within our organisation and supply chains, and in partnership with other public bodies. These include the following measures:
Anti-Slavery Wales Forum
Organised by the Welsh Government, the Anti-Slavery Wales Forum provides strategic leadership in coordinating work to counter modern slavery in Wales. This includes work to prevent modern slavery from taking place and work to identify and support victims and survivors.
Code of Practice on Ethical Employment in Supply Chains
First published by the Welsh Government in 2017, the Code of Practice requires signatory organisations to take action to eradicate unlawful and unethical employment practices and to ensure all workers at every stage of the supply chain are treated fairly. More than 500 organisations have signed up to the Code. Signatory organisations which have embedded the Code within their policy and processes include South Wales Police (see its 2022 to 2023 Modern Slavery Statement) and Cardiff Council (see its Socially Responsible Procurement Strategy for 2022 to 2027). For more information, please see the Code of Practice on Ethical Employment in Supply Chains.
Wales Procurement Policy Statement
The Wales Procurement Policy Statement sets out the strategic vision for public sector procurement in Wales with 10 key principles focussed on securing well-being for Wales through delivery of progressive policy initiatives. For more information, please see the Wales Procurement Policy Statement Principles.
The relationship between the Welsh Government and its recognised trade unions is underpinned by a partnership agreement that sets out how trade unions work with Welsh Government on issues such as pay, terms and conditions, policies and procedures, and organisational change.
Due diligence processes
The Welsh Government has in place policies and systems across our organisation and our supply chains to:
- identify inappropriate employment practices
- detect, assess, and monitor other potential risk areas
- mitigate the risk of slavery and human trafficking occurring
- protect whistle-blowers
- investigate reports of modern slavery
Supplier adherence to our values and ethics
The Welsh Government opposes modern slavery in all its forms. To support those in our supply chain and contractors to comply with our values, we operate in line with principles of responsible sourcing, including asking our suppliers to ensure that their sub-contractors are paying employees at least the minimum wage applicable within their relevant country of operations. The Welsh Government also has a Supplier Code of Conduct (the Code of Practice on Ethical Employment in Supply Chains, described above) which outlines our expectations. The Welsh Government expects suppliers to adhere to these standards or higher.
Risk assessment and management
The Welsh Government considers its main exposure to the risk of modern slavery and human trafficking exists in lower tier supply chains where products procured could potentially involve labour in regions where protection against breaches of human rights may be limited. These include:
- facilities management services
- ICT hardware (e.g., laptops, mobile phones, and printers)
- labour and materials for construction
- production of raw materials for furniture
In general, the Welsh Government considers the risks of modern slavery taking place within our immediate supply base are likely to be relatively low.
Steps taken to date
To address risks of modern slavery in its supply chains, the Welsh Government has:
- communicated the policy and approach to sustainable and ethical procurement during the bidding process and at supplier events
- outlined expectations that our suppliers sign up to the Code of Practice on Ethical Employment in Supply Chains and promote this through their supply chain
- required suppliers to comply with their obligations in publishing slavery and human trafficking statements, data on compliance is collected through our spend analytics service
- built sustainable and ethical procurement requirements into contract management arrangements and documentation
- required standard supplier contracts to include potential actions in the event the supplier is, or is suspected, to be involved in modern slavery
To ensure a high level of understanding of the risks of modern slavery in our business, in our supply chains and in our business partners, the Welsh Government provides relevant training. Under our Supplier Code of Conduct, we also require our suppliers to provide regular and relevant training to their staff and suppliers and providers. The Welsh Government regularly delivers external modern slavery training and awareness, individually and in partnership with other agencies. This training highlights the signs of modern slavery and how to report concerns, including contacting the Modern Slavery and Exploitation Helpline.
The Welsh Government regularly conducts internal communications on modern slavery and delivers internal awareness-raising events.
Proposed actions and activities
Senior officials have overall responsibility for this area and steps will be taken to:
- review, and where necessary strengthen, measures in place to periodically identify and assess the potential risks in supply chains
- produce a written policy on ethical employment and communicate the policy throughout the Welsh Government and its supply chains
- promote the mechanisms through which suspicions of unlawful and unethical employment practices can be raised
- deliver appropriate training and/or awareness raising to staff on modern slavery and ethical employment practices
- maintain our commitment to ensuring our suppliers are paid on time
- examine how we identify and monitor the employment practices of high-risk suppliers
Rt. Hon Mark Drakeford MS, First Minister
Dr Andrew Goodall, Permanent Secretary
This Modern Slavery Statement was approved on 13 July 2023.