MODERN SLAVERY
STATEMENT 2018

Save the Children is the world’s leading independent organisation for children. This year marks Save the Children’s 100 year anniversary. Since its inception, Save the Children has worked to ensure all children survive, have access to a quality basic education, and are protected from all forms of violence.

Save the Children has worked in a number of ways to address issues of child exploitation in the various places we have worked, helping to drive change in communities, and seeking to prevent modern slavery and human trafficking. Save the Children welcomed the introduction of the UK Modern Slavery Act 2015 and the milestone it represented in ensuring that organisations take steps to act against this grave violation of human rights, which often preys on children. Between 2016 and 2018, Save the Children International (SCI) has worked in diverse ways and across a range of industries in order to address the involvement of children with harmful work.

SCI has implemented measures to combat child protection violations associated with cocoa, tea and vanilla value chains in Cote d’Ivoire, Sri Lanka and Madagascar, respectively. Examples of such measures include: removing children from exploitative working conditions in cotton farming and brick kilns in India; addressing child protection issues in the cocoa industry in the Dominican Republic; supporting companies and governments to adopt child protection policies and monitoring systems which enable children to attend or return to school, such as in Cote d’Ivoire. Save the Children also recently contributed to the Modern Slavery Act Review, making a joint submission with other campaigners in this area.

Focusing on practical measures to prevent and detect modern slavery, and ensuring that those it works with do the same, is consistent with Save the Children’s vision, mission and values. Measures to counter modern slavery and human trafficking are embedded into the work we do around the world, particularly in relation to our child protection work.

A. OUR STRUCTURE AND SUPPLY CHAIN

As a global movement Save the Children is made up of 28 independent national organisations, each of which is a member of the movement’s central body, the Save the Children Association (SCA). Members lead on activities within their home territory and work with donors to develop programmes abroad, which are delivered by the movement’s implementing body - Save the Children International (SCI) - via teams on the ground in each country. SCI is a UK charity and company limited by guarantee headquartered in London, functioning through SCI’s network of 5 regional offices and 55 country offices operating programmes in 61 countries. SCI provides development and humanitarian programming and campaign, policy and advocacy work to drive change for children, including those living in some of the most difficult and dangerous places in the world.

Together with the 28 national members, SCI works in over 120 countries worldwide to inspire breakthroughs in the way the world treats children and to achieve immediate and lasting change in their lives. All the members of Save the Children, with combined revenues of over $2 billion, are working to deliver a shared strategy – Ambition for Children 2030.

This statement is SCI’s Modern Slavery Statement. It builds on SCI’s previous Modern Slavery Statements, available on our website here, detailing the steps we have taken to help prevent and eliminate risks of modern slavery in our business and supply chains.

(i) SCI’s business

SCI employs approximately 16,500 people across its offices globally, in addition to volunteers and contractors. We have human resources functions in the country and regional offices where we work, and primarily hire our workforce directly and locally, through the relevant local HR functions, although in some instances we use agencies to assist with our recruitment. Further information about how our recruitment procedures help prevent risks of modern slavery are detailed below.

(ii) SCI's supply chain

SCI has a very complex, dispersed, supply chain. SCI is not involved in manufacturing, agriculture or retail industries, which are typically high risk activities for modern slavery. However, at least 80% of SCI’s procurement is sourced in country by SCI’s 56 country offices. These are located in some of the most challenging conditions in the world, and SCI recognises the risk of modern slavery in that context and takes it very seriously. SCI is currently developing an online procurement platform, to automate many source to pay procedures, and its procurement systems across the organisation will gradually be transitioned onto this system. The platform aims to simplify procurement procedures enabling greater visibility over SCI’s supply chain and enabling increased compliance.

SCI Supply Chain Key Statistics

• $392m third party, supplier spend
• 2,500 supply chain headcount
• 363 warehouses
• 3,703 vehicles in SCI’s fleet

(iii) SCI’s partnerships

SCI delivers approximately 15% of its portfolio through partners. These are often organisations based in the countries in which SCI operates and delivers its programming. SCI has a Head of Partnerships at SCI’s headquarters in London, and regional and country office partnership focal points across our movement. We continue to work with partners to ensure that modern slavery is not present in their operations and programming.

B: OUR VALUES AND POLICIES

(i) Mandatory staff policies

As detailed in SCI’s previous modern slavery statements, our Modern Slavery and Human Trafficking policy sets out SCI’s zero-tolerance approach to modern slavery and its commitment to ensuring that modern slavery is not taking place in its business and supply chains. This approach is supported through a framework focusing on awareness, prevention, reporting and responding.

In addition to our Modern Slavery and Human Trafficking Policy, SCI has a number of policies in place which are mandatory for staff to sign, and which help us to combat modern slavery, including our Code of Conduct, Child Safeguarding Policy, Fraud, Bribery and Corruption Policy and Anti-Harassment and Bullying Policy.

SCI’s Recruitment Policy and Procedure, Reward Policies and Relocation Policies embed the principles through which SCI recruits and helps ensure that modern slavery is not present within SCI’s own business.

(ii) Supply Chain and Partners

During 2018, SCI rolled out its Procurement Policy, which is essential to the operation of country and regional offices, and the accompanying Procurement Manual; these documents assist local teams to ensure that they are following agreed processes, and are aware of the policies and procedures which we expect them and our suppliers to comply with, including our Modern Slavery and Human Trafficking Policy. The essential standard detailed in the Procurement Policy sets out SCI’s ambition to meet the highest ethical and professional standards in its interactions with suppliers and in compliance with all legal and ethical requirements, and to ensure suppliers adopt similar codes of conduct in their business dealings. In 2018, a significant amount of training was delivered to Procurement teams globally which reiterated compliance with policies. Following the training, staff have to complete a test to confirm their competence and understanding.

Our Modern Slavery and Human Trafficking Policy has been embedded as a mandatory policy in our revised template partner agreements (rolled out in 2018) and our spectrum of global template supplier contracts and tender invitations. Strict provisions have also been embedded in, and are fundamental to, our construction contract template, as we recognise the higher risk of modern slavery in this industry. Other policies to which our Suppliers are subject, such as our Child Safeguarding Policy, our Fraud Bribery and Corruption Policy, and the Inter-Agency Procurement Group Agencies and Suppliers Code of Conduct, set out SCI’s expectations of suppliers and help prevent instances of modern slavery. SCI also has comprehensive resources aimed at ensuring compliance with US Government and USAID Anti-Human Trafficking Provisions.

C. OUR ACTIONS

We have been taking the following steps to help improve our existing structures and systems and raise awareness, prevent, detect and respond to risks of modern slavery:

(i) Due diligence processes

SCI’s business

Staff awareness: Staff awareness about modern slavery is key to ensuring that suspicious behaviours and indicators of modern slavery are flagged early on, and appropriately managed. Details of training currently available to staff are set out below in ‘Awareness and Training’.

Recruitment practices: Our recruitment practices help prevent the risk of modern slavery within our business. Our recruitment agreements and policies are managed locally, based on global templates and principles but adapted for the relevant local context and applicable law. Some of the measures which SCI has in place include:

• Conducting regular salary reviews to ensure that staff get paid a living wage in the countries it operates in, and benchmarking salaries to ensure that they remain competitive in the sector;
• Conducting background checks as part of the recruitment process;
• Checking, but not withholding, identity documents and rights to work documentation;
• Providing information on workers’ rights in a language they can understand;
• Not allowing for fines or for workers to be charged finders’ fees within its contracts, and not deducting accommodation or transport costs from staff salaries.

SCI’s Supply Chain

Our existing processes require that all potential new suppliers be vetted locally and globally and that local teams, who understand the local context, consider risks associated with a potential supplier and make risk based decisions for each sourcing activity.

Following its development and early rollout in 2017, in 2018 we continued to roll out our Procurement Manual (which includes information about our Modern Slavery and Human Trafficking Policy) to cover the vast majority of country offices. In 2019, we are updating the manual, integrating further practical steps on conducting diligence on potential suppliers and identifying risks of modern slavery within their businesses.

SCI’s Partners

We ensure partner due diligence through conducting both mandatory partner vetting, and embedding questions concerning modern slavery and human trafficking in our mandatory Partnership Assessment Tool, to assess qualification of partners to deliver programmes together with us. This assists in considering and highlighting potential issues around modern slavery in partners we are considering working with.

(ii) Identifying, assessing and managing risks of modern slavery

Risk assessments: Keeping the children and people we work with safe is one of Save the Children’s top priorities. SCI has various risk assessment tools, which assist our staff to identify risks and effective mitigations, including tackling the risk of modern slavery amongst potential suppliers and partners, and in humanitarian responses. We are committed to strengthening these tools.

Humanitarian Response Risk Assessments: There can be a higher risk of modern slavery and trafficking in the context of humanitarian crises. New risk assessment templates, which SCI started using in 2018 together with risk guidance documents, are now completed at the start of any major humanitarian response, and reviews of its controls are also conducted afterwards. The risk assessment includes specific questions around modern slavery and human trafficking (particularly in the context of supply chain), and broader questions around operational risk also enable modern slavery risks to be identified.

Child Safeguarding Tools: Our child safeguarding tools, which include risk assessments, training, and dedicated Child Safeguarding focal points in each SCI location, are also supportive of an approach to identifying, preventing, reporting and following up with risks and incidents of modern slavery and human trafficking. In 2018, we completed new comprehensive risk guidance and a new risk tool which further improves our prevention work around exploitation and abuse, which is being rolled out in 2019.

New Partnership Assessment Tool: During 2018, we rolled out a new mandatory Partnership Assessment Tool, which incorporates questions on modern slavery and human trafficking to help us identify risks associated with prospective partners with whom we plan to deliver our programmes.

Supplier visits: Our local teams determine whether to conduct inspections of suppliers, and tend to focus on programmes such as nutrition and pharma where product quality is critical. We have reporting mechanisms in place for reporting modern slavery concerns, detailed within our Modern Slavery and Human Trafficking Policy. Where an issue is reported in relation to a supplier and an investigation is commenced, the investigation team determines whether a visit to the supplier’s premises is necessary.

Supplier warnings: In our supply chain, our locally managed databases record the vetting status of suppliers and whether that status has been affected by, for example, violations of our ethical standards (including where they have been involved in perpetrating modern slavery) and to ensure that they are not used by our organisation. Our global procurement system, which is currently being developed, will enable this information to be visible at a global level, to enable enhanced compliance across the contexts in which we work.

Procurement manual updates: Updates to our procurement manual in 2019 will include more detailed information about how to investigate, and act on reports of modern slavery within SCI’s supply chain. This is in addition to existing internal reporting mechanisms we have in place to escalate issues which have been identified.

Reporting: SCI’s Modern Slavery and Human Trafficking Policy encourages suspicions and concerns to be reported through its procedures. Concerns involving children may also be reported through our child safeguarding reporting mechanism. Reports are monitored by our dedicated Child Safeguarding team and appropriate action is taken against perpetrators. The corrective action will be determined according to the details of the case, and may include suspension or termination of our arrangement with a partner/supplier, referrals to police, working with the local community, and disciplinary action taken against involvement of any SCI staff member. SCI has recently introduced new software to make reporting more accessible to staff and improve monitoring of cases from start to finish. This software currently enables modern slavery concerns to be reported through limited categories of child safeguarding or fraud. We are currently exploring how to integrate modern slavery/human trafficking into the reporting mechanism through the software, alongside other changes being made to the system to improve the breadth of what the reporting software captures. We are also considering ways of using the data outcomes from the software to more robustly conduct trend analyses and future incident prevention. In 2018, our global Whistleblowing policy and procedure was revised, with the rollout scheduled to take place this year. Whilst we currently have local whistleblowing hotlines in some high risk areas, SCI is now introducing a global whistleblowing hotline. These measures should facilitate increased reporting across the organisation.

(iii) Awareness and training

Staff: Modern slavery training is integrated into two of our mandatory new starter training courses:

(a) Mandatory global online human resources induction for new starters. This is accessible by our staff across the world and explains what modern slavery is, how staff might spot it, SCI’s policy and how to report any suspected incidents. SCI started to roll out ‘in person’ human resources inductions across the organisation in 2018, which clarify and reinforce that both completion of the global induction and adherence to the Modern Slavery and Human Trafficking Policy are mandatory. It is hoped that these completion figures will rise as a result.

(b) Mandatory Child Safeguarding Training. Preventing the exploitation and abuse of children is central to our organisation’s aims and our mandatory ‘in person’ Child Safeguarding training previously indirectly addressed the issue of modern slavery and trafficking of children. In 2018, we refreshed our inperson interactive training, which now includes enhanced information about modern slavery, including its prevalence, how it may be detected and reported. This revised training is delivered at our headquarters. This has also been shared globally with our child-safeguarding leads across the organisation, who adapt the training according to the specific requirements and needs in the regions and countries they oversee. Modern slavery information is also being incorporated into other safeguarding trainings for teams across the organisation (such as our supply chain, safety and security specialist and humanitarian teams), and in additional humanitarian training.

In addition, Safeguarding training, which is being rolled out to our procurement teams globally in 2019 and includes information on modern slavery, encourages our country and regional offices to consider safeguarding risks in their own contexts and how these should be addressed.

Suppliers: With over 100,000 suppliers globally, it is not feasible to have a centralised training programme for all our suppliers across our supply chain. Our country and regional offices identify risks arising through their supplier due diligence work that they engage in, and provide support and clarification where needed on modern slavery to suppliers. We also engage with suppliers on a case-by-case basis to address queries regarding our contractual requirements (including with regard to our mandatory Modern Slavery policy). SCI provides training to suppliers in some contexts, and this is determined at the local level. SCI recently delivered training to suppliers in Bangladesh (where over 400 people were present) and Nepal, for example.

Partners: Our International Safeguarding team is incorporating information on modern slavery into our partner safeguarding training.

D: MEASURING OUR EFFECTIVENESS

In last year’s statement, information on measuring SCI’s effectiveness in ensuring that modern slavery and human trafficking is not taking place in its supply chains was integrated throughout the statement. For clarity, we have set this out separately in this years’ statement.

E. Our commitments

SCI is committed to the continuing evaluation of our systems and processes to ensure that we can better raise awareness of, prevent, report and respond to issues of modern slavery across the organisation.

Some of the actions which SCI will be taking in 2019 include:

• Strengthening existing processes and tools to ensure that modern slavery aspects are addressed more robustly, including:

- A further review of modern slavery risks within our business to assess where our current approach can be strenghtened;

- Enhancing our existing local and global whistleblowing mechanisms, including the  roll out of an updated whistleblowing policy and procedure;

- Enhancing SCI’s procurement manual to provide more information to our local teams about modern slavery, including how to identify, report and ultimately prevent such risks within the supply chain;

- Strengthening aspects of the new risk assessment template for humanitarian emergencies to incorporate modern slavery elements. 

- Developing the post-humanitarian crisis control review to incorporate modern slavery and human trafficking considerations more robustly.

• The development of a global on-boarding process for SCI’s contractors and volunteers, which ensures that such workers sign off on SCI’s mandatory policies (including the Modern Slavery and Human Trafficking policy) and complete SCI’s mandatory training. 
• An increased focus on safeguarding generally, including staff training and expanded policies.
• The development of a framework agreement to be used for recruitment agencies in the UK (with a view to global use in the future), in which SCI’s Modern Slavery and Human Trafficking Policy is embedded as a mandatory policy.
• Continuing to roll out SCI’s Procurement Policy and accompanying procurement manual globally.
• The staged introduction of a global platform to manage supply contracts, which should enable SCI to ensure that its contracts with organisations comply with its mandatory policies (including Modern Slavery and Human Trafficking).
• Considering more effective performance indicators to measure effectiveness of measures to mitigate the risk of modern slavery in our supply chain. 
• Continued delivery of child safeguarding training and guidelines to SCI’s supply chain staff globally, which incorporates information on modern slavery, helping local teams to identify and address risk areas in their contexts and providing awareness of existing tools and how to use them. Going forward, introducing country-specific requirements regarding training suppliers.
• Roll out of comprehensive risk guidance and a new safeguarding risk tool which further improves our prevention work around exploitation and abuse.
• Continuing to roll out the new risk assessment template for humanitarian emergencies.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes SCI’s slavery and human trafficking statement for the financial year ending 31 December 2018. It was approved by the Board of Save the Children International on 31 May 2019, and published on SCI’s website on 13th June 2019.

Pernille Lopez

Interim Chair of the Board

Save the Children International

31 May 2019