MODERN SLAVERY STATEMENT 2019

Save the Children welcomed the introduction of the UK Modern Slavery Act 2015 as it is consistent with SCI’s own values and missions in the work that it does. Since the introduction of the Act in 2015, SCI has undertaken a number of initiatives internally to implement this prevention work across in our supply chain, partners and across our business and has also worked with communities to drive change.

Examples of our work with communities include a number of Save the Children projects aimed at preventing and responding to child trafficking across the globe, with notable examples in Italy, Sri Lanka, Mozambique, Central America and West Africa. These programmes typically include the following core components:

• Training of law enforcement officers and social welfare workers to identify, interview and provide appropriate care to child victims of trafficking;
• Supporting the recovery and rehabilitation of child victims through information, mental health and psychosocial support and counselling, and reintegration into education, training and employment opportunities; undertaking family tracing and reunification;
• Providing support to families to prevent (re) trafficking, through economic strengthening and raising awareness; and
• Working with governments to strengthen their systems, legal frameworks and policies to prevent and respond to trafficking, including advocacy to ensure appropriate care and deinstitutionalization of child victims.

Save the Children also works on child protection issues within supply chains, including child labour. In 2019 programming in Bangladesh, India, Indonesia, Madagascar, Sri Lanka and Vietnam included this work. An example from Sri Lanka is Save the Children’s work with tea plantation companies to encourage the voluntarily adoption of a child protection policy. Five companies have voluntarily adopted a policy of 10 standards, one of which is that “no child below that age of 16 engages in paid or unpaid labour, and no child between ages 16 and 18 years engages in hazardous occupations, in accordance with Sri Lankan laws and regulations”.

As a global movement Save the Children is made up of 27 Members (national organisations) and 3 Associate Members, each of which is a member of the movement’s central body, 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 in-country teams working on the ground. SCI is a UK charity and company limited by guarantee, headquartered in London and functioning through SCI’s network of 5 regional offices and 56 country offices operating in 75 geographical territories. 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 27 National Members and 3 Associate Members, SCI worked in 117 countries in 2019 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 15,500 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.

The scale of SCI’s supply chain operations is underlined by our Supply Chain Key Statistics:

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

At least 80% of SCI’s procurement is sourced in-country by SCI’s 56 country offices. SCI recognises the risk of modern slavery in these countries and  takes this very seriously. SCI is currently developing an online global procurement platform, to automate many source-to-pay procedures, and its local, in country, procurement systems across the organisation will gradually be transitioned onto this global IT system. The prospective platform aims to simplify procurement procedures enabling greater visibility over SCI’s supply chain and enabling increased compliance.

(iii) SCI’s partnerships

SCI delivers approximately 18-19 % of its portfolio through partners. These are often local not-for-profit 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.

(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 operations 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, Protection from Sexual Exploitation and Abuse Policy and Anti-Harassment and Bullying Policy. In 2019 SCI started the development of an e-learning module on Modern Slavery Awareness. The rollout for this module had planned to be the latter half of 2020, but the timing of its rollout is now dependent on the status of the progress of the Covid-19 pandemic and its impact on SCI’s operations in countries around the world.

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.

In 2019 SCI developed a global on-boarding process for SCI’s contractors which ensures that such workers sign SCI’s mandatory policies (including the Modern Slavery and Human Trafficking policy) and complete SCI’s mandatory training prior to starting work with SCI.

We have also enhanced our existing local and global whistleblowing mechanisms, including the roll out of an updated whistleblowing policy and procedure. We now have a Global Whistleblowing Officer in place, who oversees the whistleblowing process, and have appointed staff members within our country offices to manage whistleblowing complaints at country office level.  We have several channels available for staff members who wish to make a whistleblowing complaint, including an internal incident reporting system and an external hotline, for those staff members who do not feel comfortable using our internal reporting channels.

(ii) Supply Chain and Partners

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 key 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 Protection from Sexual Exploitation and Abuse Policy, our Anti-Harassment, Intimidation and Bullying 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. 

In 2019, SCI has also enhanced its procurement manual, originally launched in 2018, 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. We have also continued to roll out SCI’s Procurement Policy alongside the enhanced manual. In January 2020, SCI deployed an updated version of Procurement Essentials, a functional training course, which includes enhanced sections on all SCI’s compliance standards, including Modern Slavery. This is a mandatory training course for all procurement staff, equipping staff with a compliance checklist to use when assessing suppliers, linking to SCI’s overall policy on 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.

In 2019 we developed 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.

Some of the other measures which SCI has in place include:

• Conducting vetting checks of prospective recruit before offer of employment given and a police and reference check prior to start date (double-stage process);
• 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;
• Checking, but not withholding, identity documents and rights to work documentation;
• Providing information on workers’ rights in a language they can understand;
• Not allowing: fines levied to be passed onto employees, for workers to be charged finders’ fees, and not deducting accommodation or transport costs from staff salaries.

SCI’s Supply Chain

In 2019, SCI began the staged introduction of a global IT platform to manage supply contracts, which should help SCI to ensure, globally, that its contracts with suppliers comply with its mandatory policies (including our policy on Modern Slavery and Human Trafficking).

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 in modern slavery

Risk assessments: In 2019 SCI rolled out comprehensive risk guidance and a new humanitarian safeguarding risk tool which further improves our prevention work around exploitation and abuse.  Our new risk assessment template for humanitarian responses was strengthened with modern slavery elements.

Child Safeguarding Tools: Our child safeguarding tools, which include risk assessments, training, and dedicated Child Safeguarding focal points in each SCI country office, are also supportive of an approach to identifying, preventing, reporting and following up with risks and incidents of modern slavery and human trafficking.

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. In our procedures, we apply a risk-based approach (with focus on modern slavery and human trafficking) to determine whether a visit is necessary. 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 databases record the vetting status of suppliers. Our vetting systems draw from a broad range of criminal records that are public as well as adverse media reports, which if public, would identify perpetrators. If the supplier does not pass our vetting process we will not work with the supplier.

Procurement manual updates: Updates to our procurement manual in 2019 included more detailed information about how to increase awareness, assess risk and report of modern slavery within SCI’s supply chain. This is in addition to existing internal reporting mechanisms we have in place to escalate issues that 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 and any concerns relating to sexual exploitation as defined in Anti-Harassment, Intimidation and Bullying Policy. Reports are monitored by the relevant teams 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 any SCI staff member involved.

(iii) Awareness and training

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, Protection from Sexual Exploitation and Abuse Policy and Anti-Harassment and Bullying Policy. In 2019 SCI started the development of an e-learning module on Modern Slavery Awareness. The rollout for this module had planned to be the latter half of 2020, but the timing of its rollout is now dependent on the status of the progress of the Covid-19 pandemic and its impact on SCI’s operations in countries around the world.

Details of training available to staff is set out throughout this statement and there is training still in development. The below figures provide information in relation to training conducted in 2019:

Mandatory child safeguarding training (incorporating modern slavery 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 issues of modern slavery and human trafficking in children. During 2019, 89% of SCI staff attended the mandatory child safeguarding training.

Mandatory global human resources online induction for new starters (incorporating elements of modern slavery) 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. During 2019, 67% of new starters completed the mandatory online induction.

If SCI receives any reports of child labour and modern slavery they are reported via SCI’s whistleblowing or safeguarding channels and dealt with appropriately at the local level. The SCI’s trustees and the Charity Commission are notified of any reports as appropriate. SCI anticipates that through the efforts being made to increase awareness of this issue amongst its staff, partners and suppliers, and the access to reporting mechanisms, modern slavery can be exposed and rooted out where it exists.

2019 was a year in which SCI committed to an increased focus on safeguarding generally, including staff training and expanded policies. Modern slavery information is incorporated into safeguarding trainings for teams across the organisation (such as our general induction training, supply chain, safety and security specialist and humanitarian teams) and in additional humanitarian training, for example our supply chain delivered child safeguarding training and guidelines to 170 supply chain staff across the globe. Going forward, we will be introducing country-specific requirements regarding training suppliers.

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.

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

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 2020 include:

• Strengthening existing processes and tools to ensure that modern slavery aspects are addressed more robustly.
• A sustained focus on safeguarding generally, including staff training and expanded policies.
• Continuing to roll out SCI’s Procurement Policy and accompanying procurement manual globally.
• The continued preparation for the roll-out 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).
• 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.
• Considering country-specific requirements regarding training suppliers.
• Embedding the use of comprehensive risk guidance and a new safeguarding risk tool that further improves our prevention work around exploitation and abuse.

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 2019. It was approved by the Board of Save the Children International on 26 May 2020, and published on SCI’s website on 26 June.