Defra group modern slavery statement 2020 to 2021

Q: Related documents

The following documents relate to modern slavery UK Government modern slavery statement Home Office modern slavery guidance

Q: Signatories

Minister: George Eustice, Secretary of State for Environment, Food and Rural Affairs Date Approved: 30 September 2021 Executive Committee and Accounting Officer: Tamara Finkelstein, Permanent Secretary Date Approved: 13 September 2021 The Defra group is grateful for Defra ALBs' assistance in preparing this modern slavery Statement. This combined modern slavery statement is signed by the relevant ALB director on behalf of their organisation only as far as the information included relates to their respective organisation. Environment Agency: Phil Lodge, Director Organisational Services Animal & Plant Health Agency: APHA 's DLT Marine Management Organisation: Senior Management team Natural England: NExCo Rural Payments Agency: Senior Management team

Question 1

Foreword from the Permanent Secretary

Accepted Answer

This is the Defra group's first Modern slavery and human trafficking statement and aims to build a solid foundation for future years.

This statement has been prepared by the Department for Environment, Food and Rural Affairs (Defra) group Commercial (DgC) team on behalf of Defra, Environment Agency, Marine Management Organisation(MMO), Animal & Plant Health Agency (APHA) and Natural England, for the period ending 31 March 2021.

The Defra group is a significant buyer of goods, services and works and has an important role to play in addressing the risk of modern slavery within its supply chain.

This statement details our assessment of these risks, progress on mitigation made so far, and provides examples of good practice across the Defra group aiming to undermine those who seek to impose modern slavery on the world's most vulnerable.

The Defra group's nominated modern slavery advocate is the Defra group commercial director who is responsible for ensuring that the risk of modern slavery is minimised in the commercial activity undertaken by the group.

The modern slavery advocate is committed to work closely with contract owners and supplier managers across the Defra group to assess and support them in mitigation of modern slavery related risks in the contracts they own.

The Defra group is committed in its efforts to fight modern slavery, and we have set ourselves key goals to achieve and report against in the next period. These goals will be monitored on an annual basis by the modern slavery advocate to add pace to the implementation of the actions outlined.

This is in addition to continuing to work closely with our suppliers to use our combined abilities to support the eradication of modern slavery.

Tamara Finkelstein

Permanent Secretary

Question 2

Section 1: the Defra group's structure, organisation and supply chains

Accepted Answer

Background

Defra is the UK government's department responsible for safeguarding our natural environment, supporting our world-leading food and farming industry, and sustaining a thriving rural economy.

Our broad remit means we play a major role in people's day-to-day life, from the food we eat, and the air we breathe, to the water we drink.

About the Defra group

The Defra group has around 27,000 staff. Although the Defra group only works directly in England, it works closely with the devolved administrations in Wales, Scotland, and Northern Ireland, and leads on negotiations with the EU and internationally.

Working with our Arm's Length Bodies (ALBs)

The Defra group commercial team manages commercial services for the following parts of the Defra group:

We provide commercial advice for wider parts of the Defra group but are not directly involved in the management of their commercial activity and supply chains. Accordingly, this statement covers the organisations above.

Defra group annual spend

In the financial year 2020 to 2021, the department spent approximately £1.7 billion buying goods and services from suppliers.

Departmental spend over the past three years has increased by 30%, while the number of suppliers has decreased by 12% in alignment with our departmental commercial strategy

Table 1: breakdown of Defra's total annual supplier spend

Key Performance Indicator (KPI)	2018 to 2019	2019 to 2020	2020 to 2021
Defra total supplier spend	£1.3 billion	£1.3 billion	£1.7 billion
Spend with top 10 suppliers	39%	36%	38%
Number of suppliers	23,255	24,408	20,302
Annual spend with Small-Medium Suppliers (SMEs)	26%	26.5%	24.5%

Figure 1: split of annual contractual spend (£1.7 Billion) by organisation

ALB	Percentage split of overall group spend
Environment agency	47%
Core Defra	41%
Other	6%
Animal and Plant Health Agency	3%
Rural Payments Agency	1%
Natural England	1%
Marine Management Organisation	1%

Goods and services bought by the Defra group

The Defra group buys a range of goods, services, and works which are detailed under the category headings below:

Technology purchases

service infrastructure including services for hosting and data centres, connectivity of our networks and telecoms and mobiles
service operations including digital workplace, managed print, software, security products and services and IT equipment and hardware
business applications including application development and maintenance

Environmental goods and services

evidence, research, and environmental equipment including environmental surveying, monitoring, research, and services
land use and biodiversity technical services including expert advice and associated operational services
veterinary, animal, plant and laboratory goods and services including disease prevention and control services, laboratory consumables and equipment, laboratory maintenance services, laboratory testing services, grants, and grants-based procurement

Corporate services

professional services including management consultancy (business and technology) and finance and legal services
workforce including permanent recruitment, temporary agency labour and contingent labour
corporate solutions include travel services, conferencing and events, marketing services, postal goods and services, office supplies, vehicle lease and fleet management, insurance and related services and occupational health and employee assistance

These purchases include science building construction and services, office building services, facilities management (utilities, catering, furniture) and general refurbishment and minor construction

Infrastructure (construction) purchases

The Defra group's regional flood and coastal defences infrastructure related contracts including construction, civil engineering, and operational maintenance

Question 3

Section 2: modern slavery policies

Accepted Answer

Implementation of the Modern Slavery Procurement Policy Note (PPN) 05/19

Defra group has fully implemented PPN 05/19 within its procurement processes and documents, building upon our existing approach to the management of human rights risks. Examples of the processes implemented include:

in 2021, an assessment was undertaken by DgC of potential modern slavery risks for the departmental top existing contracts, following the best practice methodology. Risks were assessed and, where relevant, actions plans agreed with relevant contract managers and suppliers. For details of the modern slavery risk assessment conducted, see Appendix A
the Defra group standard contractual terms and conditions, used in our contracts and procurements, have been updated to include clauses to monitor and protect against modern slavery risks and will continue to be reviewed
where relevant and proportionate to the contract, procurements now include modern slavery questions as part of the tendering evaluation process
these are included in addition to the mandatory pre-qualification questions within the standard supplier selection questionnaire (SQQ). These example questions where relevant, are evaluated in our tender process:
- please explain your proposed approach to managing the requirements of this contract or framework relating to the Modern Slavery Act 2015, compliance with employment legislation, staff pay, training and working conditions for your organisation and within your supply chain generally
- if you are using subcontractors, detail how you will ensure that these standards, processes, and systems are applied consistently, and subcontractor performance is appropriately managed
Defra now requires winning bidders for major procurements, rated as medium or high risk of modern slavery, to complete a Modern Slavery Assessment (MSAT) questionnaire so that ongoing improvement can be monitored

These tools and processes have been promoted across the Defra group via communications in the form of e-bulletins, newsletters, and training sessions.

Commercial professionals have been directed to a wide array of resources that are available to aid understanding and use of PPN 05/19 throughout the commercial lifecycle.

Examples of good practice in Defra

Policies and procedures

The Environment Agency employment policy is committed to ensuring that workers employed within its supply chains are treated fairly, humanely, and equitably.

The employment policy expects the contractor to share this commitment and to understand any areas of risk associated with this and work to ensure they are meeting International Labour Standards. Within the policy there is a requirement that the Contractor ensures that it and its sub-contractors and its supply chain:

comply with all relevant legislation relating to the employment of non-EU workers.
comply with the provisions of the Modern Slavery Act 2015
pay staff fair wages (and pays its staff in the UK not less than the foundation living wage rate)
implement fair shift arrangements and other best practices for staff welfare and performance
partnering with the Responsible Business Alliance formerly known as Electronic Industry Citizenship Coalition to ensure that suppliers within the technology category are compliant and supported
setting up a coalition made of suppliers within our supply chain (Defra e-sustainability alliance) to share best practice

Environment Agency staff routinely pass intelligence to the police where we suspect modern slavery may be taking place on sites, we visit
take part in multi-agency days of action with the police and other partners to disrupt criminality including modern slavery at sites who are operating illegally
frequently work with partners to raise the profile and awareness of modern slavery

Internal communications

These resources have been made available to Environment Agency staff:

eMission2030 - is the Environment Agency's sustainability plan and implementing this is one of the key aims of EA2025 – the Environment Agency's current business plan.

Specifically, the plan states: 'Ensure that the people we employ, and those in our supply chain, are paid a real living wage, have good working conditions and are protected from modern slavery'.

Two key outcomes of the plan are:

2022 target: we will be 100 per cent transparent on the high-risk areas in our supply chain and the action we will take to improve and protect the working conditions and rights of our supply chain.
2024 target: to become an accredited Real Living Wage organisation

Training

working with police and enforcement agencies to eradicate modern day slavery from the waste and recycling industry. Hope for Justice trained over a hundred waste and regulation Environment Agency officers in recognising exploitative work practices
developing bespoke awareness and disruption training for Environment Agency staff
contributed to the National Enforcement Powers guide. Which aims to offer support to our law enforcement partners who may encounter or investigate modern slavery. It is designed to facilitate a faster multi-agency tactical response and provide awareness of the legislation partner agencies use

Vehicle lease contracts

When procuring the new Vehicle Leasing contract, sustainability accounted for 25% of the total quality score assigned when evaluating supplier bids. Of this 10% of the weighting was allocated to people and the community which included modern slavery awareness.

Supplier engagement days emphasised our expectations regarding modern slavery, Fair Working Conditions, and the Real Living Wage. The awarded framework arrangement had modern slavery clauses included within the call-off contract documentation.

Construction contracts

For the Thames Estuary 2100 contract valued at £308 million across a 10 year term, we are always working on continuous improvement of its sustainability performance.

This includes piloting an approach on this programme that requires a percentage by value of materials used in construction task orders to have an Ethical Stone Register or Cradle to Cradle® Certification to a minimum level of Bronze.

The social fairness requirements for Bronze certification includes the following:

human rights risks are assessed for the applicant company, final manufacturing stage, and direct suppliers to the final manufacturing stage (tier 1). Progress is made on assessing risks beyond tier 1 (such as tier 2 and beyond)
a human rights policy based on international human rights standards and an understanding of the company's risk areas is in place
a strategy for implementing the human rights policy is developed. At recertification, progress toward achieving the strategy is measured
for the applicant company and final manufacturing stage facilities, performance against the human rights policy is measured and corrective actions for select issues (for example, child labour, forced labour) are complete.

Corrective actions are planned for any other poor performance issues and, at recertification, progress is demonstrated

Pension Fund

The Environment Agency Pension Fund has assets of approximately £4.5 billion. These are managed in large part through the Brunel Pension Partnership.

As part of the investment selection process, the Brunel Pension Partnership expects our fund managers to be aware of, and supportive of, combating violations of human rights.

We expect companies to comply with all legal requirements and the duty to respect all internationally recognised human rights, including the obligations of the Modern Slavery Act in the UK and the United Nations Guiding Principles(UNGPs) on Business Human Rights (PDF).

Brunel use several data sources to monitor the underlying companies within our portfolios for human rights and supply chain standards as well as compliance with the United Nations Global Compact Principles.

In addition, as part of Brunel's approach to stewardship we support several engagement initiatives that encourage businesses to prioritise strong governance mechanisms to eliminate modern human slavery.

Personal Protective Equipment (PPE) and corporate clothing contracts

The Defra group PPE and corporate clothing contract has potentially significant social and environmental impacts that occurs at all stages of its lifecycle. The global nature of clothing supply chains can make traceability and visibility of worker's rights, working conditions and pay difficult to achieve.

Managing the sustainability impacts of the Defra groups PPE and corporate clothing contract across the commercial lifecycle has been an integral part of the Defra groups procurement process. For example:

the tender attributed 30% of the total quality score to sustainability with 10% of the weighting allocated to transparency of the supply chain and working conditions
the tender documents included specific requirements relating to modern slavery such as supply chain mapping, management of risks, audits, and key performance indicators
the contract was awarded to an Ethical Trading Initiative member who demonstrated strong due diligence measures to uncover and address risks of labour exploitation
modern slavery forms a key part of contract management activity and includes increasing visibility of the supply chain, how the supplier is continuing to manage and address the risks and sharing of good practice

Question 4

Section 3: risk assessment and action plans

Accepted Answer

Modern slavery risk assessment and results

Modern slavery falls within the Defra group's wider management of sustainability risks and we manage this risk in line with our approach to the management of sustainability and social value.

The Defra groups suppliers have supply chains that are global, providing direct and indirect support to the delivery of requirements.

Due to the complexity of global supply chains, the Defra group does not have full transparency of its full supply chain and a risk-based approach has been taken to achieving greater supply chain visibility of potential modern slavery risks focusing on higher risk supply chain contracts.

In 2021, the Defra group reviewed its supply chain and has tiered all contracts using the UK Governments tiering tool. This tool assesses overall contract risk and value and categorises the contract as either gold, silver, or bronze, with the gold tier being the highest risk and value.

The gold and silver contracts represent circa 90% of the total spend with suppliers, and hence, is the focus of our analysis. The full breakdown of the contractual landscape is detailed in the table below.

Table 2: breakdown of the Defra group's contracts by risk and value-based Tier

Tier	Number of contracts	Total (value of contracts let)	Percentage of contracts
Gold	28	£4.6 billion	77.5%
Silver	695	£901 million	15.1%
Bronze	1284	£442 million	7.4%
Total	2007	£6 billion	100%

Note: the above does not contain grants, collaborative agreements, partnership agreements or Framework Records, unverified and un-tiered contracts

The desktop assessment of modern slavery risk highlighted that 61 Defra contracts delivered by a total of 40 suppliers carried a potential medium or high risk of modern slavery.

In order to better assess the potential risk, these 40 suppliers were sent a request to complete a Modern Slavery Assessment Tool (MSAT).

This focused approach accounts for around £3.5 billion of contracted spend. The 40 suppliers were primarily from 3 areas of spend, Construction (including Infrastructure and Buildings), Corporate Services and Technology.

Of the MSAT reports completed by suppliers, only 3 were assessed as potential high risk and relevant action plans were agreed with the suppliers.

This analysis showed that the lower scores were due to some limitations in their governance, management, and training arrangements within the 3 organisations. The nature of these limitations did not justify urgent action, but improvement actions will be discussed with these suppliers as part of existing contract management arrangements.

All MSAT supplier reports confirmed that no incidences of modern slavery had been encountered within their organisations or supply chains within the preceding 12 months.

The analysis of this supplier group supports the conclusion that there is a very low risk of modern slavery within the Defra group supply chain.

Improvement actions agreed with suppliers

Following the supplier completion of the MSAT, improvement actions have been identified for the small number of suppliers who had lower scores. Examples of the actions include:

consider carrying out the due diligence measures to ensure workers in the organisation and supply chain are not trapped in debt bondage
consider modern slavery during each stage of its procurement process
processes to be in place for responding to a report of suspected instances of modern slavery that follows good practice
assess the purchasing practices and how this could potentially put pressure on your suppliers, leading to modern slavery
consider undertaking activity that helps workers in your supply chains have access to representation
ensure modern slavery policies and codes include the provisions described in the guidance (contained in the supplier MSAT output report)

The above actions will form the basis of formal improvement plans with the supply chain, utilising the guidance contained within the MSAT reports. The full description for the improvement action is detailed within the respective supplier reports and will be monitored within our contract management process.

Risk Management Tool (RMT)

The Defra group's RMT is a key part of developing our procurement strategies and is used to identify and mitigate commercial and sustainability risks.

Modern slavery and wider human rights considerations form part of the sustainability section. An action plan to manage any risks identified across the commercial life cycle is developed and used throughout the procurement process.

For contracts that have been tiered as Gold or Silver, the RMT is used to identify any human rights risk. Then the High-Level Risk Assessment tool is used to grade the contract as low, medium, or high risk with respect to modern slavery.

For contracts that are graded as medium or high and are over 6 months in duration, the supplier must complete an MSAT questionnaire.

For a visual representation of how the risk management tool determines when the MSAT is required, please see flow diagram at Appendix A.

Participation in peer-learning groups and collaborative initiatives

Defra is fully engaged in a range of initiatives examples of which are:

the Defra group commercial team attend the Cabinet Office led Modern Slavery Process Implementation Group (MSPIG) aiming to influence, challenge, gain knowledge, and learn from others
our sustainable procurement specialists attend specific training day sessions on addressing modern slavery in the supply chain
training event details are shared with other sustainability experts within the wider business
senior management team members attend modern slavery advocates meetings

Responsible purchasing practices

Requirements that have been placed on suppliers are:

to make sure that payment delays cannot be used to exploit people throughout the supply chain, with prompt payment clauses included within Defra group terms and conditions and bidder packs. For further details of Defra's performance, read our performance report
that there are requirements for construction suppliers to be members of the supply chain school which gives access to a range of sustainability resources and events which also covers modern slavery

Supply chain responsible recruitment practices

Whilst the Defra group tries to make sure that its own recruitment practices are robust, care is taken to ensure that when awarding contracts, the supply chain are also implementing robust recruitment practices.

Table 3, below, highlights the specific actions the Defra group have taken to address modern slavery risks and issues in spend categories.

Table 3: spend categories and how we manage the related risks

Category	What is the issue?	What are we doing about it?
Construction (infrastructure and buildings)	- use of labour – payment challenges and use of sub-contractors - use of resources – scarcity of resources and their environmental impact - complex supply chains – differing legislation across global supply chains	- tenders that include a risk of modern slavery in the development of our frameworks and contract - specific requirements regarding recruitment and employment contracts are included in awarded contracts and designed to flow through the supply chain
Corporate services	- there is increased likelihood of modern slavery for contracts that are labour intensive and involve areas such as manufacturing for example, clothing - risks are not always directly linked to the contracted supplier but are contained further down the supply chain	- training in considering and managing the risk of modern slavery - undertake due diligence on commercial activity - ensure large companies share and promote their modern slavery statements - include liability within commercial contracts (where appropriate) on suppliers exercising the importance of managing modern slavery in the supply chain - seek as much information as possible on supply chains to support with wider due diligence on contracted suppliers and their supply chains - promote access to all involved in delivery of requirements to enable victims of modern slavery to access civil and criminal remedies or points of contact to detail the threat of modern slavery
Technology	- supply chains are global and, in many cases, remote to where the product is being delivered	- the Defra group's e-sustainability alliance aligning supplier standards and best practice - mandatory reporting on sources of minerals including country of origin for conflict minerals - complying with provisions of the Modern Slavery Act and Equality Act - implementation of fair shift arrangements, and other best practices for staff welfare and performance such as contained within the Responsible Business Alliance

Question 5

Section 4: training and awareness raising

Accepted Answer

Training and education efforts are focused on commercial staff due to their key role in identifying and mitigating modern slavery during the procurement process.

Improving awareness

To establish a baseline for understanding of the risks of modern slavery, a questionnaire was undertaken internally within the Defra group commercial team to gauge the level of awareness and understanding regarding modern slavery and the tools that can be employed to identify risks and obligations.

The response to the questionnaire demonstrated that there had been an improvement in awareness and understanding by commercial staff.

prior to the training 29% of commercial staff rated their knowledge of modern slavery as good. Following the training, 71% said their knowledge was good
prior to the training 14% of commercial staff rated their knowledge of MSAT as good. Following the training, 43% said their knowledge was good
prior to the training 14% of commercial staff rated their knowledge of the Defra groups obligations as Good. Following the training, 71% said their knowledge was good

To ensure that standards are maintained, the Defra group have made training sessions, guidance documents and process templates available so that they are accessible by commercial teams.

Staff training

Currently there are 242 Defra group employees including contingent labour working in the commercial function.

The Defra group has shared information regarding the Chartered Institute of Procurement & Supply (CIPS) Ethical training, and existing CIPS members are currently undergoing this training. We are seeking access to the CIPS Ethics training for non-CIPS members and encouraging completion of relevant modern slavery training.

Internal workshops have been held to help commercial staff understand what actions they need to take during the commercial lifecycle of a contract. This includes explanations of the high-level risk assessment to determine risk level of contracts as well as the requirement for winning bidders to complete the MSAT questionnaire so that ongoing improvement can be monitored.

The Defra groups members of staff have attended additional internal training events with more planned through the year.

Training and awareness has also been provided to our ALB Business Relation Manager (BRM) network. This aided the understanding regarding the use of the high-level risk assessment tool to identify suppliers to invite to complete the MSAT questionnaire.

The follow-on from this was the use of the supplier MSAT output reports to highlight the supplier position and any associated actions.

Question 6

Section 5: goals and next steps

Accepted Answer

The Defra group has looked for examples of best practice to measure the effectiveness of our policies and procedures. Over the course of the next 12 months, we propose to adopt the following approach to ensure there is continuous improvement across Defra group.

To strengthen how the Defra group tackles modern slavery and align our commitments, we will undertake the following actions:

Goal 1

Share good practice in regard to preventing and monitoring modern slavery with relevant ALBs and stakeholders as part of a continuous improvement programme.

Goal 2

To make sure members of the Defra group Commercial, complete mandatory training aligned to the management of modern slavery risk and encourage those who are involved in commercial activity across the wider Defra group to undertake similar training.

Goal 3

Contract Managers will work with relevant suppliers to address the improvement areas highlighted in their MSAT questionnaires. Results will be shared with DgC leadership.

Goal 4

Ongoing management of modern slavery via internal sustainability stakeholders.

Question 7

Environment Agency

The Environment Agency is an executive non-departmental public body, sponsored by Defra. We work to create better places for people and wildlife and support sustainable development. We were established in 1996 to protect and improve the environment. We have around 10,600 employees. Our head office is in Bristol and we have another office in London. We have offices across England, divided into 14 areas.

Read the Environment agencies annual report and accounts for more information.

Animal & Plant Health Agency

We work to safeguard animal and plant health for the benefit of people, the environment, and the economy. APHA is an executive agency, sponsored by the Department for Environment, Food & Rural Affairs, the Welsh Government and the Scottish Government.

Read the Animal Health & Plant Health Agencies annual report and accounts for more information.

Natural England

We're the government's adviser for the natural environment in England. We help to protect and restore our natural world. Natural England is an executive non-departmental public body, sponsored by the Department for Environment, Food & Rural Affairs.

Read Natural England’s annual report and accounts for more information.

Rural Payments Agency

The Rural Payments Agency (RPA) is an executive agency, sponsored by the Department for Environment, Food & Rural Affairs. We pay out over £2 billion each year to support a thriving farming and food sector.

Read the Rural Payment Agency’s annual report and accounts for more information.

Marine Management Organisation

The Marine Management Organisation (MMO) was created in 2009 by the Marine and Coastal Access Act. MMO is an executive non-departmental public body, sponsored by the Department for Environment, Food & Rural Affairs

Read the Marine Management Organisation’s annual report and accounts for more information.

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