Corporate report

DLUHC modern slavery statement 2020 to 2021

Published 25 November 2021

Applies to England

Foreword from the Permanent Secretary

The Department for Levelling Up, Housing and Communities has an important role in addressing opportunities for all our country. Whilst this is a new department, much of our work continues to build on the approach we have taken to create community cohesion and integration, create the homes our communities need and work with local government.

As we go forward, I recognise the importance of our relationships with the wide range of organisations we work with to deliver our objectives. We have a leadership role to play in ensuring that all organisations we work with understand and drive forward change in our society.

Our modern slavery statement is being published to show our commitment as a department to play our part in addressing a significant abuse of people in not just UK but global society. We can do this not just by ensuring those that work with us undertake assessments of risks, but by showing to all our stakeholders that this matters to us.

We all have an important role to play to ensure we do all we can to address modern slavery. As a department, we will do more to ensure that we work with our suppliers to identify and address any modern slavery risks within our supply chains.

Our modern slavery statement highlights the work done to date to examine our high value contracts and sets out our plans to further strengthen our role to tackle modern slavery in supply chains.

Jeremy Pocklington
Permanent Secretary

Background

The UK government is committed to eradicating modern slavery from the domestic and global economy. Section 54 of the Modern Slavery Act 2015 established the UK as the first country in the world to require businesses to report on how they are tackling modern slavery in their organisation and supply chains.

In March 2020, the UK became the first country to publish a government modern slavery statement.

This is the Department for Levelling Up, Housing and Communities’ (DLUHC) first modern slavery statement.

1. Organisation structure and supply chains

Background on department’s function

The Department for Levelling Up, Housing and Communities (DLUHC) is a ministerial department that supports communities across the country to thrive, making them great places to live and work.

We are at the heart of the government’s agenda to level up all parts of the UK.

Our work includes investing in local areas to drive growth and jobs, delivering the homes our country needs, supporting our community and faith groups, and overseeing local government, planning, and building safety. We are supported by 12 agencies and public bodies, the largest being Homes England.

Reporting period and scope

This statement covers the reporting period 1 April 2020 to 31 March 2021. The scope of the report is the core department, and it covers actions already being taken to ensure modern slavery risks are identified and managed in our supply chains, as well as the actions we will take in the future.

Homes England, DLUHC’s largest Arm’s-Length Body (ALB), has produced its own statement.

Our structure to mitigate modern slavery in procurement

The responsibility for the preparation and publication of this statement resides with the Principal Accounting Officer, our Permanent Secretary, Jeremy Pocklington.

DLUHC has appointed its Commercial Director to be its Anti-Slavery Advocate. The role ensures the development of a strategy to identify and manage modern slavery risks in the department’s supply chain. They are responsible for the production of, and actions within, this statement. The Anti-Slavery Advocate will:

• act as an escalation point for the reporting of any risks or issues. They will lead actions if there are any allegations of modern slavery within DLUHC’s supply chains
• be a representative for the department at the strategic cross-government working group
• be responsible for influencing the culture of the department in its anti-modern slavery activities
• ensure that relevant knowledge, lessons learned, and key information is both delivered and disseminated appropriately

To support the Anti-Slavery Advocate DLUHC has appointed an Anti-Slavery Working Lead within the Commercial Directorate. Their role is to develop and embed DLUHC’s modern slavery policy, processes, guidance and templates within the department’s activities. They are a member of the cross-government Modern Slavery and Procurement Implementation Group.

DLUHC as an employer

At the end of financial year 2020/21 DLUHC had a resource of:

• 2,503 employees on permanent contracts (2,442 full-time equivalent)
• 165 staff on-fixed term contracts (160 full-time equivalent)
• 111 staff engaged as contingent labour primary via Crown Commercial Service frameworks

The staff report and data within the DLUHC annual report 2020 to 2021 provides further detail on the description and the nature of the labour force for the core department. At the end of 2020/21 DLUHC had 21 staff in the Government Commercial Function (GCF) including 12 Government Commercial Organisation (GCO) employees.

Our supply chains

The Commercial Directorate is responsible for the procurement of contracts worth £10,000 or more. This includes ensuring contracts deliver a wide range of commercial policy including social value, sustainability and economic growth, as well as tackling modern slavery.

Modern slavery risks are much higher in some contracts than others, and we have adopted a risk-based approach to reviewing our supply chain.

In 2020/21 we:

• awarded 142 contracts
• held 184 contracts with 153 suppliers
• spent £84 million through these contracts, of which 55% was via Crown Commercial Services (CCS) frameworks^{[footnote 1]}

80% of our spend is within 10 category areas

Category*	Total Spend FY 20/21
Consultancy	£16,043,541
Business Process Outsourcing Services	£15,236,527
IT Managed / Outsourced Services	£14,288,051
Financial	£8,113,119
Technical Services	£4,763,743
Contingent Labour	£4,158,960
Software	£2,882,873
Legal	£1,442,473
ICT Hardware	£1,151,633
ICT Services	£335,193
Total	£68,416,113

*Spend by the public sector on goods and services taken from the Office of Government Commerce’s Public Sector Procurement Expenditure Survey.

Procurement and contracts

Our contracts are categorised using a contract tiering tool^{[footnote 2]} which assesses contract value, service complexity and delivery risk. Based on this assessment our contracts are tiered as either Gold, Silver or Bronze.

On the 31 March 2021 we had the following contracts:

• 9 Gold
• 74 Silver
• 101 Bronze

We have reviewed our areas of spend and concluded that 88% of our spend has a low risk of modern slavery occurrence. This review considered:

• the known risks within each sector/industry
• work force information
• supplier base location

A high proportion of our contracts are let to address specific short-term needs. This commonly involves specialist skills to undertake research or to develop digital systems. These tend to be of short duration and involve UK based highly qualified people and organisations. The risk of modern slavery within such environments is low.

2. Policies in relation to modern slavery

This section sets out DLUHC’s policies to prevent modern slavery in our operations and supply chains and how we identify and mitigate modern slavery risks throughout the commercial life cycle.

Responsible employment practices

Child labour shall not be used: we do not employ anyone under the age of 16, although occasional placements (usually lasting 2 weeks) for school pupils may also be accepted.

Living wages are paid: our lowest paid salary range is above the living wage. The salary range for our internships is also higher than the living wage.

Regular employment is provided: all our employment contracts have an adequate notice period.

Whistleblowing support: we provide an independent confidential whistleblowing helpline through our departmental EAP. This is available to staff 24 hours a day for issues such as unsafe working practices, harassment and bullying.

How we buy goods and services

Our Commercial Directorate is responsible for the procurement of goods and services valued at £10,000 or higher including the application of relevant government procurement policies.

We have taken the following steps to tackle modern slavery:

• adopted the Cabinet Office suite of model services contracts. These include terms and conditions which enable us to address risks of modern slavery
• incorporated the Modern Slavery Prioritisation Tool (MSPT)^{[footnote 3]} into our commercial processes
• delivered modern slavery awareness training for procurement, contract managers and policy staff

The relevant cross-government legislation and policies that support mitigating modern slavery are further detailed in p7-9 of the government modern slavery statement.

3. Risk assessment and due diligence

This section describes the modern slavery due diligence we have undertaken and how we are implementing and incentivising responsible business practices to protect workers in our supply chains. This section also details our understanding of the most significant modern slavery risks facing our department and where we are prioritising action.

Approach to prioritising anti-slavery activity

The Cabinet Office guidance Tackling Modern Slavery in Government Supply Chains - A Guide for Commercial and Procurement Professionals has informed our risk-based and proportionate approach to assessing our supply chain risk to modern slavery.

Within the reporting period we focused our risk assessment on procurements and existing contracts that were considered ‘Gold’ within our tiering system.

Findings

We used the MSPT to undertake an initial risk assessment.

8 of our 9 gold contracts were assessed as a low risk of modern slavery occurrence. This reflects the nature of the goods and services we buy and the location of the suppliers we use for our high value contracts.

The contract for the principal contractor for managing the Grenfell Tower Site was rated as medium risk. The contractor has published a Transparency in Supply Chain statement (TISC). Due to the short period of time remaining on the contract and the imminent new contract for this service, the supplier was not asked to complete the Modern Slavery Assessment Tool (MSAT). This contract has recently been replaced and a MSAT will be completed by the new supplier within 3 months of contract commencement.

Future assessments and strengthening the approach

In the next reporting period we will extend our initial risk assessment process and the use of the MSPT to include all existing contracts valued at £5 million or more. Where our initial assessment identifies a high or medium risk the supplier will be invited to complete a full modern slavery assessment (using the MSAT). Where this assessment indicates a high risk, further follow-up analysis and discussions will be held.

Improvement plans will be agreed to ensure that known risks are mitigated and monitored throughout the contract lifetime.

For all new procurements with contract requirements valued at £5 million or more, the MSPT will be completed early in our engagement with potential suppliers. This will highlight any potential modern slavery risks to these suppliers and the requirement to reduce or mitigate these.

Where it is identified that the supply chain for a new product or service is of high or medium risk of modern slavery, we will consider inclusion of anti-slavery activities within the tender evaluation under the Social Value within Public Procurement policy.

For all new contracts tiered Gold or valued at £5 million or more and rated as medium or high risk of modern slavery, a supply chain map^{[footnote 4]} up to tier 2 will be obtained within 3 months of contract commencement.

Contracts will require these suppliers to either complete a MSAT within 3 months of contract award or provide existing assessments and action plans. Action plans to address potential risks will be agreed between the supplier and the department and regularly reviewed for progress throughout the contract life.

We are exploring options to embed the prioritisation tool and associated risk rating (high, medium, or low) into our e-procurement system with a prompt to support compliance management.

A central risk register will be created, maintained, and overseen by the Anti-Slavery Working Lead and reviewed quarterly with the Anti-Slavery Advocate.

Broader commercial policies to support responsible purchasing practices

DLUHC publishes their prompt payment data. It details the percentage of invoices paid within 5 days and within 30 days of receipt by quarter. DLUHC follows the government commitment to pay 90% of undisputed and valid invoices from small and medium-sized enterprises (SMEs) within 5 days and 100% of all undisputed and valid invoices within 30 days. Data on our payment performance can be found here.

DLUHC complies with the PPN 07/20 regarding a bidder’s approach to payment in its procurement of major contracts. The standard selection questions have been included for competitive tendering and terms are included into our model contract, which also require 30 day payment terms through these supply chains.

4. Training and awareness raising

This section describes the training we have delivered to staff to build their capability to identify and address modern slavery risks.

We delivered in-house training to commercial staff within DLUHC to:

• raise awareness and understanding of modern slavery, including the various types of slavery that exist and how they can occur
• understand what this means for DLUHC procurement, commercial and wider departmental staff
• implement and embed the legislation and procurement policy with which DLUHC and its supply chains need to comply
• identify and manage modern slavery risks in both existing contracts and new procurement activity
• identify issues and ensure that suspected instances of modern slavery are handled correctly

Annual Ethical eLearning by the Chartered Institute of Procurement & Supply (CIPS) is mandatory for commercial and procurement staff to improve their understanding of how to mitigate against risks of modern slavery in our supply chains.

90% of Gold contract managers have received one to one training. They were trained on how to use the MSPT and to carry out the assessment of their contracts.

Our anti-slavery advocate, the Commercial Director, has been inducted into the role. They are aware of the responsibility to oversee the production of the annual modern slavery statement and attend regular meetings to keep informed and develop strategies to prevent modern slavery.

Our modern slavery working lead attends cross government meetings hosted by the Home Office. They contribute to and receive best practice, training, tools and guidance to support our work to tackle modern slavery risks in our supply chains.

The ‘Social Value for Commercial Success’ mandatory eLearning module supports the implementation of this policy. DLUHC selects from a list of ‘social value’ policy outcomes, including reducing modern slavery risks, where relevant to the contract. Delivery is measured against standard metrics, to be used for both contract management and impact reporting.

The department hosted a training event on social value attended by commercial and policy staff from DLUHC, Homes England and the Planning Inspectorate, aimed at raising awareness across these organisations.

5. Goals and key performance indicators (KPIs)

The following KPIs have been developed to tackle modern slavery in our operations and supply chains. We will report on them in our next statement.

Training and commercial capability

KPI 1 – MSAT training to be available to Business Contract Managers / Procurement Leads every 6 months.

KPI 2 – To be completed by 31 March 2022:

• 80% of the procurement delivery team to have undertaken the annual CIPS Ethical Procurement and Supply e-Learning (or recommended equivalent).
• 80% of CIPS qualified staff to have achieved chartered status.

Risk assessment and management

KPI 3 – MSPT to be completed for:

• 90% of existing contracts tiered gold, or valued at £5 million or more, and with more than 6 months remaining.
• 100%^{[footnote 5]} of new procurements tiered gold or valued at £5 million or more.

KPI 4 – A supply chain map to be obtained for:

• 100% of all new procurements tiered gold, or valued at £5 million or more, and rated as medium or high risk of modern slavery, within 3 months of contract commencement.
• 60% of existing contracts tiered gold, or valued at £5 million or more, and rated as medium or high risk of modern slavery, with more than 6 months remaining on 31 March 2022.

Due diligence processes

KPI 5 – A Modern Slavery Assessment Tool (MSAT) record to exist for:

• 80% of all new procurements tiered gold or valued £5 million or more where the MSPT identifies a medium or high risk of modern slavery within 3 months of contract award.
• 60% of contracts tiered gold or valued at £5 million or more and with 6 months or more remaining where the MSPT identifies a medium or high risk of modern slavery on 31 March 2022.

KPI 6 – Risk management action plans to exist for 90% of MSAT entries by 31 March 2022.

Goals for DLUHC

DLUHC will continue to review and improve the processes and systems to tackle modern slavery in our supply chains and ensure our procurement policies comply with PPN 06/20. We will use our key performance indicators to identify additional areas to improve.

Our progress is set out below. All outstanding goals will be monitored and completed during the reporting year 2021/22.

	Goal	Progress
1	Appoint an anti-slavery advocate at director level to help oversee activity and increase awareness of the actions to take.	Complete
2	Develop KPIs to help us understand whether the action we are taking is working well and where we need to improve.	Complete
3	Review, and where relevant, amend procurement policies following publication of PPN 05/19.	Complete
4	Begin or continue contract risk assessments to ensure action plans are targeted.	In progress
5	Invite all major suppliers in medium or high-risk areas to complete the MSAT with follow up meetings to help better understand the anti-slavery activity they should be undertaking.	In progress
6	Begin mapping our tier 2 suppliers for their high-risk supply chains.	In progress. This goal will be managed in line with KPI 4 above
7	Participate in training (to build capacity internally) and cross government working groups to collaborate on areas of common interest.	Complete

This statement has been approved by:

• Eddie Hughes MP, Corporate Minister, 6/10/2021
• Jeremy Pocklington, Accounting Officer, 30/09/2021
• Matt Thurstan, Chief Financial Officer, 24/09/2021

1. Crown Commercial Services (CCS) helps public and third sector buyers in the UK with billions of pounds of spending each year. ↩

2. DLUHC use a Contract Tiering Tool which informs the classification of the contract (gold / silver / bronze) by assessing 3 criteria: value, complexity and level of risk. This tool informs the criticality and level of contract management required which would include modern slavery risk. ↩

3. A tool designed by the Home Office to undertake initial assessments of modern slavery risks on contracts. ↩

4. The supply chain map will be for the specific goods and services being delivered by the contract. ↩

5. This is not required for construction contracts as this is a known area of high risk. ↩