Environment Agency modern slavery report 2022 to 2025
Updated 16 October 2025
Introduction
This report outlines the activities and progress made from September 2022 through to March 2025 to tackle modern slavery risks in the Environment Agency.
Modern slavery remains a key issue globally, including in the UK, taking the form of:
- forced labour
- debt bondage
- human trafficking
- other exploitative practices
The Environment Agency is a significant buyer of goods and services, some of which are considered as high risk. These include Personal Protective Equipment (PPE), cleaning services, construction and waste services). Our regulatory and incident response roles provide us with an opportunity to spot the signs of modern slavery whilst we are working on site in high-risk industries such as the waste, agricultural and construction sectors.
The Environment Agency is a member of Slave Free Alliance (SFA) which supports organisations and businesses globally to combat modern slavery. SFA has undertaken an independent analysis of Environment Agency activities which has helped us to focus modern slavery actions where they will have the most impact.
We are committed to identifying and addressing the risks within our business and supply chain. We are using the latest Home Office guidance to structure this modern slavery report into the following categories recommended under Section 54(5) of the Modern Slavery Act 2015:
- Organisational structure, business and supply chains.
- Organisational policies.
- Assessing and managing risk.
- Due diligence in relation to modern slavery (including approach to remediation).
- Training.
- Monitoring and evaluation (understanding and demonstrating effectiveness).
Section 1: Environment Agency structure, business and supply chains
About the Environment Agency
Our role
The Environment Agency is a regulator, operator, adviser, responder and research centre. It was established in 1996 by the Environment Act 1995 with the aim of protecting and improving the environment, taken as a whole, to contribute to sustainable development. With a workforce of over 12,000 employees, we operate as a non-departmental public body, sponsored by the Department for Environment, Food and Rural Affairs (Defra). Our remit primarily covers England, though our influence and collaboration with other UK environmental bodies and partners extends beyond England’s borders. Our 3 long-term goals set out in our 5-year corporate strategy EA2030 are:
- healthy air, land and water supporting nature’s recovery
- sustainable growth
- a nation resilient to climate change
Organisational structure
We have offices across England, divided into 14 operational areas. Six regional hubs manage our capital works programme. Our organisation is made up of 4 directorates, which report to our Chief Executive.
Due to the nature of our work and our large operational workforce, we are in a unique position to spot the signs of modern slavery, report our concerns and escalate them if we suspect worker exploitation or modern slavery.
Since 2023, we have had dedicated resource within our Sustainable Business team to manage modern slavery risks, response, communications and action planning.
Defra group Joint Services
In 2023, Defra established the Defra Joint Modern Slavery Project and Modern Slavery Steering Group, which was initiated to review joint services that are provided to several arm’s length bodies across Defra group including the Environment Agency. The services provided by Defra group include:
- Defra group Commercial (DgC): offers commercial advice to the Environment Agency but does not manage its supply chain or commercial operations
- Digital, Data, and Technology Services (DDTS): delivers IT and digital services across the group
- Defra group Shared Services (DgSg): manages HR and finance functions for the Environment Agency through Shared Services Connected Ltd (SSCL), ensuring quality and timely outcomes via agreed processes
As Defra’s largest arm’s length body, we play a key role in the Defra Joint Modern Slavery Project, where actions suited to a collective group-level approach are designed and delivered jointly. Issues that are more specific to an individual arm’s length body’s context are addressed by that organisation. Working together, the group is positioned to achieve more consistent and impactful outcomes than through separate initiatives.
Defra group Commercial have developed clauses for use in low value but high-risk contracts and are also advancing modern slavery prevention by:
- training commercial staff to recognise risks within procurement activity
- collaborating with suppliers to mitigate identified risks
- ensuring appropriate action and reporting when instances are uncovered
Environment Agency action
In August 2023, building on our ongoing efforts to address modern slavery, the Environment Agency became the first public sector organisation to partner with Slave-Free Alliance (SFA) – a social enterprise owned by the global anti-slavery charity Hope for Justice. SFA supports organisations in preventing exploitation, developing anti-slavery strategies, and assisting victims through rescue and support services.
This strengthens our capabilities and reflects our commitment to upholding human rights and tackling exploitation, trafficking, and forced labour.
As part of our membership, SFA conducted an independent gap analysis in March 2024 to help us better understand key modern slavery risks across our business and supply chain. This valuable assessment provided clear insights and actionable recommendations, shaping our 3-year Environment Agency Modern Slavery Action Plan.
The analysis identified priority areas where we could maximise our impact:
- procurement: enhancing visibility and strengthening influence over supplier due diligence throughout the procurement and contract management lifecycle
- governance: establishing a clear structure to manage modern slavery, labour exploitation, and broader human rights risks
- construction: addressing the challenges of outsourced, complex supply chains with a focus on transparency and risk management
- local operations: improving frontline awareness and escalation processes to better identify and report concerns in high-risk environments
We prioritised these findings based on impact, effort, and strategic value to shape a focused and phased approach. The following summarised priorities represent the foundations of our Action Plan for 2025 to 2028:
1. Organisational structure, its business and its supply chains
- set up and coordinate a cross-functional working group
- require Supply Chain Sustainability School (SCSS) membership for all new and renewed delivery partners
- integrate modern slavery awareness content into framework communications
- co-develop the Modern Slavery Maturity Tool with Defra
- engage with Defra Shared Services on modern slavery priorities
- review and update risk registers to reflect current modern slavery status
2. Organisational policies
- develop a comprehensive Modern Slavery Policy and escalation procedure
- update Whistleblowing Guidance to include labour exploitation
- align escalation procedures with Safeguarding Adults Policy
- develop a bespoke modern slavery training module relevant to our new Environment Agency procedure
- embed escalation protocols into key internal policies
3. Assessing and managing risk
- strengthen due diligence across questionnaires, contracts, and tenders
- co-develop targeted risk tools with Defra
- integrate modern slavery measures into framework renewals
- embed due diligence throughout the procurement lifecycle
- analyse data to uncover risk trends and reporting gaps
- improve processes using insights from lived experience
4. Due diligence in relation to modern slavery (including approach to remediation)
- strengthen supplier due diligence activity
- include strengthened due diligence requirements across all framework renewals
- launch escalation process with stakeholder input
- add modern slavery criteria to framework reporting
- integrate prevention measures into framework monitoring
- standardise due diligence practices across frameworks
- build reporting process arising from escalation process
- implement remediation steps for suspected cases
5. Training
- host training sessions with Framework Directors
- track Environment Agency completion of Defra Civil Service online training
- deliver escalation training to wellbeing advisors
- run lunch and learn events to raise awareness
- launch Spot the Signs virtual training module
- encourage uptake of Supply Chain Sustainability School (SCSS) training for staff and suppliers
- attend modern slavery conferences
- embed training into delivery partner onboarding
- promote peer learning through the Community of Practice
- embed role-specific training into our broader training programmes
6. Monitoring and evaluation (understanding and demonstrating effectiveness)
- provide quarterly updates to Strategy Transformation and Assurance Director
- refine escalation and reporting based on feedback
- monitor modern slavery metrics via procurement reporting
- track referral data to spot trends and strengthen response
- measure training uptake and awareness progress
- publish the Modern Slavery Report
- assess and improve framework performance
- evaluate delivery of social value through Defra frameworks
These actions will be tracked and monitored and may be subject to change in response to emerging risks. We will report our progress through our annual modern slavery report.
Delivery partners and suppliers
The built environment is exposed to modern slavery risks through a range of often-overlooked factors (SCSS, 2024) and organisations can be indirectly linked through their operations and supply chains. Our spend areas span the following categories:
- environmental goods and services
- infrastructure and construction
- buildings
- technology
- corporate solutions
Frameworks are used to manage environmental projects such as Flood and Coastal Erosion Risk Management (FCERM), Mapping and Modelling, Beach Management, Ecological Services, and Asset Operations, Monitoring and Response (AOMR). These frameworks typically involve a mix of large contractors, consultants and SMEs.
Key procurement risk drivers include:
- supplier selection – including their awareness and practices on modern slavery
- contract types – temporary, seasonal or heavily subcontracted arrangements
- purchasing behaviours – aggressive pricing, short lead times, late payments and other pressures down the value chain
We acknowledge that some of the goods, services, and works we procure carry a higher risk of modern slavery. We therefore identify and address these risks through procurement and contract management and follow relevant Procurement Policy guidance including PPN 05/19 and from February 2025 PPN 02/23 Tackling Modern Slavery in Government Supply Chains. All delivery partners are also required to demonstrate how they are actively minimising these risks within their workforce and supply chains.
We apply these controls through:
- tenders – bespoke modern slavery questions requiring evidence of prevention measures and statutory compliance
- frameworks – preapproved suppliers with agreed terms that reduce ad hoc subcontracting; all new and renewed frameworks include assessment, escalation and action planning requirements
- contract clauses – clear, proportionate obligations that require suppliers to prevent, detect, report and remediate modern slavery risks
The SFA recognised our Corporate Clothing and PPE Specification as an example of best practice in ethical procurement. Used across the Environment Agency and the wider Defra group, this outlines clear contractual requirements and reasonable, proportionate and necessary measures to address risk. This document also serves as a practical guide for suppliers.
Our Property Flood Resilience Framework is another example; setting out reporting requirements relating to modern slavery and human rights violations for delivery partners. This means that we are required to report and act against those requirements.
Other examples of supplier requirements include:
- prompt payment clauses to prevent payment delays being used to exploit workers
- Supply Chain Sustainability School membership to give suppliers access to modern slavery and sustainability resources
- scalable requirements in frameworks (for example AOMR) to ensure fairness and accessibility for SMEs; lessons from AOMR will inform future renewals
Case study 1: tackling modern slavery through the Asset Operation, Maintenance and Response (AOMR) Framework
This new framework has replaced the previous FCRM Operational Framework to strengthen how we manage and deliver operational flood and coastal risk services.
As part of the procurement process, we invited tenders from a range of suppliers and delivery partners, embedding sustainability and modern slavery considerations into both our selection criteria and contract clauses. This ensures our partners are:
- aligned with the Environment Agency’s values
- committed to reducing modern slavery and labour exploitation risks within their own operations and supply chains
To support continuous improvement, we have established the AOMR Sustainability Community of Practice, which meets quarterly to:
- share knowledge and experiences
- promote best practice in sustainability, modern slavery, and social value
- create a collaborative environment that encourages innovation and drives progress across the framework
We are also working closely with suppliers to build maturity in addressing modern slavery. We provide support and training throughout the framework term to strengthen capability and collective impact.
In the first year of the framework, we’ve seen encouraging signs of growing maturity –especially through the development of Modern Slavery action plans and reporting mechanisms. Notably, smaller delivery partner companies, many of whom were not previously expected to report on outcomes or progress, have begun to engage meaningfully with these responsibilities. This marks a significant step forward in embedding accountability and transparency across the full spectrum of delivery partners.
Section 2: Modern slavery policies, strategy
Environment Agency policies
Organisational policies are crucial for developing and maintaining anti-slavery standards across an organisation. When implemented correctly, they should influence staff and supplier decision-making and ensure that anti-slavery action is taken across the whole business and supply chain with monitoring, tracking and feedback processes in place.
For further information about the cross-government policies that Defra group apply – see the UK government modern slavery statement.
Employment policy for workers within our supply chain
The Environment Agency 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 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
- implement fair shift arrangements and other best practices for staff welfare and performance
- partner with the Responsible Business Alliance (formerly known as Electronic Industry Citizenship Coalition) to ensure that suppliers within the technology category are compliant and supported
- set up a coalition made of suppliers within our supply chain
- share best practice through the Defra e-sustainability alliance
The following policies apply to our staff within the Environment Agency:
Whistleblowing policy:
Allows our staff to raise concerns without fear of reprisal or unfair treatment. The policy includes ‘risk to the health, safety and wellbeing of an individual or a group of people’ as an example concern that employees and workers can raise confidentially. This includes commitments to protect people from modern slavery. The plan covers both our direct business activities and our supply chain.
Safeguarding children and young people policy
Ensures every child and young person has a right to equal protection from harm. We have worked with the NSPCC (National Society for the Prevention of Cruelty to Children) to establish new safeguarding policies to protect children and young people from harm and to outline the process if an allegation is made about one of our employees.
Human Resources (HR) operational guide
Provides specific and clear guidance on pre-employment for permanent, temporary and contract staff which provides rigor that will mitigate the risk of modern slavery in recruitment process. SFA considers this guidance as best practice as evidenced in our gap analysis.
ISO14001 accreditation
Our management system is certified to Environmental Management Systems Standard ISO14001. This is an internationally recognised standard for formal environmental management. One of our key objectives is to lead by example. We act according to best environmental practice and continually work to improve our own environmental performance. To do this, we identify our environmental aspects – elements of our activities or products or services that interact with the environment – and evaluate their significance.
One of our aspects is ‘procurement of goods and services across the Environment Agency’ which details our commitment to tackle modern slavery as part of a global effort.
In progress
We are working on a safeguarding at risk adults policy which includes identifying and reporting modern slavery and labour exploitation.
We are also developing specific guidance on how to uphold standards, recognise and respond to incidents of modern slavery and human rights infringements. The approach will set out an escalation procedure which will identify how to act and report on a suspected case of modern slavery and labour exploitation.
Section 3: Assessing and managing risk
Using tools and data to strengthen risk management
For strategic, higher-value procurements, we ask suppliers and delivery partners to use the Modern Slavery Assessment Tool (MSAT) developed by the Home Office. The MSAT helps public sector organisations and suppliers identify and assess their readiness to respond to modern slavery risks. While it is a useful starting point, we understand it has limits and does not reflect the real-world challenges and risks in supply chains.
We are actively engaging with a cross-government working group that is reviewing and refining the MSAT to improve its functionality and relevance. We support efforts to develop more tailored and sector-specific tools that enable buyers to make better-informed decisions and to follow up more effectively when risks are identified.
Currently, MSAT is used for high-risk contracts. To improve consistency, we are strengthening internal procedures to ensure risk identification becomes a standard early step in procurement.
In collaboration with the Defra Modern Slavery Steering Group, we’ve adapted the Modern Slavery Risk Prioritisation Tool (MSRP). The MSRP complements tools like the MSAT by offering a more tailored, data-driven approach to risk mapping – especially useful for strategic or high-risk contracts. It is available to both buyers and suppliers and links materials and goods to source countries to highlight relative risk.
We’ve also helped develop guidance to support risk assessments when purchasing solar panels. See case study 2.
Case study 2: addressing modern slavery labour exploitation in solar PV supply chains
As part of our sustainability plan, we are continuing to assess effective ways to deliver energy efficient options across our construction projects and our estate. In doing so, we have identified risks within the solar PV sector, particularly the production of polysilicon and critical minerals.
These risks include credible allegations of forced labour, including state-enforced labour in the Xinjiang Uyghur Autonomous Region (XUAR). To help address these risks, we co-funded and reviewed new guidance on tackling modern slavery and labour exploitation in the solar photovoltaic (PV) supply chain: Address modern slavery risks in solar PV supply chains
This highlights modern slavery across the solar PV lifecycle, from raw materials to installation.
The guidance gives procurement teams clear steps to follow to address these complex risks. It encourages going further than the UK Modern Slavery Act and connects with international standards, making sure our approach is aligned. Standards include:
- ISO 20400 (Sustainable Procurement)
- BS 25700 (Organisational Response to Modern Slavery)
- OECD Due Diligence Guidelines
- UN Guiding Principles on Business and Human Rights
This is a tool, and not a guarantee of zero exploitation. It works best when used in collaboration across sectors and supply chains with shared influence and responsibility. Industry groups like Solar Stewardship Initiative (SSI) are helping drive transparency and traceability. The guidance also references the work of the Responsible Minerals Initiative and the Solar Energy Industries Association (SEIA). These organisations are helping raise standards and accountability.
This work supports a fair transition to a low-carbon economy. It protects workers’ rights and addresses social and environmental impacts. This is especially important in vulnerable communities affected by mineral extraction and solar manufacturing.
The guidance was shortlisted for the Partnership Award at the 2025 Unseen Business Awards.
Section 4: due diligence in relation to modern slavery
We have carried out some targeted due diligence within selected frameworks to assess modern slavery risks, taking proactive action even where procurement responsibility sits elsewhere. While not yet applied uniformly, this work provides a firm foundation.
As part of our operational work, we also work with the police and local authorities regularly as well as the National Crime Agency. We regularly share intelligence, learnings and trends relating to modern slavery and exploitation incidents and risks.
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
- work with partners to raise the profile and awareness of modern slavery
Many of the goods and services we use are procured through central government frameworks led by Defra, including services managed under Digital, Data, Technology and Security (DDTS). While these frameworks operate under robust government procurement standards, our direct visibility of modern slavery due diligence within them remains limited. For shared services where the Environment Agency manages delivery on behalf of the Defra group – such as Fleet and Clothing – we maintain full visibility and oversight.
Over the coming months we will improve data quality, refine due diligence, and deepen engagement with suppliers and delivery partners to turn policy into practice, strengthen accountability, and embed a culture of awareness across the Environment Agency and government buying processes to meet legal requirements and promote ethical, fair, and sustainable supply chains.
We are strengthening our collaboration with Defra, to increase transparency and influence across procurement stages – from supplier selection and tender evaluation to contract oversight. This will help us further embed ethical and sustainable standards into our practices.
We are improving how we monitor our suppliers. At present, we check whether suppliers have published modern slavery statements as required by law. Having a statement alone does not guarantee its depth, quality, or impact. We are working on better ways to evaluate these statements, so they show genuine action, clear accountability, and evidence of ongoing improvement.
We are also exploring opportunities to assess how well suppliers are embedding anti-slavery measures across their operations and supply chains. This includes:
- reviewing how suppliers cascade expectations to subcontractors
- supporting vulnerable workers
- handling reports of exploitation
Case study 3: TEAM2100 and flood risk asset management
Launched in 2012, the Thames Estuary 2100 Plan (TE2100) outlines how tidal flood risk in the Thames Estuary will be managed throughout the 21st century. To implement Phase 1 of the plan, the TEAM2100 programme began in 2015, starting with detailed investigations into individual flood defences and the wider system. These findings informed a 10-year programme of works and long-term asset management strategies.
Valued at over £450 million, TEAM2100 is the UK’s largest flood risk management programme and is recognised as one of the government’s top 40 major infrastructure projects.
As part of this programme, the Environment Agency has developed a Work Package to support the social impact theme of its eMission sustainability plan, with a strong focus on modern slavery. This initiative aims to:
- identify challenges and opportunities related to modern slavery
- review best practices
- develop a method to assess and mitigate modern slavery risks across the TEAM2100 supply chain
- support the development of a tailored action plan aimed at preventing and mitigating modern slavery risks through the recommendations from this work
This work demonstrates the TEAM2100 commitment to innovative, best-practice solutions in tackling modern slavery. This approach will support future delivery phases of the TE2100 Plan and enhance modern slavery prevention across the Environment Agency and wider society.
Early outcomes from this collaborative approach are promising. The team has come together to define clear, time-bound actions that will strengthen the monitoring and auditing of contract activities – ensuring proactive measures are in place to prevent Modern Slavery. This shared commitment lays a strong foundation for accountability and continuous improvement across delivery partners.
Section 5: Training
Environment Agency staff training and development
Training and education are critical to our approach to modern slavery prevention -equipping staff to recognise, respond to, and escalate concerns, while supporting survivors and protecting those most at risk. Staff in operational and recruitment roles, such as construction, maintenance, and on-site teams, are especially well placed to spot potential signs of exploitation.
We provide tailored training to help employees identify risks during site visits, supplier engagement and frontline interactions.
Our learning offer includes:
- a virtual ‘Spot the Signs of Modern Slavery’ module available through our internal platform
- lunch and learn sessions within operational hubs and areas
- Civil Service Learning access to government-aligned training resources
- participation in awareness events such as World Day Against Trafficking in Persons
- Health, Safety and Wellbeing updates to reinforce key messages and promote the Modern Slavery Helpline
Our virtual module has been widely accessed, with increasing completion rates across operational teams. We have seen increased engagement with lunch and learn sessions, and bespoke hub-led training has helped tailor content to team needs. Line managers are consistently promoting guidance through regular wellbeing updates, and our presence in national awareness campaigns continues to grow.
Training is embedded in our onboarding procedures and aligned with Safeguarding Vulnerable Adults protocols. Staff can seek further guidance or report concerns directly through our Sustainable Business Team, which provides bespoke support – see section 6: Monitoring and Evaluation.
We have identified that individuals in key roles could benefit from additional training and knowledge to strengthen their ability to identify and manage modern slavery and labour exploitation risks within our operations. Future activity will focus on increasing awareness among teams by fully understanding and improving where necessary:
- Defra’s risk assessment steps for modern slavery and labour exploitation
- due diligence practices during supplier selection
- transparency on supplier risks and corresponding action plans
- risk management within contract oversight
- escalation procedures and victim-focused approaches for targeted staff in high-risk areas
We will also embed role-specific modern slavery and labour exploitation training into our broader training programmes to empower staff and enhance organisational capability. As our understanding of modern slavery evolves, we are also exploring ways to extend awareness beyond the workplace – encouraging vigilance across local communities and supply networks.
Together, these efforts are building a more ethical, accountable, and resilient supply chain that supports our mission and the communities we serve.
Supplier management and development
Suppliers and delivery partners are key to delivering our sustainability goals. We prioritise collaboration with those demonstrating leadership in responsible practices, embedding social and environmental expectations into our contracts and engagement processes.
We are promoting shared learning and transparency through:
- the Sustainability Community of Practice, supporting collaboration across the Environment Agency and delivery partners
- peer learning between suppliers within our frameworks
- active engagement in the AOMR pilot to test and improve supply chain interventions
Our risk-based approach ensures potential issues are identified early and that sustainability is embedded across the procurement lifecycle – not as a compliance task, but as a driver for positive impact.
This includes:
- understanding life-cycle risks
- translating findings into contract-level action
- supporting continuous improvement across supply chain operations
We are members of the Supply Chain Sustainability School (SCSS), which provides training for staff, suppliers, and delivery partners. Membership is now required for all new or renewed framework partners, ensuring they have access to social value and modern slavery learning materials.
In our supply chain, uptake of SCSS membership has risen among delivery partners, supported by reinforced training expectations at framework renewal. We have seen more referrals for advice and guidance through our Sustainable Business Team, showing greater staff confidence in recognising and raising concerns. Through the Sustainability Community of Practice, our early pilot with the AOMR framework has demonstrated clear appetite for ongoing peer collaboration and shared learning. See case study 4 for further information.
Section 6: Monitoring and evaluation
As part of our commitment to tackling modern slavery and promoting safe, ethical practices, we have established multiple channels for identifying and recording concerns related to exploitation and abuse.
When our teams are working within communities, they may come across intelligence or take actions relevant to safeguarding individuals. We record these formally in our enforcement database to ensure appropriate follow-up and accountability. We use an intelligence system to record suspected cases of modern slavery encountered during our work. This system enables information sharing with partner agencies to ensure coordinated, effective responses.
In addition to our internal reporting systems, members of staff and the public can also report incidents or suspicions of modern slavery directly to the Modern Slavery Helpline, ensuring an independent and confidential route is always available.
We also encourage and enable reporting through our Health, Safety and Wellbeing system, which is designed to support the welfare of our workforce and those we interact with in the course of our work.
Further reporting mechanisms are embedded within a range of internal staff policies – outlined in Section 2 of this document – which provide additional guidance and support for employees who may need to raise concerns.
By maintaining these multiple, accessible reporting pathways, we aim to ensure that no instance of modern slavery or unethical practice goes unnoticed, and that swift, appropriate action can be taken to protect those at risk.
As we continue refining our escalation procedures, we are creating a more consistent and trackable process for reporting, helping us better understand and amplify the Environment Agency’s impact in tackling modern slavery.
Next steps for 2025 to 2026
Looking ahead, our 2025 to 2026 priorities reflect a clear and coordinated path toward achieving actions outlined in Transparency in Supply Chains: A Practical Guide. This gives clear actions to support our ambition to reach Level 2 within this guidance. With a strong emphasis on governance, risk, due diligence, training, and evaluation, we are strengthening our ability to identify and mitigate risks across operations and supply chains.
As this is a live and evolving plan, we remain agile – ready to adapt to emerging risks and business needs – while maintaining our focus on protecting people, upholding human rights, and driving sustainable, ethical practice across everything we do.