Corporate report

Modern slavery statement for financial year 2021 to 2022

Updated 13 September 2023

The Nuclear Decommissioning Authority (“NDA”) is making this statement in accordance with its commitment to meet section 54 of the Modern Slavery Act 2015 (“MSA”).

This statement covers the period between 1 April 2021 and 31 March 2022.

The NDA is committed to preventing modern slavery and human trafficking in any part of our business or supply chain. It is absolutely the right thing to do, and we aim to take sustained and concerted action against such acts.

Organisation structure and supply chains

The NDA is a non-departmental public body formed under the Energy Act 2004 to oversee the decommissioning of the UK’s nuclear legacy. We are the ultimate parent of the NDA Group, with operating companies that undertake and support decommissioning and waste management in the UK, provide specialised transport services, as well as ancillary functions such as training and socio-economic services to our local areas. The NDA has offices located in London, Harwell, Warrington, Cockermouth, and Whitehaven. Additional organisational information about the NDA can be found online.

Some key facts and figures about the NDA and it’s supply chain profile are provided.

Figures for the reporting year 2021 to 2022:

167 suppliers including 159 in the UK and 8 non-UK

103 stand-alone contracts including 31 framework agreements and 71 call-off contracts

£82.6m spend in the financial year

Spend is broken down into 6 sub-categories:

• Corporate Services & Resourcing
• Facilities Management & Property
• Information Technology
• Site Operations
• Manufactured Products and Services
• Capital Projects & Infrastructure

50 procurement and supply chain staff

11 strategic suppliers

Policies in relation to slavery and human trafficking

NDA recognises its responsibility to operate our business with effective policies and procedures. Key relevant policies include:

• Supply Chain Modern Slavery Guidance
  The guidance provides a comprehensive overview of the roles and responsibilities of the commercial practitioner in assessing and mitigating the risk of modern slavery in the supply chain. The supply chain servicing our requirements for goods, services and works is vast and includes large multinational organisations, publicly owned bodies as well as a range of small and medium sized suppliers. Through our standard terms and conditions of contract, we require that our supply chain members (no matter what size) support the NDA in its mission to prevent modern slavery and human trafficking in any part of our business or supply chains.
• Code of Conduct and Standards of Behaviour in the Workplace
  Our Code of Conduct (supported by policies such as respect at work, diversity and inclusion) sets out the expectations we have of those who work for us in relation to standards of behaviour.
• Speak Up Policy
  Our Speak Up policy encourages the raising of concerns (whether by employees or others in the supply chain) either directly or using the independent Safecall service to the Group Ethics & Compliance team (overseen by the Audit Risk & Assurance Committee made up of Non-Executive Members of the NDA Board). NDA is committed to listening and acting when Speak Ups are raised. No concerns related to modern slavery were identified in 2021 to 2022.
• NDA Supply Chain Charter
  This includes provisions that set out our expectations of the supply chain to take steps to prevent modern slavery and human trafficking further down the supply chain. Around 780 organisations are signed up to our Supply Chain Charter.

Due diligence processes

The NDA approach to due diligence and assessment of the modern slavery risk within the supply chain is aligned with the general UK Government and our sponsoring department (BEIS) approach, in that a tiered approach is undertaken;

• Throughout 2021 to 2022 any new supplier, supply chain or change within our supply chains has been subject to the NDA Modern Slavery Categorisation Assessment Tool. To assess the potential level of modern slavery risk with that supplier or supply chain, the tool uses:
  • Industry type – for example those that involve raw materials and are labour intensive
  • Nature of workforce - for example reliance on temporary or low skilled labour
  • Supplier location – some countries have a higher predicted risk of modern slavery
  • Context in which supplier operates – for example high levels of poverty and unemployment
  • Commodity type – for example imported products as identified in the Global Slavery Index
  • Business/supply chain model – for example sub-contracting and complex supply chains.

No contracts were identified to be at greater risk over the period covered by this statement, nor any issues flagged

• Should a contract be identified to be at greater risk of modern slavery, we will approach the supplier to complete a self-assessment of their business using the Home Office approved, Modern Slavery Assessment Tool (MSAT). The MSAT is a free, risk identification and management tool that the government has developed for public bodies to use with their suppliers. The tool gives suppliers tailored, good-practice recommendations to improve their management of modern slavery risks.
• Where the risk identifier remains a “high-level risk” the NDA will then consider its options, including on-site audits.

In the event of modern slavery practices being identified within our supply chain, the NDA will refer to its the process laid out in the Supply Chain Modern Slavery Guidance for referrals and support, in accordance with the principles below;

• The report must be addressed immediately and in a manner that is proportional to the case being reported.
• Work collaboratively with the supplier and in accordance with the terms of the contract to address the issues being raised.
• Development of a remediation plan for handling such occurrences which sets out the process for dealing with such instances and set out roles and responsibilities. The core points to consider are:
  • Where we suspect workers are being subjected to modern slavery, we shall involve law enforcement agencies:
  • In the UK, if someone is in immediate danger, it shall be reported to the police by dialling 999. A potential victim can then be referred to the National Referral Mechanism by the police to be formally identified and offered Government-funded support.
  • Where concerned about a potential victim, or suspicious about a situation that is potentially exploitative, we will call the Modern Slavery Helpline on 0800-012-1700, or call the Gangmasters and Labour Abuse Authority on 0800-432-0804 or submit a report online.
  • If overseas, then the response should be tailored to the local circumstances.
  • We will continually assess the situation and ensure that remediation plans are in place and being progressed.

Risk assessment and management

Although the risk is determined to be low, modern slavery risks are documented in the NDA Group, NDA, and Commercial Risk Registers. These registers are reviewed and updated quarterly to ensure that content is and remains relevant and that allocated actions are delivered by the identified owners.

Key activities undertaken in 2021 to 2022 to address our Modern Slavery Risk

The following steps were taken during 2021 to 2022 to further enhance our approach to modern slavery.

• The new Supply Chain Modern Slavery Guidance for commercial practitioners was updated and relaunched. Modern slavery training was made available and promoted.
• We have included guidance and linked the commercial practitioner guidance on modern slavery in our induction process for anyone joining the NDA Procurement & Supply Chain function.
• We reviewed commercial practitioner guidance on modern slavery, ensuring it remains up to date and relevant.
• We have included modern slavery risk assessment indicators (such as industry type and nature of workforce) in the scope of our requirements for our new electronic sourcing system.
• We have reviewed and launched the Speak Up Policy.
• We continue to engage with our parent organisation, the Department for Business, Energy, and Industrial Strategy to share best practice.

Training on modern slavery and trafficking

Awareness of modern slavery and the risks it poses to the NDA is an essential part of our training programme.

We use three main modern slavery training packages:

• The NDA Modern Slavery training package – developed specifically by the NDA for all members of the organisation.
• Crown Commercial Services Modern Slavery Workshops – specifically for commercial practitioners
• Government Commercial College training – a training package on tackling modern slavery in the supply chain using a Personal Protection Equipment case study, available to all members of the commercial team.

Aims for 2022 to 2023

We set out below our aims to further develop our approach to modern slavery in 2022 to 2023

• to have developed and tested a route to market for third-party auditing including the ability at short notice instigate further desktop and/or on-site audits.
• to refresh our risk assessment in relation to all aspects of modern slavery, including any new risks arising due to global or UK events.
• to deliver the electronic sourcing system which includes modern slavery risk assessment indicators, which will support our reporting requirements as well as supporting cross-NDA group identification of risk.
• to continue our annual review cycle of the guidance given to commercial practitioners, which this year will include how the new electronic sourcing system will further support them in addressing modern slavery risk.
• we will consider appropriate measurements of the efficacy of our programme and approach, and begin to track them
• to mandate the completion of the NDA modern slavery training package for all commercial practitioners.
• to promote the NDA modern slavery training package to all employees of the NDA who interact with third-party suppliers including those outside the Commercial team.

This statement was approved on the 27 September 2022 by the NDA Board of Directors.

Signed on behalf of the NDA by:

David Peattie, CEng HonFNucI
NDA Chief Executive Officer