Corporate report

Modern slavery statement for financial year 2024 to 2025

Updated 2 October 2025

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 specialist transport services, as well as ancillary functions such as training and socio-economic services to our local areas.

The NDA has offices located across the UK. Additional information about the NDA can be found online.

Some key facts and figures about the NDA and its supply chain are provided.

Figures relate to the reporting year 1 April 2024 to 31 March 2025:

• 263 Suppliers (259 are UK based)
• 348 Contracts

Breakdown:

• 79 Standalone Contracts
• 10 Framework Agreements
• 259 Call-Off Contracts
• 54 Procurement and Supply Chain Staff Positions
• 11 Strategic Suppliers
• £148m Spend

Spend is broken down across six sub-categories of spend:

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

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 is based upon the latest Procurement Policy Note issued by the Cabinet Office (PPN 009: Tackling modern slavery in government supply chains - GOV.UK) and 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 large and includes large multinational organisations, publicly owned bodies as well as small & 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 chain.
• Code of Conduct and Standards of Behaviour in the Workplace: Our Code of Conduct (supported by policies such as respect at work, diversity & 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 up issues are raised. No concerns relating to modern slavery were identified during this reporting period.

Due diligence processes

The NDA approach to due diligence and assessment of modern slavery risk within the supply chain is aligned with the UK Government’s and our sponsoring department (Department for Energy Security & Net Zero) approach, in that a tiered approach is undertaken.

• Throughout the reporting year new procurements above the minimum level for open procurement ( i.e., £12,000 including VAT) has been subject to the NDA Modern Slavery Categorisation Assessment Tool. To assess the potential level of modern slavery risk within the supply chain delivering the proposed contract, the tool uses the following risk indicators as assessment criteria;
• Industry Type – for example those that involve raw materials and / or 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 the 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 reporting period, nor were 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 identified as “high risk” the NDA will then consider further options including deep-dives and / or site audits.

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

1. The report must be addressed immediately and in a manner that is proportional to the case being reported.
2. Work collaboratively with the supplier and in accordance with the terms of the contract to address the issues being raised.
3. Development of a remediation plan for handling such occurrences which sets out roles and responsibilities. The core points to consider include:

• 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 exploitive, 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 during this reporting period to address our Modern Slavery risk

The following steps were taken during this reporting period to further enhance our approach to modern slavery.

• We have offered our supporting to Cabinet Office in the user testing of the new Modern Slavery Risk Assessment Tool.
• Staying up to date with Cabinet Office involvement in the national baseline assessment of the UN Guiding Principles on Business & Human Rights.
• We carried out an annual review of our Modern Slavery risk assessment, including any new risks arising due to global or UK events. This has included an update based on the PPN 009: Tackling modern slavery in government supply chains - GOV.UK guidance released Feb 25.
• We have concluded our annual review of the guidance given to commercial practitioners, and highlighted the change from PPN 02/23 to PPN 009: Tackling modern slavery in government supply chains - GOV.UK following the ‘go-live’ of Procurement Act 23.
• We are continuing to work closely with Cabinet Office through the cross-Government Procurement Policy Working Group to keep abreast of all up-coming changes that will affect how we address Modern Slavery, as a result of the new Procurement Act 2023 (PA23) and will support in the review of the MSAT Cabinet Office intend to carry out 6 months after PA23 ‘go-live’.
• NDA Modern Slavery training was mandated for all Commercial employees with successful completion linked to remuneration. The successful completion rate was 100%.

Training on modern slavery and trafficking

Awareness of modern slavery and the risks it poses to the NDA and its supply chain is an essential part of our training programmes. We use three main modern slavery training packages, and these are available to our commercial practitioners:

• The NDA Modern Slavery training package – developed specifically by theNDA for all members of the organisation
• Crown Commercial Services Modern Slavery Workshops – specifically forprocurement and supply chain practitioners
• Government Commercial College Training – a training package on tacklingmodern slavery in the supply chain using a Personal Protection Equipmentcase study, available to all procurement and supply chain practitioners.

Aims for the reporting year 2025 to 2026

We set out below our aims to further develop our approach to modern slavery in 2025 to 2026:

• To continue our annual review cycle of the guidance given to procurement and supply chain practitioners, which will ensure alignment with Cabinet Office guidance and Procurement Act 2023.
• To continue to mandate the annual completion of the most up to date NDA Modern Slavery training packages for procurement and supply chain practitioners. -To promote the NDA Modern Slavery training package for a week leading up to Anti-Slavery Day (18th October 25) to all employees of the NDA who interact with third-party suppliers including those outside the Commercial team.
• To support Cabinet Office in the user testing of the Modern Slavery Risk Assessment tool and MSAT review expected in Q2 2025. Ensuring successful implementation into NDA Policy & Procedures.

This statement was approved on 1st October 2025 by the NDA Board of Directors.

Signed on behalf of the NDA by:

David Peattie, FREng FNucI
NDA Group Chief Executive Officer