Modern slavery statement
Modern slavery and human trafficking annual statement, financial year 2024 to 2025
Our modern slavery and human trafficking statement, financial year 2024 to 2025
This statement is made on behalf of Nuclear Waste Services (NWS) pursuant to Section 54(1) of the Modern Slavery Act 2015. The Act requires any organisation with a global turnover of £36 million or more, and operating in the United Kingdom, to produce an annual statement outlining the steps taken to prevent modern slavery and human trafficking in its operations and supply chains.
As an employer, NWS is also committed to upholding the principles of Equality, Diversity, and Inclusion. We strive to foster a respectful, inclusive, and non-discriminatory working environment where all employees feel safe and empowered to speak up about wrongdoing without fear of retaliation.
This statement provides an opportunity for NWS to report on the progress made since our last disclosure, outline planned next steps and describe our business operations and supply chain. It also details the systems and processes we have in place to identify, assess, and manage potential modern slavery risks.
As NWS continues to map its supply chain, we remain committed to identifying and addressing potential risks related to modern slavery. These considerations are actively embedded in our commercial management processes and will remain a key focus going forward. We are prioritising the mapping of high-risk categories, working closely with key stakeholders to ensure responsible and ethical supply chain practices.
The NWS Commercial Directorate has been reviewing processes across the organisation. Insights from this analysis are guiding the ongoing development of a harmonised approach, integrating best-in-class elements into our Intelligent Client process. This evolving framework is designed to ensure strong and consistent compliance with modern slavery legislation.
Modern slavery training is mandatory for all employees within the Commercial function. While not required for other areas, the training is available to those whose roles may involve relevant risks. This supports our commitment to raising awareness and promoting accountability across the organisation.
The Procurement Act 2023 broadened the scope of offences under the Modern Slavery Act 2015, introducing mandatory exclusion grounds for certain violations. In preparation for its implementation, the Commercial Directorate were expected to complete the Transforming Public Procurement training prior to implementation wherever possible but as a minimum before undertaking any PA23 procurement activities. This mandatory training ensures that modern slavery considerations are effectively integrated into our procurement activities. Additionally, we are aligning our practices with the current National Procurement Policy Statement (NPPS) and the latest Procurement Policy Notes (PPNs) to ensure we meet, at a minimum, the updated expectations for identifying and mitigating modern slavery risks.
This statement is reviewed and approved by the NWS Board of Directors prior to publishing.
Our business
Nuclear Waste Services (Company Registration No 5608448), registered office is at Pelham House, Pelham Drive, Calderbridge, Cumbria CA20 1DB.
We have integrated the expertise of LLWR, RWM and the Nuclear Decommissioning Authority (NDA) group’s Integrated Waste Management Programme (IWMP). This creates an organisation focused on the management of the UK’s nuclear waste, safely and securely for generations to come.
We are part of the NDA group, which is undertaking one of the largest nuclear decommissioning and remediation programmes in Europe over many decades. Nuclear Waste Services is integral to this environmental clean-up mission, as we work to provide safe, secure, and permanent solutions to the UK’s nuclear legacy.
Our supply chain
NWS is committed to developing a supply chain that supports the delivery of safe, sustainable nuclear waste solutions while delivering value for money for the UK taxpayer throughout the commercial lifecycle.
Our supply chain partners include large multinational organisations, publicly owned bodies, universities, and a diverse range of small and medium-sized enterprises (SMEs). In alignment with the UK Government’s SME agenda, we actively work to remove barriers and increase SME participation in our contracts wherever possible.
Currently, our supply chain delivers a wide range of services, including site programmes and operations, waste management, and professional and business services.
NWS takes a proactive approach to identifying and mitigating modern slavery and human trafficking risks within the sectors in which we operate. This is reflected in our current practices, which include the use of tailored risk assessment tools to identify high-risk procurements, as well as toolkits that equip staff to effectively manage and respond to these risks.
Our policies and guides relating to modern slavery
NWS operates the following policies and training in support of preventing modern slavery and human trafficking.
Modern Slavery and Human Trafficking Policy
NWS is committed to engaging with both internal and external stakeholders to raise awareness of the risks of modern slavery within our operations and supply chain. We actively promote the prevention, detection, and reporting of any suspected instances of modern slavery or human trafficking.
Our policy requires that clear and accessible channels are available for stakeholders to report concerns or activities that may indicate modern slavery. To support this, we have launched our Speak Up policy, which provides safe and confidential reporting mechanisms. This includes access to the Safecall service, a free, 24/7, independent reporting line that connects directly to the NDA Group Ethics and Compliance team.
Whistleblowing Policy
Our Modern Slavery Statement is also aligned with our Whistleblowing and Grievance Policies, which provide clear and accessible channels for staff and other stakeholders to raise concerns related to modern slavery. These policies ensure that individuals can report issues in a safe and supportive environment.
Code of conduct
Our commitment is further reinforced through our Code of Conduct, issued as part of the NWS Standards and Expectations Handbook. It clearly outlines our expectation that individuals report all observations and abnormal events, supporting a culture of transparency and accountability.
Modern Slavery Training
Modern Slavery awareness training, delivered through the Government Commercial College, is mandatory for all members of the NWS Commercial Directorate. While we closely monitor compliance with this requirement, staff turnover (including new starters and leavers) has impacted our ability to maintain 100% completion across the full financial year. This is being proactively managed, and all outstanding training will be completed at the earliest opportunity. NWS ensures sufficient time is allocated for training, with recent completions achieved within an average of 5.1 weeks.
| Financial Year | Commercial completed |
|---|---|
| 2023 to 2024 | 86% |
| 2024 to 2025 | 100% |
Figure 1: Mandatory Training Completed
Due diligence processes
To fulfil the commitments made within our policies, NWS operates the following business processes.
External focus Pre-contract Procurement and Purchasing
NWS continues to use the Modern Slavery Assessment Tool (MSAT), as recommended under the Modern Slavery Act 2015, to assess and monitor compliance within our supply chains.
For contracts identified as medium or high risk for modern slavery, we require suppliers to complete a set of Supplier Audit Questions (SAQs). This self-assessment includes the submission of documented evidence to demonstrate compliance. These questions and associated processes are fully embedded within our Intelligent Client Process and associated Toolkit, and we remain committed to applying this approach as part of our ongoing due diligence.
Modern slavery and human trafficking risks are also considered when appointing new suppliers. Suppliers must demonstrate that they have appropriate policies and procedures in place, provide safe working conditions, treat workers with dignity and respect, and act ethically in their use of labour.
As part of our supplier onboarding process, we review the latest reports from external rating agencies, including Dun & Bradstreet. Any concerns or risks identified during this stage are escalated to senior management for further review and action, where appropriate.
Post-contract Delivery and Management
All commitments and requirements agreed at the procurement stage—including those related to modern slavery policies and procedures—must be upheld for the full duration of the contract. Contract Leads are responsible for defining quality assurance requirements within the Contract Management Plan, which is used, reviewed, and updated as necessary throughout the contract lifecycle.
Where specified in the Contract Management Plan or required as part of risk mitigation, NWS may conduct site visits to supplier premises to assess working conditions and practices as part of mobilisation and assurance activities. We also work collaboratively with the NDA, which may carry out modern slavery audits on suppliers if deemed necessary.
Any serious concerns, observed violations, investigations, or alleged offences related to slavery or human trafficking are reported through the NWS event reporting system and shared across the NDA Group to ensure appropriate visibility and action.
We also conduct horizon scanning of our suppliers to identify any emerging modern slavery concerns. As part of our ongoing monitoring of critical suppliers and our supply chain mapping, beginning with Tier 1, we have implemented Resilinc alerts. These alerts enable proactive monitoring of potential modern slavery risks, allowing us to identify and investigate areas of concern in a timely manner.
Key goals and key performance indicators (KPIs)
This year, a compliance check was conducted across our supply chain. We will continue to carry out these checks on an annual basis to monitor any changes in compliance and ensure ongoing alignment with our modern slavery commitments.
| Financial Year | Top 80% spend number of Suppliers | Suppliers qualified to publish a Modern Slavery Statement | Qualified Suppliers that have published a Modern Slavery Statement |
|---|---|---|---|
| 2023 to 2024 | 24 | 12 | 100% |
| 2024 to 2025 | 28 | 19* | 100% |
Figure 2: Top 80% of Supplier Spend: Modern Slavery Statement Publication Check
*Five suppliers do not meet the criteria requiring them to publish a Modern Slavery Statement. However, a statement is available for each of their respective parent companies.
Our effectiveness in combating slavery and human trafficking
The identification and assessment of risks or potential instances of modern slavery and human trafficking are currently integrated into our broader supply chain management, monitoring, and assurance activities. As part of these ongoing efforts, NWS has found no evidence of modern slavery within our supply chain to date.
| Financial Year | Incidents |
|---|---|
| 2023 to 2024 | 0 |
| 2024 to 2025 | 0* |
Figure 3: Number of Modern Slavery Incidents
*This figure includes a detailed supplier audit which confirmed that their existing Modern Slavery Statement will be revised. The updated statement will remain in effect despite a change in nationality of ownership meaning they are no longer legally required to publish a statement under UK legislation.
Further steps planned for financial year 2025 to 2026
We will expand our use of Resilinc’s supply chain mapping capabilities to implement a tiered due diligence approach. This will prioritise suppliers and categories based on key risk indicators such as geography, industry, and past performance. High-risk suppliers will be subject to enhanced scrutiny, including targeted audits and advanced screening. In parallel, we are extending our supply chain mapping efforts to include Tier 2 and Tier 3 suppliers.
Over the next twelve months, NWS will:
-
continue to strengthen our efforts to identify and address modern slavery risks across our operations and supply chain, ensuring our strategy remains agile and responsive to emerging challenges
-
review and refine our procurement and purchasing practices to identify opportunities for improvement
-
encourage broader participation in modern slavery training and introduce briefing and education sessions within the Commercial Directorate to promote consistent and informed due diligence
-
work to continuously improve access to grievance mechanisms for workers within our supply chain
We remain confident that the actions NWS is taking are both effective and appropriate in meeting our commitment to preventing modern slavery and human trafficking within our business and supply chain.
Signed:
Steve Glasson, Commercial Functions Director