Corporate report

LLW Repository Ltd's Modern Slavery and Human Trafficking Annual Statement 2023 to 2024

Updated 29 September 2023

1. Our modern slavery and human trafficking statement 2023/24

Low Level Waste Repository Ltd (LLWR) has published this statement in accordance with section 54(1) of the Modern Slavery Act 2015.

The Modern Slavery Act (MSA) requires any organisation with a global turnover of £36 million or above and that is operating in the United Kingdom to produce an annual statement.

This statement builds on previous LLWR statements and details the steps that have been taken to ensure that modern slavery isn’t taking place within any part of the organisation’s business or within its supply chain.

2. Our Key Performance Indicator

During this financial year, we have not identified any evidence of modern slavery occurring within LLWR Ltd or its extended supply chain.

3. Our commitment

Modern slavery is a criminal offence and a violation of fundamental human rights. This will not be tolerated by LLWR Ltd and as such, we are committed to doing business in a fully transparent and responsible way.

This level of commitment cascades through our own organisation and into our supply chain, where we expect the same level of commitment from suppliers.

4. Our organisational structure, our business & supply chain

“Nuclear Waste Services” is a joint trading name of LLW Repository Ltd (Company Registration No 5608448) and Radioactive Waste Management Ltd (Company Registration No. 08920190), whose registered office is at Pelham House, Pelham Drive, Calderbridge, Cumbria CA20 1DB

LLWR is the Site Licence Company (SLC) established to hold the Nuclear Site Licence for the Low Level Waste Repository Site (the Site) in West Cumbria. Whilst LLWR operates and manages the Site, the Site itself is owned by the Nuclear Decommissioning Authority (NDA). The Site is the UK’s principal disposal facility for Low Level Waste (“LLW”) and is the only facility that is permitted to receive all categories of low level radioactive waste. 

Nuclear Waste Services operates within the wider NDA Group of companies and have a range of reporting, management, service and collaboration activities undertaken as part of day-to-day business. As part of the NDA Group, Nuclear Waste Services regularly shares and receives business and operational learning and briefings to improve business performance. This includes any indicators or warnings of Modern Slavery and Human Trafficking.

Our Supply Chain

This section describes the types of works, goods and services LLWR procures, including the geographic regions where our suppliers are based. LLWR contracts with a wide range of organisations in support of delivering our business operations and services. LLWR is classed as a Contracting Authority as defined under the Public Contracting Regulations (PCRs) and must comply with the PCRs and Government procurement and contract policies. Where appropriate LLWR also adopts Government best practice for supply chain management.

The majority of LLWR’s contracts are with UK registered companies who are based and operate in the UK.

LLWR’s supply chain can be summarised as follows:

• Site Programmes and Operations – In support of programme delivery and Site operations, a broad range of construction works and industrial goods and services are provided via a small number of higher value, longer term contracts and framework agreements. In some cases, these contracts involve a portfolio of specialist subcontractors managed by the prime contractor. The main areas of spend are on construction works, engineering and infrastructure services, and hard and soft facilities management.  LLWR retains its own capability to deliver most site operations and maintenance activities.
• Waste Management Services – LLWR manages a portfolio of around 30 suppliers in the provision of waste management services to UK customers. The services include transport, incineration, metallic waste treatment and alternative waste disposal.  These support the application of the waste hierarchy across the UK nuclear industry and to avoid the disposal of waste and usage of limited space within the Site disposal vaults. Except for metallic waste treatment, which includes access to facilities based within the EU, all services are provided from UK facilities. The majority of goods for Waste Management Services are manufactured by British businesses in the UK, with limited goods manufactured outside of the UK in areas such as the Philippines and India.
• Business Functions – Spend within this business area involves predominantly professional services providers. The majority of these suppliers are UK based. LLWR sources a range of IT services and some consultancy and software capability is based within the EU and India.

5. Our policies and guides relating to modern slavery

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  Our commitment is further reinforced through company policies.

As a subsidiary of the NDA, LLWR has signed on to a Supply Chain Charter which sets out expectations from the supply chain to prevent modern slavery and human trafficking.  In addition, our Whistleblowing Policy provides a reporting method for our staff and others to alert us to any concerns they may have. 

Our procurement contract terms and conditions require suppliers to comply with the MSA.

We also require our suppliers to:

• implement due diligence procedures for their own supply chains
• use reasonable endeavours not to purchase raw materials, resources and/or products from organisations using forced labour

We will work with suppliers through our Supplier Relationship Management (SRM) programmes and contract management meetings offering support to them, whilst ensuring that any reports featuring any aspect concerning or including modern slavery are fully investigated with appropriate remedial actions being taken.

LLWR continue to operate an open-door approach allowing individuals from within the company or supply chain to raise concerns relating to modern slavery with the confidence of anonymity and without fear of reprisal.  This sits within our existing whistleblowing policy and details reporting methods for our staff and others to alert us to any concerns they may have, including those relating to modern slavery.  [Policy 024 Whistleblowing]

6. Our management and risk based approach

During one of our most economically challenging years the cost of living reached a 41 year high of 11.1%, LLWR as a business has continued to focus on  clear accountabilities and responsibility covering modern slavery.

We continue to exercise our attention towards vigilance and embedding processes that drive a commitment to continuous improvement, whilst gaining guidance from Home Office publications and other areas of MSA best practice.

These expectations continue to be cascaded through our own organisation and through to our extended supply chain in a joint commitment and a collective focus on collaborative, mutual and behavioural relationships that fully commit to the eradication of any forms of modern-day slavery.

Transparency is central to our collaborative approach, as we look to build on previous year’s annual statements.  Differing platforms of improvements have been described in further steps to progress our organisation.

Our aim, year on year is to report against MSA progress explaining how LLWR under Nuclear Waste Services has continued to embed practices, processes and tools that minimise risk to our business, but more importantly, the risk to those individuals that may potentially be caught in the grip of modern slavery.

LLWR Ltd recognises the importance of observing the United Nations Guiding Principles on Business and Human Rights, (UNGPs) and UK Government Home Office Guidance, all of which provide direction to due diligence activities recognising a risk-based approach to combating slavery and trafficking.

During 2023/24, Nuclear Waste Services will revisit its modern slavery risk assessment programme to allow itself a health check of current MSA practices and measures of effectiveness, noting any potential supplier changes.

The approach once again will use the globally recognised HMG MSA Areas of Concern Identifiers

Our areas of focus and risk management will centre on the following:

• Personal protective equipment (PPE) and clothing manufacture
• Labour (specifically supply chain labour terms)

We continue to embed due diligence reviews as part of our post contract management processes and future SRM programmes.

Improved, targeted, in depth discussions were driven by our need to reassure ourselves that our suppliers are continuing to manage and mitigate risk effectively. The process allows us to build stronger mutual relationships with our suppliers and provides the opportunity to have those open, honest discussions.

7. Further steps

Having undertaken a review of the effectiveness of the steps we have taken to ensure that there is no modern slavery or human trafficking in our supply chains, it has been determined that during this financial year we will take the following steps to ensure continued compliance; We will:

• Continue to observe and respond to Cabinet Office Procurement Policies - Tackling modern slavery in government supply chains;
• Continue to roll-out modern slavery awareness training, ensuring it forms parts of NWS Induction as well as extending this beyond the Commercial Function to those already within the NWS organisation, maintaining a register of this training;
• Establish a Modern Slavery Champion within Nuclear Waste Services as a point of contact for any related queries/support;
• Continue to develop our links across a range of organisations coupled with assessment of market knowledge to build a robust understanding of MSA trends and themes to ensure any risks are mitigated and that our policies remain fit for purpose. The systems used will include, but not be limited to Stronger Together; Gangmasters & Labour Abuse Authority – GLAA;
• We will continue to work with the wider NDA team to cross check estate wide MSA alignment;
• Continue to undertake a risk-based programme of audits on our supply chain as we mature across the NWS portfolio of categories and suppliers, reporting any findings and proposed further actions back through our Board . These will target key site specific areas where deemed appropriate;
• Communicate the benefits of the Unseen app to the entire NWS organisation, utilising our intranet to promote the download and usage of this app on personal devices to enable the swift reporting of MSA offences;
• We have aligned LLWR and RWM’s statements to enable us to issue a single Nuclear Waste Services statement as we form one single legal entity.