Corporate report

RWM Modern Slavery and Human Trafficking Annual Statement 2023 to 2024

Updated 29 September 2023

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

We are committed to preventing modern slavery and human trafficking in any part of our business or supply chain; we will take sustained and concerted action against such acts.

In addition, as an employer, RWM is committed to Equality, Diversity & Inclusion and we aim to create and ensure a respectful and non-discriminatory working environment for our staff. We want all our employees to feel confident that they can expose wrongdoing without any risk to themselves.

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.

Radioactive Waste Management Limited’s (RWM) Modern Slavery and Human Trafficking Statement for 2023-24 offers RWM the opportunity to report on progress of activities previously identified alongside planned next steps. This statement builds on previous RWM 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 RWM 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 Radioactive Waste Management 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.

Radioactive Waste Management Limited is responsible for planning and delivering geological disposal of higher activity radioactive waste in the UK. This includes finding a suitable site with a willing community to host a permanent, safe and secure solution for managing radioactive waste. RWM’s activities are primarily planning and design-based but, as our mission progresses, will focus more on construction and operation activities.

Our supply chain

Our supply chains include large multinational organisations, publicly owned bodies and universities as well as a range of small and medium sized suppliers. The vast majority of our supply chain currently provide professional services, such as consultancy. We are already expanding into construction-related activities; for example, drilling and geophysical survey activities are underway and we continue to develop supporting design and early investigative infrastructure works.

We therefore need to take a proactive approach to combatting modern slavery and human trafficking risks that arise in those sectors. This is recognised in our plans below through the development of risk assessment tools to identify future procurements that may be high-risk in relation to any form of slavery or human trafficking and the creation of toolkits to equip staff to manage these.

5. Our policies and guides relating to modern slavery

We are fully committed to ensuring that no modern slavery or human trafficking takes place in any of our supply chains or in any part of our business. To make sure we do this, we have undertaken and continue to undertake significant amounts of planning work to ensure we shape and manage our GDF programme appropriately.

It is intended that the single entity NWS (Nuclear Waste Services) will publish a supplier charter which includes expectations required of our suppliers and ourselves to prevent modern slavery in all of its forms in our businesses and our supply chains. Our suppliers are encouraged to sign the charter and links to it will be included in all future tender documentation.

Our existing whistleblowing and grievance policies provide a reporting method for our staff and others to alert us to any concerns they may have in relation to modern slavery.

6. Our Management and risk based approach

As part of our initiative to identify and mitigate risk we undertake high-level due diligence whenever we procure. We have adapted the Modern Slavery Assessment Tool (MSAT), recommended by the Government’s Modern Slavery Act 2015, which is utilised to make an initial assessment of our supply chains’ compliance with modern slavery and human trafficking legislation. In addition, we have developed a process by which we are able to request our supply chain to complete a questionnaire to confirm their compliance.

We are further auditing our critical suppliers through Dun and Bradstreet, ensuring no Modern Slavery public filings have been issued.

For contracts that score as medium or high risk for modern slavery, we have also developed a set of Supplier Audit Questions (SAQs), that the supplier will then need to complete. This is a self-assessed set of questions that requires proof of compliance. Both documents and the relevant processes are now fully embedded within the IC Toolkit procedure.

We have implemented mandatory modern slavery training for our Commercial team, through the Government Commercial College, and the intention is to widen this over the next 12 months. The course is ‘Tackling modern slavery in supply chains: PPE case study’ and the training will be done in conjunction with the delivery teams and Project Managers.

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.