Modern Slavery Act statement 2019-20
We recognise the impact that modern slavery can have on people’s lives. In 2016, an estimated 40 million people were trapped in modern slavery, including 24.9 million people in forced labour, 4.8 million people in forced sexual exploitation and 15.4 million people in forced marriage. 70% of these were women and girls. This equates to 5.4 people trapped in modern slavery for every 1000 people in the world.
We are committed to identifying and eliminating any modern slavery in our own supply chain and in organisations that we work with around the globe, and we would not work with any organisation that we suspected of involvement in modern slavery. In 2018, we hired a Global Safeguarding Manager to protect the health and wellbeing of our staff, volunteers and the communities we work with. In 2019-20 we will be delivering more Modern Slavery training and further expanding our supplier due diligence and ethical checking process.
This statement is made in relation to the Modern Slavery Act and demonstrates our commitment to the Act and to promote transparency across all areas of our work. It is authorised by the trustees and signed by the Chair of our Trustees, Tim Clark. It outlines the work we have done and will do to identify and prevent modern slavery in our global operations.
Our organisation’s mission and structure
WaterAid is determined to make clean water, decent toilets and good hygiene normal for everyone, everywhere within a generation. Without all three, people can’t live dignified, healthy lives. With all three, they can unlock their potential, break free from poverty and change their lives for good. Everything we do is guided by our values:
Respect We treat everyone with dignity and respect and champion the rights and contribution of all to achieve a fairer world.
Accountability We are accountable to those whose lives we hope to see transformed, to those we work with and to those who support us.
Courage We are bold and inspiring in our actions and words, and uncompromising in our determination to pursue our mission.
Collaboration We work with others to maximise our impact, respecting diversity and difference in the pursuit of common goals.
Innovation We are creative and agile, always learning, and prepared to take risks to accelerate change.
Integrity We act with honesty and conviction and our actions are consistent with openness, equality and human rights.
WaterAid UK is part of a global federation of member organisations working in 34 countries worldwide. The members are: WaterAid UK, WaterAid Sweden, WaterAid Canada, WaterAid Australia, WaterAid America, WaterAid Japan and WaterAid India. WaterAid UK is the largest member organisation working in 21 countries across Africa and Asia. This statement covers the activities of WaterAid UK and WaterAid Trading Ltd (our trading company which is wholly owned by WaterAid UK).
WaterAid UK employs over 1,000 staff based globally.
Our work in relation to the Modern Slavery Act
This section outlines our work in relation to the Modern Slavery Act in respect of our operations, staff, partners, beneficiaries and our supply chains.
Global code of conduct
All existing and new staff are required to read and sign our Global Code of Conduct. This outlines WaterAid’s expectations of staff as well as what they can expect from WaterAid. In signing the Code of Conduct, staff are committing to:
- uphold WaterAid’s values
- promote WaterAid’s work within all aspects of their role
- treat everyone with respect and dignity
- not to abuse the privileged position of a role in WaterAid
- respect people’s human rights
- prevent and report any criminal or unethical activities that may impact WaterAid’s work
- ensure their actions do not create an unacceptable risk to anyone’s health, welfare, safety or security
- report any concerns regarding safety and security.
Ethical check process
WaterAid follows an ethical checking process for our donors, suppliers and implementing partners. It assesses reputational risks and considers factors such as compliance with national laws, extent of subsidiary links and supply chains, any regulatory investigations (eg linked to labour standards or environmental standards), links to fraud or bribery and other ethical issues that may be in conflict with WaterAid’s stated values, aims and objectives. We will not enter into a relationship with another organisation if we are not satisfied that they meet our ethical standards. We take our ethical policies and standards extremely seriously and any breach can lead to disciplinary action, cessation of contract and potential law enforcement action.
We work with a wide variety of partner organisations, ranging from those providing building services and water bore-hole construction to fundraising organisations and commercial participators. Our programme work in our country programmes is mainly done through local partner organisations, to ensure that we invest in and empower local communities. We will always ensure that we follow the local legal system and promote ethical practices throughout our work both in the UK and internationally.
We conduct due diligence on all potential new partners and this includes an ethical check. We also set financial control and other standards for our implementing partners, and this includes minimum requirements in respect of procurement and contracting.
As a non-profit organisation, we rely on the generous work that our volunteers do in promoting our work. We strengthened our volunteer policies and procedures in the last two years to better support our volunteers, and we also include them in any mandatory or other applicable training, such as safeguarding and data protection. Our organisational policies, such as the Code of Conduct, apply to staff and volunteers.
Whilst we recognise the importance of voluntary work, it in no way seeks to replace paid staff with the work of volunteers, and we do not expect volunteers to conduct work that a paid member of staff should be completing.
Since our last Modern Slavery Statement for the year 2017-18
- We updated the Reporting Malpractice and Breaches of the Global Code of Conduct Policy. This outlines all the avenues a staff member, volunteer or partner can take to report suspicions of malpractice or safeguarding concerns.
- We introduced a whistleblowing telephone number and email address for those who want to report anonymously.
- We appointed Safeguarding Focal Points, based in all Country Programmes who are trained at identifying safeguarding concerns and instances of harm and abuse. They are trained in how to investigate and respond to incidents of this kind.
- Any breach of the Global Code of Conduct or other forms of abuse are now registered on a central global register. This helps us ensure that we meet statutory or regulatory reporting requirements.
- We updated the ethical checking process that ensures that we do not enter into agreements with, or take donations from, organisations or individuals whose work or actions undermines the achievement of our mission or would damage our reputation or credibility. Organisations shown to have been involved in criminal or regulatory investigations in the last 10 years would be considered high risk and further extensive checks would always be conducted before entering into any relationship.
- We recruited a Contract Lawyer to ensure that all contracts are of an appropriate standard to help ensure that we meet regulatory and statutory requirements (such as modern slavery and data protection). The role also works with other departments to strengthen the procurement process in the UK and specifically to ensure more rigorous due diligence for suppliers.
- We recruited a Global Safeguarding Manager who has produced a suite of Global safeguarding policies and procedures as well as embedding safeguarding practices around the organisation, conducting training with staff and partners and investigating incidents.
- We recruited a Fundraising Compliance Manager. Part of their role includes developing and rolling out an enhanced due diligence framework focussed on suppliers and third parties working with our Fundraising Teams. One example of this is our telephone fundraising agencies and ensuring that no one is recruited on commission-only paid roles.
- We have drafted detailed Procurement Guidance for our country programmes and this is currently being finalised and approved and will be rolled out throughout 2019.
- We are in the process of recruiting a Senior Audit and Compliance Manager, whose role will include reviewing our operations against the requirements of the Modern Slavery Act.
- We identified policies, such as the Global Accounts Manual, where changes can be made to better reflect the Modern Slavery Act requirements. We shall be working on these improvements throughout 2019-20.
- We have identified improvements that can be made to our supply chain due diligence mechanisms. We will roll out an enhanced supplier due diligence process over the coming year. This will include due diligence questionnaires, compliance monitoring and annual assurance statements.
- We will enhance our staff and partner training in anti-slavery, trafficking, child protection, safeguarding, fraud and bribery, and strengthen monitoring to ensure all compulsory training is completed (e.g. child protection training).