Modern Slavery Act statement September 2021
We recognise the impact that modern slavery can have on people’s lives. In 2016, the International Labour Organisation stated an estimated 40 million people were trapped in modern slavery. 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. We would not work with any organisation that our ethical checks had caused us to suspect of involvement in modern slavery.
This statement made in relation to the Modern Slavery Act relates to the financial year, ending 31 March 2021. It demonstrates our commitment to the Act and to promote transparency across all areas of our work. It is approved by the Trustees and signed by the Chair of our Board of Trustees, Andy Green, on 8 September 2021. 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
At WaterAid, 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 an international non-government organisation, part of a global federation of member organisations working in 34 countries worldwide. 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 850 staff in 23 countries, 378 of which are based in the UK.
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 policies for staff and partners, and our operations and supply chains. These demonstrate our commitment to this issue and help ensure that appropriate and coordinated action is taken throughout the organisation.
Global Code of Conduct
All existing and new staff, and all those who represent WaterAid, 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
- 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 safeguarding, fraud, safety and security.
There is also a procedure in place for reporting malpractice and breaches to the Global Code of Conduct. Our organisational policies and the Global Code of Conduct also apply to our volunteers, whose generous support we rely on to achieve our objectives.
For WaterAid to successfully achieve its objectives, it requires the support of third parties. They provide capacity, expertise and added value to enable us to undertake all our operations. WaterAid has due diligence procedures in place for all suppliers and requirements include: assessing financial stability; reviewing policies including modern slavery; and having a written, signed contract in place which meets regulatory and statutory requirements. Additional requirements are in place for all fundraising suppliers and any suppliers classed as high risk.
Our programme work in our country programmes is mainly done through local partner organisations, to ensure that our work is informed by local knowledge. 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 new partners. We also set financial control and other standards for our implementing partners, and this includes minimum requirements in respect of safeguarding, procurement and contracting. We conduct checks to ensure that our partners do not appear on the list of terrorist groups or other organisations banned under UK law.
WaterAid follows an ethical check 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 (e.g. 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.
International development, by its very nature, carries a degree of inherent risk. For WaterAid to achieve our mission of transforming lives by improving access to safe water and sanitation in the world’s poorest communities it is necessary for us to take managed risks and to capitalise on opportunities.
WaterAid is risk averse when it comes to the protection of our reputation and the safety of our people and will take managed risks in respect of investing in our work and in developing the organisation to have greater impact.
The identification and management of strategic risks would include modern slavery where appropriate. Strategic risks are discussed at meetings of the Board and the Audit Committee.
WaterAid have introduced Quality Programme Standards to ensure we maintain high quality and ethical methods in our programme work, and to inspire and motivate others to adopt good standards in the delivery of water, sanitation and hygiene services. These standards are used at every stage of the planning, monitoring, evaluating and reporting cycle of our projects and programmes.
WaterAid conducts training to raise awareness and ensure staff understand the importance of issues deemed to be of high risk. It also helps staff to understand what they need to do and how to work together internally or externally if they encounter something that raises concerns. The following training courses are mandatory for existing and new staff, which combined, seek to reduce the risk of modern slavery in our work:
- Data Protection
- Cyber Security
Training on fraud, equity, discrimination and inclusion, partnerships, and recruitment is available to all staff. Volunteers are also included in any mandatory or other applicable training. Each of our country programmes has a safeguarding focal person, who ensures that all WaterAid staff have completed mandatory training and who also conducts a programme of training for our partner staff. Our Global Safeguarding Team provides guidance and support to the safeguarding focal points.
We have in place the following policies and procedures, which combined, seek to further reduce the risk of modern slavery in our work:
- Procurement Guidance for Country Programmes, which include due diligence requirements
- Environmental Statement and Policy and Environmental Group which promotes ethical and sustainable business practices
- UK and Global Accounts Manuals including procurement requirements
- Recruitment policy and process and hiring manager guides including Safer Recruitment
- Grievance Policy
- Access for staff to a free Confidential Counselling and Advice Helpline in the UK and support and counselling services available to country programme staff.
- Federation Standards including safeguarding, ethical standards, finance and risk.
Since our last Modern Slavery Statement for the year 2019-20
- We have increased safeguarding capacity with the creation of a Global Safeguarding Team.
- Recruited a Governance and Legal Support Officer who assists with the meeting of regulatory and statutory responsibilities as well as standards of best practice.
- Designed and delivered bespoke safeguarding training to Safeguarding Focal Points in all our country and member offices, increasing their knowledge and capacity.
- Developed and started to implement our Global Safeguarding Strategy.
- Improved our safeguarding tools for working with partners and communities to ensure effective contextual safeguarding methods are in place.
- Contributed to the design of a sector wide open source Community Based Safeguarding visualisation toolkit, to improve accessibility to reporting mechanisms for communities.
- Completed an internal audit of our Mandatory Operating Procedures, covering safeguarding, security and financial controls. These are defined as the most important WaterAid procedures that must be maintained, even during times of crises, over and above all others. They ensure we can continue working to achieve our mission, whilst upholding our most basic legal, moral and contractual duty of care to all stakeholders.
- We have commissioned a full internal safeguarding audit against our federation safeguarding and child protection standards. This will allow us to assess the impact of our Global Safeguarding Strategy.
- In consultation with communities, and including young people, we will be reviewing a number of key safeguarding policies.
- Continuing our safer recruitment development and ensuring all individuals whom we employ are appropriate through the highest levels of criminal record checks possible.
- We are in the process of updating the Global Accounts Manual, where changes can be made to better reflect the Modern Slavery Act requirements.
- We have recruited a Global Ethical Checks Manager who will bring our third-party ethical checks in house and will review and refresh our processes, and ensure that all third parties we work with meet our ethical standards.