Modern Slavery Act statement September 2020
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 2019-20, ending 31 March 2020. It 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, on 9 September 2020. 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 800 staff globally, 336 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 and staff and partners, and our operations and supply chains. These demonstrate our commitment to this issue and helps ensure that appropriate and coordinated action is taken throughout the organisation.
We have in place the following policies and procedures which combined, seek to reduce the risk of modern slavery in our work:
- 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
- Grievance Policy
- Access for staff to free Confidential Counselling and Advice Helpline
- Federation Standards including safeguarding, ethical standards, finance and risk.
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
- 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.
There is also a procedure for reporting malpractice and breaches to the Global Code of Conduct in place. 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, including fundraising organisations and commercial participators. They provide capacity, expertise and added value to enable us to undertake all our operations. WaterAid has due diligence procedures in place and requirements include: assessing financial stability, reviewing policies including modern slavery and having a written, signed contract in place which meet regulatory and statutory requirements.
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. We also set financial control and other standards for our implementing partners, and this includes minimum requirements in respect of procurement and contracting.
Ethical check process
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 (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.
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 WASH. 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 Manager provides guidance and support to the safeguarding focal points.
Since our last Modern Slavery Statement for the year 2018-19
- We partnered with Protect who provide an independent third-party external reporting line which can be accessed by staff, partners, volunteers and the public.
- 2019 saw WaterAid implement safeguarding audit checks in Country Programmes to monitor safeguarding policies and procedures and to highlight any challenges.
- We recruited a Compliance Officer, increasing our capacity to ensure our third-party due diligence is robust. This role has also focused on operationalising a Compliance Manual, a point of reference to support fundraisers carrying out effective due diligence on partners and other legal, regulatory and best practice requirements.
- We introduced a new fundraiser induction process, which covers supply chain due diligence and emphasizes that we are equally responsible for any actions by our fundraising partners, so our monitoring of them must be comprehensive and robust.
- We have initiated a contract register to ensure that all contracts are recorded centrally and are of an appropriate standard to help ensure that we meet regulatory and statutory requirements. Our In House Lawyer provides contracts training to ensure every third party we work with agree to meet our requirements eg has a modern slavery statement if required
- Our internal audit team undertook a review of our supplier due diligence process. The audit made recommendations for improvements to our supply chain due diligence process.
- In January 2020, we updated our Risk Policy to reflect our updated risk management framework. This helped increase overall awareness of risk throughout WaterAid and to support those responsible for managing risk to better identify, assess, report and control risks.
- We have rolled out detailed Procurement Guidance for our country programmes, designed to increase transparency and ethical practices and reduce the risk of loss, poor value for money and inappropriate procurement practices.
- Mandatory Operating Procedures have been defined, which highlight the most important WaterAid procedures that must be maintained, even during times of crisis, 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 our stakeholders.
- We are expanding our global safeguarding function to include a Global Safeguarding Officer, this will help in building capacity across the federation and provide support to the Global Safeguarding Manager.
- 2020 will see us embark on our first two-year federation wide safeguarding strategy to ensure all areas of safeguarding are fully embedded in everything that we do.
- We have identified improvements that can be made to our supply chain due diligence mechanisms. This will include the completion of due diligence checklists, which includes the requirement to publish a Modern Slavery Statements, and more regular and documented supplier visits.
- We had commenced the process of recruiting for an Ethical Check Process Manager to bring our third-party ethical checks in house and enables us to review the process, improve it and ensure all third parties meet our requirements in terms of the ethics of working with them. (Recruitment is currently on hold during the COVID-19 pandemic).
- Included in our Internal Audit plan in 2020-21 is a review of our ethical process, including the policy and process and sample of previous ethical checks made.
- We plan to further assess the nature and extent of our exposure to the risk of modern slavery, using relevant information from internal and external sources. This will enable us to take more targeted action to identify, remedy and prevent modern slavery occurring in the future.