Modern Slavery Act Statement
Modern Slavery Act Statement 2016-17
National Nuclear Laboratory Limited (“NNL”)
The Modern Slavery Act 2015 (’the Act’) requires organisations with an annual turnover above £36 million to publish an annual slavery and human trafficking statement. NNL’s annual turnover exceeds this threshold.
This statement outlines the actions taken to ensure slavery and human trafficking is not taking place in any of NNL’s business or supply chains and considers the future steps NNL can put in place to make improvements over time.
NNL is committed to preventing modern slavery and human trafficking. NNL will not tolerate the abuse of men, women or children and strives for total transparency right through its business and supply chains. Accountability is assigned to the NNL Chief Financial Officer with the Procurement Team undertaking day to day management.
NNL Limited is a wholly owned subsidiary of NNL Holdings Limited, which in turn is a wholly owned subsidiary of the Department for Business, Energy and Industrial Strategy (DBEIS). NNL Limited is the only trading Company within the NNL Group.
NNL’s former name was Nexia Solutions Ltd whose business was originally owned by British Nuclear Fuels plc. (’BNFL’). In 2009, ownership of NNL transferred from BNFL to the Department of Energy and Climate Change (‘DECC’) and management was delegated to a consortium made up of Serco, Battelle Memorial and Manchester University. In 2013, the management contract ended and NNL became a Government owned, Government operated organisation, now reporting to the DBEIS.
As the UK’s National Nuclear Laboratory, NNL offers a breadth of technical advice; solutions; products and services supporting the complete nuclear fuel cycle, from fuel manufacture and power generation to reprocessing, waste treatment and disposal. We operate from six sites in Cumbria, Lancashire, Cheshire, Gloucestershire and Oxfordshire, although most of our work is focused around our sites in the North West of England, and we are the second biggest industrial employer in West Cumbria.
NNL plays a central role in the co-ordination of UK nuclear research and development and maintains close links with academia and industry. We support Government in safeguarding the UK’s nuclear skills and capabilities and provide advice on key strategic decisions.
NNL Supply Chain - activities undertaken
NNL will not willingly engage in business with anyone in breach of the Act and takes a zero tolerance view to Suppliers who are found in breach of the Act after contract award. High level consideration has been given to NNL’s supply chain and due to the geographical nature of our suppliers (see chart below) and the types of products/services procured, the risk is considered low. However we are not complacent in any of our assumptions.
NNL’s standard Procurement terms have recently been updated in line with the Act with the insertion of the following clause:
7.5 …………., the Supplier shall:
7.5.1 comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015;
7.5.2 have and maintain throughout the term of the Contract its own policies and procedures to ensure its compliance;
7.5.3 not engage in any activity, practice or conduct that would constitute an offence under sections 1, 2 or 4, of the Modern Slavery Act 2015 if such activity, practice or conduct were carried out in the UK; and
7.5.4 require that each of its sub-contractors and suppliers shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015.
7.6 NNL may terminate the Contract with immediate effect by giving written notice to the Supplier if the Supplier commits a breach of Condition 7.5.
NNL has also made a commitment to the Procurement function to complete the CIPS Ethical Procurement and Supply online training package. Awareness training will also be made available to other departments within NNL.
NNL is committed to the Act and its purpose to eradicate slavery and human trafficking. NNL Procurement will continue to evaluate the supply chain and engage with tier one suppliers to trace the full supply chain to gain greater awareness.
The forms used by NNL Procurement to engage with suppliers will also be reviewed in the coming months to incorporate question(s) in the most appropriate form, providing greater insight into the supply chain.
The ETI (Ethical Trading Initiative) Base Code will be reviewed and consideration given to obtaining commitment from targeted suppliers to this internationally recognised set of labour standards.
NNL will give consideration to publishing a slavery and human trafficking policy and in line with this will review the NNL Corporate Social Responsibility Charter to substantiate as appropriate.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes NNL’s slavery and human trafficking statement for the financial year ending 31st March 2016.
Head of Procurement
Chief Financial Officer
National Nuclear Laboratory Limited
Date: October 2016