National Nuclear Laboratory Limited (“NNL”) – Modern Slavery Act Statement – 2023
Section 54 of 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 by NNL during the financial year ending 31 March 2023 to ensure slavery and human trafficking is not taking place in any of NNL’s business or supply chains. It also considers what further steps NNL can put in place to continually improve.
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 own business and supply chains. Accountability is assigned to the NNL Chief Financial Officer, with the Procurement Team undertaking day to day management.
NNL 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. NNL is the only trading company within the group which meets the requirements of Section 54(1) of the Act.
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 eight sites in Cumbria, Lancashire, Cheshire, Leicester, Gloucestershire, Oxfordshire and Wales, 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’s Supply Chain
NNL will not engage in business with any supplier or individual known to engage in practices which are in breach of the Act and takes a zero-tolerance view to any suppliers who are found in breach of the Act after contract award.
NNL has ensured that CIPS Ethical Procurement and Supply e-Learning has been undertaken by members of the Procurement team.
Terms and conditions require our suppliers and each of their subcontractors to comply with the Act.
NNL carries out due diligence throughout the tender supplier selection process, including use of the UK Government Supplier Questionnaire, which contains specific requirements related to the Act, for all contracts valued over £100,000. NNL also use supplier intelligence sources, such as Rapid Ratings and Dun & Bradstreet to provide confidence that our suppliers are financially, ethically and legally sound. If a supplier is found to be in breach of the Act or found to have misled NNL during the tendering process, steps will be taken to measure the impact of the breach, and if necessary, terminate the contract.
Consideration has been given to NNL’s supply chain and due to the geographical nature of our suppliers (see chart) and the types of products/services procured, the risk is considered low. NNL is committed to periodic reviews of our suppliers, in particular where multi-year contracts are placed. This allows us to reassess any, or all, of the information provided at the time of the contract award and highlight any areas for improvement, including where the supplier is in breach of, or falling short of, the conditions of the Act.
In addition, in October 2022, NNL signed up to the Government’s Modern Slavery Assessment Tool (“MSAT”) and will be trialling the toolkit with a small number of suppliers during the first half of 2023, with a view to rolling this out for all suppliers in the second half of the year.
NNL has an Anti-Slavery and Human Trafficking Policy which has been endorsed by the NNL Executive Leadership Team and communicated to all employees and staff via NNL’s Information Management System.
Training and awareness on NNL’s procurement process is available to all staff via NNL’s e-Learning platform and Management System.
NNL is continuing to work to increase awareness within our organisation and to ensure a high level of understanding of risks, including modern slavery and human trafficking, in our supply chain and in our business.
Developments from Modern Slavery Act statement 2022
NNL has implemented a risk assurance tool for all suppliers who we spend more than £25k per annum with. This features in-depth questionnaires regarding supplier’s policies, operations, and their respective supply chains. There is a specific section dedicated to modern slavery and ethical business practises within the questionnaires, of which, suppliers are requested to respond in detail. All submissions are vetted, and the tool then produces a score based on the level of risk the supplier poses to NNL’s mission: ‘to work with an ethical supply chain who are opposed to anti-slavery and human trafficking’. The risk assurance tool will be reviewed annually with updated forms submitted by each supplier to NNL on an annual basis and the risk subsequently refreshed. Any suppliers who are found to be non-compliant with applicable laws or NNL’s policies are either removed from NNL’s supplier base or informed and supported so that they can become compliant with applicable requirements and best in class business practices.
In addition, NNL has put in place a plan to trial the Government’s MSAT risk identification and management tool (noted above).
NNL carries out periodic reviews of our suppliers, in particular where multi-year contracts are placed to ensure that such contracts contain terms requiring our suppliers and each of their subcontractors to comply with the Act. This includes utilising Government audited frameworks and suppliers. NNL have drafted a specific Sustainable Procurement Policy, which includes Modern Slavery. This will be finalised and approved by the Board during the current financial year.
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 31 March 2023.