National Nuclear Laboratory Limited (“NNL”) – Modern Slavery Act Statement – 2021
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 2021 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 (“BEIS”). NNL is the only trading company within the NNL group.
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’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 l members of the Procurement team. Further training and awareness sessions are to be rescheduled (due to COVID-19 restrictions) for the wider business, such as NNL’s internal audit team, as appropriate.
NNL’s standard terms and conditions require our suppliers and each of their subcontractors to comply with the Act.
NNL practices robust due diligence throughout the tender supplier selection process, including use of the UK Government Supplier Questionnaire (“SQ”) for all contracts valued over £100,000 which contains specific requirements related to the Act. NNL also use supplier intelligence sources, such as Rapid Ratings and Dun and Bradstreet to ensure that all 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, immediate 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 below) and the types of products/services procured, the risk is considered low. However, we are not complacent in any of our assumptions. 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.
NNL is continuing to work to increase awareness within our organisation and to ensure a high level of understanding of the risks associated with modern slavery and human trafficking in our supply chains and in our business.
Developments from Modern Slavery Act statement 2020
NNL has recently implemented a new risk assurance tool for current suppliers (with the top 100 based on spend having been uploaded as at FY ending 31 March 2021) which 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 upon in detail. All submissions are vetted rigorously, 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 incompliant to applicable laws or NNL’s
policies are either removed from NNL’s supplier base or educated and supported so that they can become compliant with applicable legislation and best in class business practises.
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 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 Management System.
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 2021.
Chief Financial Officer
National Nuclear Laboratory Limited