Barnardo’s and the Modern Slavery Act
Barnardo’s is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking. This statement is made on behalf of Barnardo’s and its relevant subsidiaries in line with Section 54 of the Act.
Barnardo’s Business Model and supply chain
Barnardo’s is a charity registered in England and Wales and Scotland. It is governed by its Articles of Association and its objects are to promote the care, safety and upbringing of children and young people and the relief of those in need by reason of age, ill health, disability, financial hardship or other disadvantage.
Barnardo’s owns the whole of the issued capital of Barnardo Holdings Limited, which in turn owns the whole of the issued capital of the following subsidiaries, operating with the following principal activities:
- Barnardo Developments Limited – property development
- Barnardo Events Limited – sponsorship and special events
- Barnardo Services Limited – childcare services
- Barnardo Trading Limited – retail, online and direct marketing
- Barnardo’s Garden Village Management Company Limited – property management
- Adoption Plus Limited – specialist adoption services
Barnardo’s uses a large number of suppliers across all of its functions, to enable it to carry out its charitable purposes. These range from fundraising and retail suppliers to those used in property redevelopment and the provision of office facilities and recruitment services.
Independent Child Trafficking Guardianship Service
Barnardo’s runs the Home Office commissioned Independent Child Trafficking Guardianship Service (ICTGS) in Wales/Cymru, East Midlands, West Midlands Combined Authorities, Bedfordshire, Gloucestershire (including Bristol), Warwickshire, all London Boroughs, Hampshire and the Isle of Wight, Kent, Surrey, Essex, Greater Manchester, North and West Yorkshire, Lancashire and Merseyside. The ICTG Service is underpinned by the Modern Slavery Act 2015, Section 48 by:
- building trusting relationships with trafficked children to help them build a positive future.
- helping children navigate the criminal justice, immigration, and social care systems.
- giving practical support, such as help with housing, medical needs, and education.
- giving emotional and psychological support
- training professionals working with children so they can spot the signs of trafficking and know how to support trafficked children
Barnardo’s is a First Responder for the National Referral Mechanism and has a duty to ensure that all young people we work with who have been suspected of trafficking under Section 52 of the Modern Slavery Act 2015 are referred to the Single Competent Authority in the Home Office. A referral into the National Referral Mechanism enables children to be identified as a potential and confirmed victim of trafficking. Barnardo’s Services work with the SCA and the local authorities involved with the child’s care to provide appropriate safeguarding.
Governance and policies
Barnardo’s has a zero-tolerance approach to modern slavery and human trafficking and is fully committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that it is not taking place anywhere within Barnardo’s or in our supply chains.
The Board of Trustees has overall responsibility for ensuring this statement complies with our legal and ethical obligations, and that it is reviewed on an annual basis. Management is responsible for raising awareness and implementing the relevant policies.
Barnardo’s has considered its strategy of implementing the measures set out in its previous statement and concluded that whilst the pandemic and subsequent economic challenges have delayed the work, good progress has been made recently. Our Corporate Leadership team will continue to monitor progress against the actions through the next year.
Procurement
We have comprehensive Procurement Policies and Procedures in place which seek to ensure modern slavery is addressed throughout the procurement process. We have recently reviewed our procurement policy and procedures and supplier code of conduct. The responsible procurement policy and a comprehensive ‘how to buy’ guide for budget holders and other key stakeholders will provide a clear statement and central framework for conducting procurement and managing contracts.
Barnardo’s Responsible Procurement Policy and Suppliers Code of Conduct requires all direct suppliers, service providers and contractors to answer questions on modern slavery and be committed to preventing modern slavery within their own activities and through their supply chain. We conduct due diligence of potential suppliers in relation to modern slavery risk before they enter the supply chain. This will continue once a supplier has been appointed via contract management activities.
In order to assess the risk of modern slavery in our existing supply chains and to understand the operating context of the charity, Barnardo’s has continued to conduct detailed audit and risk assessment of our existing suppliers, which is a long-term project given the size of the organisation. We will take action to eliminate and/or reduce the risk of modern slavery where appropriate. For any overseas suppliers to our Retail business, we have a due diligence process in place to ensure compliance.
Barnardo’s is committed to ensuring that all Trustees, employees and volunteers are provided with appropriate guidance and training on the principles of responsible procurement relevant to their roles and responsibilities. We regularly review and monitor the effectiveness of our procurement framework and update it as considered appropriate. In line with our continuous learning principles, a new wave of training on responsible procurement has been rolled out in 2023, targeting those members of staff who are budget holders with responsibility for procurement.
Recruitment
As an equal opportunities employer Barnardo’s has a rigorous recruitment process. Our recruitment practices include ‘right to work’ checks for all prospective employees. This ensures we maintain an assured overview of those entering our employment and prevents the occurrence of forced or involuntary labour. We have also recently conducted a comprehensive assessment of all recruitment agencies supplying staff to Barnardo’s and established a Preferred Supplier List (PSL) which ensures all recruitments are conducted through vetted suppliers in accordance with our Supplier Code of Conduct.
Programme of continuous improvement
In addition to the steps set out above Barnardo’s will progress its commitment to the principles of the Modern Slavery Act by:
- rolling out a refresher awareness training to all staff and volunteers
- ensuring modern slavery is addressed in all key policies and procedures across the charity
- continuing to ensure that suppliers are risk assessed and that risks identified are appropriately addressed
Mark Wood
Chair of the Board of Trustees
March 2024