Modern Slavery Statement
The Money Advice Trust wishes to ensure that we do not knowingly participate with any activity or organisation that involves any form of modern slavery.
Modern slavery is a term used to encapsulate various forms of servitude, forced or compulsory labour and human trafficking. The Money Advice Trust and its operating names National Debtline, Business Debtline and Wiseradviser (all referred to as “the Trust”) are committed to conducting our business responsibly and have a zero tolerance approach to the issue across our business and supply chain.
It is estimated that around 40 million innocent men, women and children have been forced into various forms of modern slavery, around the world. The estimated number of victims of modern slavery in the UK has markedly increased in recent years to approximately 136,000 individuals (2018 Global Slavery Index). This has been estimated to generate £116bn in profits each year, across the world. A third of this is generated in developed countries, including the UK.
We realise that modern slavery is a complex and growing global issue that affects millions of people around the world. The Trust is committed to ensuring its practices combat slavery, including forced, bonded or compulsory labour and human trafficking. We strive to ensure that modern slavery is not taking place anywhere in our own business or in our supply chains.
This statement, pursuant to the UK Modern Slavery Act 2015 (the ‘Act’), is our first under the Act and relates to the financial year ending 31 December 2020. We fully support the aims of the Act and associated standards such as the UN Guiding Principles on Business and Human Rights (UN Guiding Principles) and are committed to tackling slavery and human trafficking wherever we can.
The following statement includes our current policies and practices and the steps we plan to take over the coming 12 months, to further improve our commitment to meeting the principle and the Act.
The Trust is aware that by producing this statement on modern slavery, we are committing to ensuring our working practices and those of our partners minimise the impact our business activities to help combat modern slavery in the UK.
This first modern slavery statement is the first step in helping to set out the Trust’s pathway to achieving this within all our services and activities. The preparation work we have completed within our policies, procedures and practices so far has seen changes made to the following areas:
- Anti-corruption and Bribery Policy
- Code of Conduct
- Recruitment and selection
- Right to work Procedures
- Safeguarding Policy
- Whistleblowing Policy
In reviewing these polices and processes we were able to ensure that the processes relating to each of these polices, minimised the risk of the Trust breaching the Modern Slavery Act (2015) principles.
The Trust is aware that there are areas it can further improve to reduce the risk of breaching the Acts principles. The main areas we are now working on are:
- Creating a supply chain mapping process, to identified risks within this and with our suppliers,
- Update and improve our procurement process, to ensure that we are assessing the risk posed by procuring services and supplies,
- Due diligence audit to assess the risk associated with procurement and contracts for services and supplies,
- In doing the above we will aim to create a risk assessment process to monitor and track all areas of risk and give them a risk rating that can be used as part of the procurement or contract decision making process,
- Improved contracting process, to build in modern slavery conditions and ensure the Trust can terminate, or amend the contract if modern slavery breaches are identified that significantly increase our risk and exposure to being linked with modern slavery practices,
- To create and provide training programmes to raise awareness and requirements for all staff, ensuring the risk to the Trust is minimised, in relation to modern slavery.
The plan for the next 12 months is outlined in the full statement, with the main aims being to train all staff and put process and practices in to place to reduce the impact of our future activities being associated with breaches of the modern slavery principles through procurement and contracting.
The term “modern slavery” refers to the offences of human trafficking, slavery, servitude, and forced or compulsory labour. This can then be considered under five headings:
- The sexual exploitation of adults
- The trafficking of adults into conditions of labour exploitation
- The trafficking of adults into conditions of criminal exploitation
- The trafficking of minors into conditions of sexual, criminal or labour exploitation
- Other forms of exploitation
Human trafficking involves the recruitment, transfer or obtaining of an individual through coercion, abduction, fraud or force, to exploit them. Although human trafficking often involves an international cross-border element, it is also possible to be a victim of modern slavery within our own country. There are several broad categories of exploitation linked to human trafficking including sexual exploitation, forced labour, domestic servitude, organ harvesting, child related crimes, forced marriage and illegal adoption.
Modern slavery includes victims who have been brought from overseas and vulnerable people in the UK who are forces to work illegally against their will across many different sectors.
This statement sets out the Trust’s actions to understand all potential modern slavery risks related to our business interests and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in any part of the Trust or its supply chains. This statement relates to actions and activities during the financial year 1 January 2020 to 31 December 2020. We will endeavour to publish our annual statements before the 30 June each year. This is designed to follow our annual report (and any other annual publications we need to make available on our website each year).
As part of money advice sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. The Trust is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensure that our supply chains are free from slavery and human trafficking.
People across the UK tackle their debts and manage their money with confidence
Supporting people and small businesses to deal with their debt, training the free advice sector to help them, and improving the UK’s money and debt environment
Be balanced, Be supportive, Be innovative
The Trust’s structure
The Trust works to help people across the UK to tackle their debts and manage their money with confidence. We do this by providing telephone and web-based debt advice through National Debtline and Business Debtline to support people and small businesses to deal with their debt. We also train debt advisers in the free advice sector through Wiseradviser, and campaign to improve the UK’s money and debt environment. Our expert advice services are available in England, Wales, Scotland and Northern Ireland.
This activity supports our charitable objectives which are the relief of poverty including, but not limited to, that arising from indebtedness and the advancement of public education in all matters relating to the management of personal finances. The Board has developed strategic plans to ensure that the Trust provides public benefit and achieves its aims as set out in its governing document. The Board confirms that it has complied with the duty in section 17 of the Charities Act 2011 to have due regard to public benefit guidance published by the Charity Commission in determining its activities.
Our policies and procedures are designed to ensure that ethical behaviour forms the basis of our ways of working. We ensure all staff are trained in safeguarding, which includes being aware of what modern slavery is and how it can happen. We will continue our programme to update all relevant policies to include appropriate references to the risk of modern slavery. We also operate numerous risk controls to protect staff and clients’ personal information, and to ensure that our systems and services are not used to perpetrate or facilitate crime, including modern slavery.
We have circa 260 staff. The Trust carries out appropriate pre-employment checks prior to commencement and staff complete mandatory training to ensure they understand and comply with our values and policies. Appropriate references to modern slavery are incorporated into relevant aspects of our recruitment processes and training. We are a Living wage foundation recognised employer, with all our staff receiving at least a real living wage.
Our supply chain
The Trust uses a wide range of suppliers to conduct its business, with the majority of these being from within the UK. They supply a wider range of services and goods to ensure that we can continue to deliver our services to our clients.
The Trust recognises the importance of its role in implementing the guidance of the Modern Slavery Act. Those involved in procurement are aware of the risk of modern slavery specifically, and our Financial Procedures on procurement and tendering, set out our requirement for buying goods, services and sets out the due diligence required to be completed on suppliers. The Trust’s code of conduct and whistleblowing polices are designed to encourage staff to report any concerns.
An ethical procurement and tendering process will be developed in the coming year building on the existing process and will include a specific section on risk of modern slavery in our supply chain. The ethical procurement and tendering process will be used to further draw the attention of our people to the risk relating to modern slavery and child and forced labour, ensuring that they have access to the necessary information and most importantly how they can report any concerns they have.
Responsibility for our anti-slavery initiatives is as follows:
- Policies: Each department has been allocated responsibility for ensuring that all policies, within their specialisms, are up to date with the latest legislation and good practice. These policies are reviewed and signed off by the appropriate executive committee and in appropriate cases signed off by the Board and consulted about with our Trade Union Representatives, before being implemented. All polices are developed and reviewed in-line with good practice and the Trust’s Values, which are ‘Be Balanced’, Be Supportive, Be Innovative.
- Risk assessments: We are currently developing a process for supply chain mapping and creating a human rights risk assessment.
- Investigations: All suspected breaches of the Modern Slavery Act are reported to Head of Risk and Compliance, who would arrange further investigation and if appropriate share this with the relevant external authority, to take further action.
- Due diligence: The Trust carries out due diligence on all new suppliers and contracts. This process is outlined in the Trust’s Financial Procedure policy and Guide to Entering a Contract document. These checks are carried out by our Finance Manager and the individual who is responsible for signing the contract or agreement.
- Training: We are currently developing training for staff who are involved in agreeing contracts and procuring new suppliers, this includes a section on our Code of Conduct, and we are building capacity across key staff to enhance supplier engagement regarding human rights. Additional training and engagement activities will be developed as appropriate as we continue to advance our human rights and modern slavery program.
The Trust’s staff have access to the following polices, which are reviewed on an annual cyclical programme:
- Recruitment Policy
- Code of Conduct
- Whistleblowing Policy
- Anti-corruption Policy
- Financial Procedures (including procurement procedures)
- Guide to Entering into Contracts
- Safeguarding Policy
- Environmental Policy
Through these policies and the measures below we aim to prevent modern slavery occurring at the Trust or in our supply chains:
- All staff have undertaken mandatory training in safeguarding which covers modern slavery.
- Staff are aware of how to report incidents of concern and are encouraged to do so. They can do this through their managers or through our whistleblowing procedure.
- Safeguarding incidents are reported to the safeguarding panel.
- An appropriate procurement process is in place to satisfy ourselves all suppliers meet our policies and procedures.
- Pre-employment checking to minimise the risk of modern slavery within our recruitment process.
We undertake due diligence when considering using new suppliers, and regularly review existing suppliers. We aim to incorporate the following into our due diligence process:
- mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking.
- evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment].
- reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping.
- conducting supplier audits or assessments through our own staff and or third-party auditor, which have a greater degree of focus on slavery and human trafficking where general risks are identified.
- creating an annual risk profile for each supplier.
- participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking, ensuring our investments are managed ethically and do not cause conflict with our commitment to the principles of modern slavery.
- using an ethical supplier database, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking.
- invoking sanctions against suppliers that fail to improve their performance in line with an action plan or for those who seriously violate our supplier code of conduct, use the termination of the business relationship.
We have reviewed our key performance indicators (KPIs). As a result, we are:
- requiring all staff to have completed training on modern slavery by mid 2022;
- developing a system for supply chain verification expected to be in place by mid 2022, whereby we evaluate potential suppliers before they enter the supply chain; and
- reviewing our existing supply chains expected to be completed by mid-2022, whereby we evaluate all existing suppliers.
We require staff working with new suppliers or contracts to sign up to one of a number of training sessions that are being planned between late 2021 and early 2022.
Our modern slavery training covers:
- Our organisation’s purchasing practices, which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline.
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available.
- how to identify the signs of slavery and human trafficking.
- what initial steps should be taken if slavery or human trafficking is suspected.
- how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation.
- what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and “Stronger together” initiative.
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains.
As well as training staff, we have raised awareness of modern slavery issues by circulating a series of emails to staff, as well as links on our intranet pages.
These will explain to staff:
- the basic principles of the Modern Slavery Act 2015;
- how employers can identify and prevent slavery and human trafficking;
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
- what external help is available, for example through the Modern Slavery Helpline.
This statement was approved on 23 September 2021 by our Trustees, who
review and update it annually.
Date: 23 September 2021