Modern Slavery statement

UK Shared Business Services Ltd (UKSBS) fully supports the UK Government’s objectives to eradicate modern slavery and human trafficking, constituted in the Modern Slavery Act 2015 by the offences of ‘slavery, servitude and forced or compulsory labour ’and ‘human trafficking’ and is an abuse of human rights.

This statement sets out the policies, processes and actions that we have taken to understand the potential risks and impacts to UKSBS from Modern Slavery during the 2024/25 financial year and is in full accordance with the following legislation and guidance:

  • Section 54 of the Modern Slavery Act (2015)
  • Procurement Policy Note (PPN) 02/23 Tackling Modern Slavery in Government Supply Chains (under The Public Contracts Regulations 2015 (PCR2015) (as amended)
  • PPN 009 Tackling Modern Slavery in Government Supply Chains under The Procurement Act 2023 (PA2023) (as amended)
  • Home Office Transparency in Supply Chains (TISC) Statutory Guidance.

UKSBS Organisational Structure

UKSBS is a private company limited by shares, classified as a Non-Departmental Public Body, subject to all applicable UK legislation and required to comply with all relevant Government policies and guidance for public bodies, including HM Treasury’s Managing Public Money. The Company operates solely in the UK and all employees are classified as public servants.

The Company provides essential Human Resources, Payroll, Finance, Digital and Information (D&I) and Procurement services to its owners, UK Research and Innovation (UKRI) the Department for Science, Innovation and Technology (DSIT), the Department for Energy Security and Net Zero (DESNZ), the Department of Business and Trade (DBT) and some of their partner organisations, all of which are also classified as UK public bodies and, in procurement terms, contracting authorities. As contracting authorities, they are all are subject to UK public procurement rules and UK Government legislation.

Our mission is to provide high quality, easy to use and ever improving business services that delight and add value to our partners, so they can focus on delivering the best outcomes for the British people and the UK economy. We recognise our responsibility to prevent modern slavery and human trafficking in our own business activities and within our supply chains.

Supply Chains and Due Diligence Processes and Practices

Our Supply Chain

We know that our supply chain presents the greatest risk of Slavery and Human Trafficking so our relationship with suppliers is a critical part of our commitment to eliminating modern slavery.

UKSBS contractual spend in the 2024-25 financial year was £26.1 million across 160 suppliers (77.2% of this figure is with our top five highest spend suppliers IBM, Oracle, AMS, Hays & PwC) providing mainly IT hardware, software and associated support, staff, including contingent labour, and professional services. UKSBS suppliers have been appointed primarily through Crown Commercial Services (CCS) frameworks. The geographical profile of these suppliers is predominantly UK / EU based; however, we recognise that some companies (predominantly ICT based) will naturally have global supply chains, beyond our tier 1 supply chain, that are subcontracted to support their business.

The Company’s Procurement Service leads on procurement activities for both UKSBS and clients, through both the use of CCS and other public sector frameworks, and undertaking bespoke procurements where the goods and /or services required cannot be sourced centrally.

Our engagement with suppliers includes the following:

  • An assessment for every new supplier during the onboarding process, including the acceptance by suppliers to comply with any procedural or legislative code of conduct regarding the payment of invoices within 30 days.
  • Compliance with reporting obligations via notices under the Procurement Act 2023 (PA2023).
  • The requirement for all suppliers that are in scope of the Modern Slavery Act to provide a copy of their Modern Slavery Statement.
  • The incorporation of Modern Slavery contractual obligations and adherence with the Act where these are permitted to be applied e.g. CCS vehicles CO based terms and conditions.
  • Utilising a bespoke set of terms and conditions in relation to Modern Slavery where an alternative contractual adaptation is required (e.g., NEC4).
  • Incorporating the previously published PPN 02/23 and new PPN 009 (covering the Government’s transparency in supply chains to address the Modern Slavery Act 2015) into its sourcing documents.
  • UKSBS successfully incorporated and used the revised SQ content that has been issued under PPN 03/24, which relates to PPN 02/23(replacing PPN 03/23) for all open competition above threshold procurements, for both UK SBS and its clients, to which PPN03/24 contains Government mandated Modern Slavery selection criteria
  • UKSBS Procurement service worked as part of a sub Working Group of the CO Procurement Policy Working Group (PPWG) to create the new PSQ that supersedes the above SQ under the PA2023, and has successfully incorporated the newly revised PSQ content into UKSBS Library based documents, for all new bespoke competitions in above threshold procurements, for both UKSBS and its clients under the PA2023
  • Social Value guidance for pre-procurement launch discussions around the inclusion of Social Value criteria, aligned to the procurement outcomes sought and the associated requirements of PPN 06/20 PCR2015 and PPN002 PA2023 needs, which also contains relevant Modern Slavery requirements.
  • UKSBS has in the past and continues to work extensively with the Government Policy team the PPWG to incorporate into the UKSBS procurement Library (for all procurements after April 2022) a Modern Slavery Assessment Tool (RAMS) which is mandated by the Integrated Corporate Services team (ICS) for all DISIT, DESNZ and UKSBS procurements over £1M, with the option available to the project team to incorporate this aspect for all procurements over £10k, in particular for high-risk categories or geographical locations internationally recognised as being high risk. Any monitoring or KPI requirements for bespoke and CCS vehicles will be the subject of pre-procurement launch discussions with the client to place any contractual obligations on any supplier to provide a trafficking report during the performance of the contract term, at a frequency set by the Contracting Authority relative to the risk profile of the procurement.
  • The UKSBS procurement service will be further working with the CO PPWG on a new MSA assessment tool, and will be further providing consultative critique and feedback that DSIT and DESNZ will be considering for incorporation once cross Government departmental agreement is reached, which currently still remains at large.
  • Continued ongoing discussions with regards to Modern Slavery via the pre-procurement meeting template and RAMS will promote and highlight the MSA whilst provide a gateway for clients, to ensure that Modern Slavery is suitably addressed during pre-procurement activities and during the performance of contracts.

Procurement Act 2023

Under the new PA2023 for above threshold procurements, a key new step change in public procurement law is to consult the Governments Procurement Review (PRU) departments debarment list for exclusion grounds under Sch 6 & 7 of the PA2023, which squarely interrelates and complements MSA obligations.

Where the Company, its clients or suppliers develop any concerns relating to modern slavery (or any other procurement compliance matter) prior to or during the procurement evaluation stages or for contracts in performance, these would be referred to the Corporate Commercial team and / or the UKSBS Procurement service for investigation and resolution. Contract termination would be an option if the circumstances warrant such action. Once fully investigated, the matter may, dependent upon timing (Sec 59 PA2023) or circumstances, be referred to the newly formed PRU department for investigation for any above threshold procurement and any below threshold procurements under the MSA.

It is worth noting that the PRU are departmentally charged, under the new PA2023, to place suppliers that breach the MSA, as well as other mandatory or discretionary grounds, on the debarment list, which prevents any debarred supplier from bidding for Government contracts.

Strategic supplier management is in place as an integral part of CCS and UKSBS category management, both corporately and where this forms part of its Procurement service delivery to its clients. Strategic suppliers are defined as such through a combination of the value, complexity, volume, bespoke nature and impact of the contracts. Supplier management includes active performance and risk management, including risks within the supplier’s supply chain.

Internal Operations

UKSBS has a responsibility to ensure that our employees are not being exploited, that they are safe at work and that relevant employment, health and safety and human rights laws are followed. To ensure that there is no Modern Slavery or Human Trafficking within UKSBS, we have taken the following interventions:

  • All employees have a contract of employment that sets out the rights and obligations arising from their employment, including the notice period needed for them to terminate the contract and leave their employment. Employees are free to serve notice at any time.
  • We are committed to paying at least the National Living Wage to all employees
  • UKSBS carries out verification of an employee’s identity and right to work in the UK.
  • We do not withhold any employee’s physical identity documents (e.g. passport) during their employment.
  • UKSBS complies with, or provides enhanced versions of, all legislation in respect of working time and statutory time off, holiday entitlement, time off for personal emergencies and sickness, parental leave and minimum rest break periods.
  • The rights of all employees to join a trade union are respected and we are committed to engaging with trade unions where applicable.
  • A communications and training campaign regarding Modern Slavery has been introduced to make employees aware of their rights and how to spot and report signs of Modern Slavery.
  • All employees have access to several different routes to raise and report concerns, ranging from line management to the Audit Committee Chair and an external whistleblowing hotline. There were no whistleblowing incidents raised in 2024/25.

To date, we have not had any instances of an employee reporting a suspected case of modern slavery within our company.

UKSBS Policies

UKSBS maintains policies applicable to all our employees to support the steps we are taking to prevent modern slavery in our operations and supply chain. We continuously review and improve our policies with input from employee groups, specialists and third parties where appropriate.

Code of Conduct – sets out the standards of behaviour and conduct expected of UKSBS employees, ensuring that legal and ethical principles are followed in all areas of the business and upholding a zero tolerance on illegal or unethical behaviour, which squarely aligns to the new PA2023 obligations.

Whistleblowing – encourages colleagues to speak up if they have concerns about illegal practices within UKSBS, including possible modern slavery in our business or supply chain. All employees have access to an independent whistleblowing phoneline.

Corporate Procurement – applies to all procurement activities in the UK and requires that we adhere to social and ethical standards, and human and labour standards in the procurement of goods and services. Contractual Terms and conditions should in bespoke procurements and where possible to do so (e.g. via an existing vehicle) also require suppliers to uphold human and labour rights and local legislation to prevent modern slavery and human trafficking in their own operations and their supply chains.

Inclusiveness – UKSBS is committed to establishing and maintaining a working environment which is free from discrimination and values all employees as individuals.

With support from an external consultant, UKSBS has been strengthening its Corporate Social Responsibility (CSR) agenda, to identify CSR topics of focus and the importance, influence and scale of impact that UKSBS has over various CSR themes. These are aligned to the UN Sustainable Development Goals, including Goal 8 – Decent work and economic growth.

Modern Slavery Training

UKSBS has developed, in conjunction with UK Research and Innovation (UKRI), a bespoke training package, aimed at Procurement, D&I Supplier Integration and Management, Recruitment and Onboarding teams (approx. 120 employees), all of which are directly involved in supply chain management and / or the procurement process or other high-risk areas. The Risk, Information Security and Compliance, People and Executive teams were also required to undertake the training. As at the date of this statement, 95% of those required to complete the training on a mandatory basis had done so.

In 2022, due to internal demand, the mandatory training package was opened up for all other employees to complete on a voluntary basis should they choose to do so.

An annual awareness campaign for all UKSBS employees is undertaken to help increase understanding of modern slavery, identify key indicators of potential modern slavery using such tools as the MSAT and highlight where to find further information or to report suspected incidents. UKSBS will look to support this campaign in 2025/26 with a ‘learn-over-lunch’ style event with an external speaker or further online training.

Next Steps

In 2025/26, UKSBS will undertake the following activities and report on them within future modern slavery statements:

  • Ensure that all current and revised MSA PPN’s / updated tools and guidance is available to be accessed by the procurement teams and incorporated via the DCRB process into UKSBS’s sourcing library suite of documents.
  • Work closely with colleagues in the CO PPWG with regards to the creation of new Tools and PPNs and ensure that UKSBS’s Library documentation reflects the new PA2023 needs.
  • As part of a wider review of Key Performance Indicators (KPIs) and in conjunction with our clients, the consideration and inclusion of procurement KPIs specific to Modern Slavery reporting measures is still ongoing on a case-by-case basis.
  • We will work to continue to build the knowledge, skills and confidence of employees by encouraging all employees to complete the Modern Slavery Training and hosting a ‘learn-over-lunch’ style event with an external speaker.

This statement was approved by the UKSBS Board on 23 July 2025.

Richard Semple
Chief Executive
Signed on behalf of the UKSBS Board.

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