Modern Slavery statement

UK Shared Business Services Ltd (UKSBS) fully supports the UK Government’s objective to eradicate modern slavery and human trafficking. Modern slavery, as defined in the Modern Slavery Act 2015, includes the offences of slavery, servitude, forced or compulsory labour and human trafficking and constitutes a serious abuse of human rights.

This statement sets out the policies, processes and actions undertaken by UKSBS during the financial year ended 31 March 2026 to assess, manage and mitigate the risks of modern slavery within our operations and supply chains.

This statement is published in accordance with:

  • 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 Regulation 2015 (PCR 2015);
  • PPN 009 – Tackling Modern Slavery in Government Supply Chains under the Procurement Act 2023 (PA 2023) and the Procurement Regulation 2024 (PR 2024);
  • PPN 03/24 supplier selection requirements;
  • Relevant provisions of PA 2023, PR 2024 and associated secondary legislation; and
  • 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.

UKSBS provides Human Resources, Payroll, Finance, Digital and Information, and Procurement services to UK Research and Innovation (UKRI), the Department for Science, Innovation and Technology (DSIT), the Department for Energy Security and Net Zero (DESNZ), the Department for Business and Trade (DBT) and a range of partner organisations. These organisations are UK public bodies and contracting authorities subject to UK procurement legislation.

We recognise our responsibility to identify, assess and address the risk of modern slavery and human trafficking within both our own operations and our supply chains.

Supply Chains and Due Diligence Processes and Practices

Our Supply Chain

We recognise that the greatest risk of modern slavery lies within supply chains rather than our directly employed workforce.

UKSBS contractual spend in the 2025/26 financial year was £23.2 million (excl. VAT) across 172 suppliers (70.4% of this figure is with our top five highest spend suppliers IBM, Oracle, Softcat PLC, Alexander Mann Solutions Ltd and Academia Ltd) providing mainly IT hardware, software and associated support, staff including contingent labour and professional services. UKSBS suppliers have been appointed primarily Government Commercial Agency (GCA) previously known as Crown Commercial Service (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 chair that are subcontracted to support their business.

The UKSBS Procurement Service leads procurement activity for both UKSBS and our clients through the use of GCA and other public sector frameworks and through bespoke procurements where goods or services cannot be sourced through existing frameworks.

Procurement Controls and Supplier Due Diligence

UKSBS continues to operate a risk-based approach to tackling modern slavery through procurement and supplier management activities.

Our controls include:

  • Assessment of all new suppliers through onboarding processes.
  • Requirement for suppliers within scope of the Modern Slavery Act to provide Modern Slavery Statements.
  • Incorporation of modern slavery obligations into standard and bespoke contractual terms and conditions.
  • Use of bespoke contractual provisions where alternative contractual forms are required.
  • Consideration of modern slavery risks during pre-procurement, procurement, contract award and contract management stages.
  • Application of Social Value requirements where relevant.

Procurement Policy Notes and Government Commercial Guidance

During 2025/26, UKSBS continued to embed Government commercial policy requirements relating to modern slavery.

This included:

  • Continued application of PPN 02/23 under PCR 2015;
  • Application of PPN 009 under PA 2023 and PR 2024 regimes;
  • Use of the revised supplier selection requirements contained within PPN 03/24 under PCR 2015;
  • Participation in Cabinet Office Procurement Policy Working Group (PPWG) activities relating to modern slavery guidance, tools and subsequent PPNs as part of sub-working groups; and
  • Maintenance of sourcing library documentation to reflect current Government policy and legislative requirements.

Procurement Specific Questionnaire (PSQ)

Following implementation of PA 2023 and PR 2024, UKSBS Procurement successfully implemented the Procurement Specific Questionnaire (PSQ) into UKSBS’s suite of sourcing documents.

The PSQ incorporates mandatory and discretionary exclusion grounds relating to modern slavery and labour exploitation and is used within applicable procurement processes to support supplier due diligence and assessment activities.

Modern Slavery Risk Assessment Tools

UKSBS continues to work with Government commercial policy teams to embed modern slavery risk assessment tools within procurement processes.

The Procurement Service continues to utilise and support the development of the Risk Assessment for Modern Slavery (RAMS) methodology and related assessment tools.

For DSIT, DESNZ and UKSBS procurements over £1 million, RAMS remains mandated by Integrated Corporate Services arrangements, with project teams also able to apply the methodology to lower value procurements where risks warrant enhanced due diligence. For PA 2023 and PR 2024 regime procurements an assistive risk tiering tool that reflects the previously used RAMS is available.

For UKRI, UKSBS uses under instruction from UKRI their Responsible Procurement Impact Assessment (RPIA) tool as per UKRI’s Responsible Procurement Charter for both PA 2023 and PR 2024, and PCR 2015 regimes. The RPIA tool incorporates consideration of modern slavery.

Procurement Act 2023, Exclusions and Debarment

PA 2023 and PR 2024 introduced significant reforms to public procurement, including the establishment of a debarment regime overseen by the Procurement Review Unit (PRU).

UKSBS has implemented arrangements to:

  • Consider exclusion grounds under Schedules 6 and 7 of the PA 2023;
  • Review relevant information concerning supplier misconduct;
  • Monitor developments regarding the Government Debarment List published by the newly formed Procurement Review Unit (PRU) within the Cabinet Office (CO);
  • Escalate concerns relating to modern slavery through commercial governance processes. No modern slavery concerns have been raised at the time of this report; and
  • Consider contract management interventions, remedial actions or termination where circumstances warrant.

Where concerns relating to modern slavery are identified, matters would be investigated by the appropriate commercial, procurement or contract management teams and may be referred to relevant Government authorities such as the PRU where appropriate.

Internal Operations

UKSBS has a responsibility to ensure that our employees are not being exploited, that they are safe at UKSBS is committed to ensuring that modern slavery does not occur within our workforce.

All employees:

  • Have formal contracts of employment;
  • Are free to leave employment in accordance with contractual notice periods;
  • Receive at least the statutory National Living Wage or equivalent contractual entitlement;
  • Undergo appropriate pre-employment and right-to-work checks;
  • Retain possession of their personal documentation;
  • Have access to formal grievance and whistleblowing arrangements; and
  • Are free to join recognised trade unions

UKSBS operates multiple routes for employees to report concerns, including line management, senior management, the Audit Committee Chair and an independent whistleblowing facility. No whistleblowing incidents relating to modern slavery were raised during the reporting period.

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, incorporated into our People Handbook – 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 PA 2023 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.

Governance and Board Oversight

The UKSBS Board has overall responsibility for oversight of the effectiveness of the organisation’s arrangements to prevent modern slavery and human trafficking.

The Board:

  • Reviews and approves the annual Modern Slavery Statement;
  • Receives assurance through governance, risk management and internal control processes;
  • Considers modern slavery risks within the wider organisational control framework; and
  • Oversees the continuous improvement of UKSBS’s approach to modern slavery risk management.

Operational responsibility is delegated through procurement, commercial, people, risk management and assurance functions.

Modern slavery risks may be identified and escalated through:

  • Procurement and supplier management activities;
  • Risk management processes;
  • Internal audit and compliance activities;
  • Assurance reporting;
  • Whistleblowing arrangements; and
  • Escalation from client or supplier concerns.

UKSBS maintains a zero-tolerance approach to modern slavery and human trafficking.

Modern Slavery Training and Capability Building

UKSBS recognises the importance of maintaining awareness and capability amongst employees who are most likely to encounter modern slavery risks.

The organisation continues to provide targeted Modern Slavery training to colleagues working within:

  • Procurement;
  • Supplier Integration and Management;
  • Recruitment and Onboarding;
  • Risk and Assurance;
  • Information Security and Compliance;
  • People Services; and
  • Executive functions

Training supports colleagues in:

  • Understanding the requirements of the Modern Slavery Act 2015;
  • Recognising indicators of labour exploitation;
  • Applying procurement controls and due diligence requirements;
  • Understanding the use of risk assessment tools including RAMS; and
  • Escalating concerns appropriately.

During 2025/26:

  • 189 employees were identified as requiring Modern Slavery training.
  • 186 employees completed the training.
  • Compliance attained: 98.4%.
  • The UKSBS compliance benchmark of 95% was achieved.

Alongside mandatory training, UKSBS continues to promote wider awareness through communications campaigns and learning activities to help employees identify and report potential concerns.

Next Steps

In 2026/27, UKSBS will undertake the following activities and report on them within future modern slavery statements:

  • Continue to incorporate updated Government commercial guidance, PPNs, tools and assessment methodologies into sourcing documentation.
  • Continue engagement with the Cabinet Office Procurement Policy Working Group regarding the development of future modern slavery guidance and assessment tools.
  • Further strengthen procurement and supplier due diligence arrangements under the PA 2023 regime.
  • Continue to review opportunities to introduce meaningful modern slavery KPIs and reporting measures with clients and suppliers.
  • Continue to increase awareness, knowledge and confidence through employee engagement and training activity.

Approval

This statement has been reviewed and approved by the Board of UK Shared Business Services Ltd in accordance with Section 54 of the Modern Slavery Act 2015.

The Board recognises its responsibility for ensuring that effective arrangements are in place to identify, assess and manage the risk of modern slavery and human trafficking within UKSBS's operations and supply chains. The Board receives assurance through the organisation's governance, risk management and internal control framework and reviews progress against ongoing improvement activities.

The Board considers that the actions outlined in this statement are proportionate to the nature, scale and complexity of UKSBS's operations and supply chains and demonstrate the organisation's continuing commitment to the prevention of modern slavery and human trafficking.

This statement constitutes UKSBS's Modern Slavery Statement for the financial year ended 31 March 2026 and has been approved by the Board for publication.

Approved by the UKSBS Board on 23 July 2026

Richard Semple
Chief Executive Officer and Accounting Officer
UK Shared Business Services Ltd

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