This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps taken by UK Shared Business Services Ltd (UKSBS) during the 2022/23 financial year to prevent modern slavery and human trafficking in its business and supply chains.
UKSBS fully supports the UK Government’s objectives to eradicate modern slavery and human trafficking.
UKSBS Organisational Structure
UKSBS is a private company limited by shares, classed as a public body, subject to all applicable UK legislation and required to comply with all relevant Government policies and guidance for public bodies, including Managing Public Money. The Company operates solely in the UK and all employees are public servants.
The Company provides services – Human Resources, Payroll, Finance, Digital and Information (D&I) and Procurement - to its owners, UK Research and Innovation (UKRI) and the Department for Business, Energy and Industrial Strategy (BEIS), and some of their partner organisations, all of which are also UK public bodies and contracting authorities. As contracting authorities, they are all subject to UK public procurement rules and UK Government implementing legislation, namely the 2015 Public Contracts Regulations (as amended) (PCR), associated government policies and guidance e.g. Procurement Policy Notes (PPN’s).
Our mission is to provide high quality and easy to use business services that add value to our partners, so they can focus on achieving the best outcomes for the British people and the UK economy. We recognise our responsibility to ensure that there is no slavery or human trafficking in our own business and across 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 contracts, on an annual budget of 2022/23 £17.6M, directly with approximately 230 suppliers providing mainly IT hardware, software and associated support, contingent labour, legal and professional services, facilities management, including office rentals, and travel booking 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, some companies (ICT based) will naturally have global supply chains that are subcontracted to support their business.
The Company's Procurement Service leads on procurement activities for both itself and clients through the use of CCS 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.
- 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 across UKSBS' suite of Terms and Conditions for all contracts.
- Utilising a bespoke set of terms and conditions in relation to Modern Slavery where an alternative contractual adaptation is required (e.g., NEC3 for Construction /FM).
- Incorporating the recently published PPN 02/23 (covering the Government's transparency in supply chains to address the Modern Slavery Act 2015) into its sourcing documents.
- UKSBS is currently incorporating the newly revised SQ content that has been issued under PPN 03/22 (replacing PPN 08/16) for all open competition above threshold procurements for both UKSBS and its clients which contains Government mandated Modern Slavery selection criteria.
- Including in its kick-off meeting template and library content, 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, which also contains relevant Modern Slavery requirements.
- UKSBS has worked extensively with the BEIS Policy team to incorporate into the UKSBS procurement library (for all procurements after April 2022) a Modern Slavery Assessment Tool (RAMS) which is mandated for all BEIS 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. This embedded requirement also places 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.
- Introducing a commercial intelligence Modern Slavery (red, amber, green) RAG assessment, to provide an alert system to procurement professionals when working with high-risk suppliers, with action taken as a result of the RAG assessment, when appropriate.
Where the Company, its clients or suppliers develop any concerns relating to modern slavery (or any other matter) for contracts in operation, they are raised with the CCS and/or UKSBS Procurement Service for investigation and resolution. Contract termination is an option if the particular circumstances warrant such action.
Strategic supplier management is in place as an integral part of CCS and UKSBS category management. 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.
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.
- UKSBS carries out verification of an employee's identity and right to work in the UK.
- We do not retain 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 Modern Slavery communications and training campaign 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 Chairman and an external whistleblowing hotline.
UKSBS maintains several 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.
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 phone line.
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. Standard terms and conditions for our suppliers also require suppliers to uphold human and labour rights and (in the UK) to prevent slavery and human trafficking in their own operations and their supply chains.
Diversity and Inclusiveness – UKSBS is committed to establishing and maintaining a working environment which is free from discrimination and values all employees as individuals.
In 2022/23 UKSBS, supported by an external consultant, 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 primarily at Procurement, D&I Supplier Integration and Management, Recruitment and Onboarding teams (circa. 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 and Security Compliance, Corporate HR and Executive teams are also required to undertake the training. As at the date of this statement, 92% 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 was launched in 2022 to help increase understanding of modern slavery, identify key indicators of potential modern slavery and highlight where to find further information or to report suspected incidents. UKSBS will look to support this campaign in 2023 with a 'learn-over-lunch' style event with an external speaker.
Modern Slavery and COVID-19
UKSBS continued to identify and address risks of modern slavery within its operations and supply chain throughout the COVID-19 pandemic via those actions mentioned within this statement. The health and safety of UKSBS employees is of utmost importance to the Company, with local and national government guidelines and policies on social distancing and payment of statutory sick pay implemented where applicable.
The payment of suppliers, employees and grants are priority activities for UKSBS and the Company is continuing to adhere to the government's prompt payment guidelines to help protect the payment of wages within supply chains.
As part of UKSBS' move to a hybrid working model, all internal policies, including grievance procedures, have been reviewed to ensure they are applicable and accessible to UKSBS employees whilst working both from home and the office. Additional signposting to the Employee Assistance Programme has been provided for employees to access independent, confidential advice and the modern slavery awareness campaign that last took place in May 2022 highlighted contact information was required for employees to report suspected incidents.
Recruitment activity, both within UKSBS and on behalf of our clients, continues with sustained, rigorous checks to eliminate the risk of vulnerable workers being exploited by third parties during and since the crisis
In 2023/24, UKSBS will undertake the following activities and report on them within future modern slavery statements:
- As part of a wider review of Key Performance Indicators (KPIs) and in conjunction with our clients, the consideration and inclusion of KPIs specific to Modern Slavery reporting measures, in preparation for the new procurement regulations that are currently going through governmental procedural scrutiny.
- We will work to continue to build 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.
Continued implementation of the kick-off meeting template, RAMS and UKSBS Terms and Conditions will provide a gateway for clients to ensure that Modern Slavery is suitably addressed during pre-procurement activities and during the performance of contracts.
This statement was approved by the UKSBS Board on 25 May 2023.
Signed on behalf of the UKSBS Board.