Modern Slavery Act Statement for the year ending 31st March 2021
This is the modern slavery and human trafficking statement for Sense, the National Deafblind and Rubella Association, for the financial year ending 31 March 2021. It is the sixth statement Sense has made in compliance with section 54(1) of the Modern Slavery Act 2015.
Our business and our structure
Sense is a national disability charity that supports people who are deafblind or living with complex disabilities that can make it a challenge to communicate, access information and take part in life.
We support children and adults to communicate, be understood, valued and to experience the world, through our centres, residential provision – including working in people’s homes, providing holidays and short breaks, volunteer buddies and creative and physical activities. We enable people to live more active lives and to be less lonely. We also support families of children and adults with complex disabilities, and campaign to positively change relevant laws and government policies.
Our supply chains and due diligence processes
Sense is committed to ensuring that the organisation and its supply chains are free from slavery and human trafficking, and that the necessary due diligence is undertaken to provide assurance of this. The Group Director of Finance & Resources, Catherine Still, has overall responsibility for this area of compliance.
Our risk analysis for modern slavery and human trafficking affecting our organisation has concluded that this remains a low risk. The areas most likely to be affected by modern slavery are new goods purchased for our trading arm (i.e. charity shops which raise funds for Sense).
We set out below the due diligence processes Sense has put in place to prevent the organisation from being involved with modern slavery in any way.
We seek to establish long-term relationships with suppliers who understand Sense and our values. Our Trading Team secures statements from all suppliers of new goods, guaranteeing their compliance with the Act through our Code of Conduct and they cannot be engaged without it. This is renewed annually to ensure continued compliance. Our Trading Department only purchase from UK based suppliers who are listed on the Charity Retail Association list of approved suppliers.
Sense’s procurement practices incorporate processes to ensure that our major suppliers of goods comply with the requirements of the Modern Slavery Act 2015.
Invitations to tender require suppliers to confirm their compliance with the Act and to provide a formal statement to this effect. If it is considered necessary, they will be asked to provide further assurances.
Depending on the type of goods being provided and the origin of the supply chains involved, further due diligence may be undertaken if necessary.
Effectiveness and Assurance
Sense would not tolerate slavery and human trafficking in our supply chains and will terminate our relationship with any suppliers where there was evidence of their failure to comply with the Modern Slavery Act 2015.
Sense is satisfied that, over the year to April 2021, there has been no evidence of any connection with modern slavery or human trafficking, either within the organisation or through any of our suppliers or sub-contractors.
Although it is important to undertake due diligence with our suppliers, we do not consider that it is necessary to set any performance indicators for this area. We have not so far needed to take any action against a supplier. We will however continue to keep this under review.
Our policies in relation to modern slavery and human trafficking
We are a values–led organisation and we have a number of policies which relate to modern slavery and human trafficking. Our policies on recruitment, whistle-blowing, antibribery, equality & diversity and disciplinary and procurement procedures should ensure that modern slavery or human trafficking in any form, will not directly impinge on our organisation.
However, we will be ensuring that it is specifically referenced in relevant HR policies before the end of this financial year. Our Safeguarding policy already refers to the fact that people with learning disabilities are also at risk of being coerced into modern slavery.
Training our staff about slavery and human trafficking
Staff who work in the areas likely to be affected by modern slavery (in particular Trading) are trained in our procedures for ensuring that the organisation and its supply chains remain free of slavery and human trafficking.
We have now also incorporated awareness of modern slavery and human trafficking into our online safeguarding awareness training course for all staff, with an additional module for staff who work in our Operations Dept, which looks at the issues in more detail.
This statement has been approved by the Council of Sense, the National Deafblind and Rubella Association for the year ending 31 March 2021.
Andrew Pearson, Treasurer
22 September 2021