- As Trustees will know from previous reports, we are required to publish a statement of compliance with the Modern Slavery Act 2015, within 6 months of the end of our financial year.
- The legal requirement in section 54 of the Modern Slavery Act 2015, is that all companies with a turnover of over £36m publish a slavery and human trafficking statement each year. This must describe the main actions the organisation has taken to deal with modern slavery risks in supply chains and its own business. The statement should be published on the website and include a link in a prominent place on the homepage.
- This statement is a slightly updated version of the 2019 one. We do think that the risk of modern slavery affecting our supply lines is low, and that the area of greatest risk is likely to be in Trading. There was also a particular potential risk this year, in terms of the procurement of PPE and this is highlighted in the statement.
- The Committee is asked to agree that the Statement in Appendix 1 be recommended to Council for agreement. We will then need to ensure that it is put onto our website by the end of September.
That Council approve the Modern Slavery Act Statement for the Financial Year ending on the 31st March 2020.
Modern Slavery Act Statement for the year ending 31st March 2020.
This is the modern slavery and human trafficking statement for Sense, the National Deafblind and Rubella Association, for the financial year ending 31st March 2020. It is the fifth 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, to enable people to live more active lives and to be less lonely. We also support families and campaign to 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 of 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 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 think that it is unlikely to affect general procurement for the organisation.
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.
Our Trading Team secures statements from all suppliers of new goods guaranteeing their compliance with the Act. They cannot be engaged without this compliance statement. Two years ago the compliance of all longstanding suppliers was reassessed. They were all found to be compliant.
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.
Because of the Corona Virus Pandemic, we have had to procure a great deal of Personal Protective Equipment (PPE). We were aware that this could have been a risk in terms of modern slavery in the supply lines. However, our Operations Directorate used our regular suppliers, or where they not able to supply the equipment, we used local authority or NHS suppliers lists. Our Trading Team also uses PPE for staff and volunteers in our shops, and this was all procured from existing suppliers, who are fully compliant.
Effectiveness and Assurance
Sense would not tolerate slavery and human trafficking in our supply chains and would 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 2020, 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.
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, anti-bribery, equality & diversity and disciplinary and procurement procedures should ensure that modern slavery in any form will not directly impinge on our organisation.
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.
This statement has been approved by the Council of Sense, the National Deafblind and Rubella Association for the year ending March 31 2020.
Andrew Pearson, Treasurer
22 September 2020