Modern Slavery and Human Trafficking Statement
The Restoration and Renewal Delivery Authority oppose slavery and human trafficking in all forms and make this statement to set out the steps we have taken to ensure that there is no slavery or human trafficking in our organisation or supply chain in the year to 31 March 2022 and which further steps are to be taken to address the risk of modern slavery.
This statement is our third modern slavery statement.
Our Structure and Supply Chain
The Restoration and Renewal Delivery Authority Limited (the Delivery Authority) is a private company limited by guarantee and incorporated under the Companies Act 2006, based in London, UK.
The Delivery Authority is responsible for the restoration and renewal of the Palace of Westminster and related works on behalf of the Houses of Parliament pursuant to the Parliamentary Buildings (Restoration and Renewal) Act 2019 (“the Act”).
The Delivery Authority reports to Parliament via the Parliamentary Works Sponsor Body (the Sponsor Body), a statutory corporation established under the Act. The Sponsor Body is the Delivery Authority’s sole member and guarantor. Proposed changes to this structure were announced in March 2022 and further updates on the progress of those changes are accessible on the R&R website. At the time of writing the Delivery Authority employs 148 direct employees and has two secondees. Furthermore, the Delivery Authority employs an additional 24 contractors.
The Delivery Authority contracts with third party supply chain to undertake much of the work required for the Programme. The Delivery Authority has direct contracts with 113 suppliers; with 112 suppliers based in the UK and one in Ireland. Three of our suppliers represent 75% of our supply chain expenditure. With these key suppliers we review their sub-contracting arrangements prior to any contract awards. As our programme develops and our supplier base grows, we are committed to having a high level of visibility into our supply chain to establish risk profiles and take appropriate mitigating actions. Our organisation prohibits the use of modern slavery and human trafficking in all its operations and supply chain. It is committed to improving awareness of the practices necessary to combat and eliminate slavery and human trafficking and to assess the risk profile of its business in these areas.
Our Policies, Processes and Contracts
The Delivery Authority recognises that slavery is not only an ethical and human rights issues, but also one of criminality. We recognise that corruption is a key factor and driver of exploitation and that it takes various forms that impact worker welfare such as forced labour, labour exploitation, poor working and living conditions, poor terms of employment, detained passports, salary deduction issues and withheld payment. These all have the deprivation of a person's liberty to exploit them for personal or commercial gain in common. Our organisation is committed to promoting high standards of ethical behaviour on the Programme. Our policies and processes underpin these requirements.
These policies and procedures are regularly reviewed and updated as part of our Quality Management System, and include:
Code of Conduct
Resourcing and Recruitment Policy
Anti- Fraud and Bribery Policy
Equality, Diversity and Inclusion (EDI) Policy
Skills and Apprenticeships Policy
Our employees are required to uphold the Delivery Authority’s Code of Conduct and sign adherence to this as part of our onboarding process. All colleagues are encouraged to submit anonymous feedback and seek support through our reporting guidelines contained in our Whistleblowing Policy.
Our supply chain partners are expected to maintain equally high standards of behaviour. We ensure that they can do this by confirming they have a suitable Slavery and Human Trafficking Statement in place and, with high-risk contracts, reviewing their application of it on a regular basis.
The Delivery Authority requires compliance with our policies and processes relating to Modern Slavery and Human Trafficking from sub-contractors, suppliers, and agency/interim staff. As part of our procurement processes, we have developed subject specific material to be included in our standard procurement templates and provisions addressing requirements relating to modern slavery and human trafficking are included in our standard contract terms.
Having completed a second full year of operation of the Delivery Authority we have revised our implementation plan to build on our policy framework and implement further measures to ensure that we can demonstrate our commitment to eliminating modern slavery and human trafficking.
The key areas of focus for our plan will be our supply chain and how we can further incorporate best practice into our policies and processes. A risk assessment of all existing Delivery Authority contracts was committed to in our last statement and no high-risk suppliers were identified. In the next year we intend to formalise our approach to how we assess the risk of modern slavery in our tendering processes and contracts; and the steps we would take if an instance of modern slavery (either suspected or confirmed) was identified; updating both our Procurement Code and Contract Administration Manual as required.
Legal compliance reporting is an established part of the governance and compliance framework of the Delivery Authority, and this encompasses the requirements of the Modern Slavery Act 2015. As such, progress against the implementation of measures to address modern slavery and human trafficking risks is monitored by the Risk Audit and Assurance Committee, who report to the board of directors of the Delivery Authority.
Training and Measuring Effectiveness
The Delivery Authority engaged Slave-Free Alliance (a social enterprise, wholly owned by anti-slavery charity Hope for Justice) in January 2022 to develop an eLearning module on Modern Slavery which launched in June 2022 with completion being mandatory for all new and existing Delivery Authority staff. The learning outcomes ensure our staff:
understand what we mean when we talk about 'modern slavery';
recognise the indicators and understand how to report any suspicions or instances of forced labour or exploitation anywhere in our supply chain;
are aware of the proactive steps the Delivery Authority is taking to tackle the problem of modern slavery in supply chains.
Bespoke training has also been delivered to the Commercial team which is responsible for all procurement and contract management activity on behalf of the Delivery Authority. This training will be refreshed in 2022 following the formal approval of our policy on the implementation of the Social Value Model in procurements; of which criteria on tackling modern slavery forms a key part.
As a relatively new organisation we are conscious of the need to inform ourselves of best practice in this area. In furtherance of this we maintain close links with the wider Parliamentary community through the UK Parliament Social Sustainability and Modern Slavery Working Group. Our policies and all relevant documentation will be continuously benchmarked against latest best practice as published by the Home Office and relevant Procurement Policy Notes as published by the Cabinet Office.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and was approved by the board of directors of the Delivery Authority on 25 July 2022.
David Goldstone CBE
Chief Executive, Restoration & Renewal Delivery Authority
25 July 2022