Modern Slavery statement

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 2023/24 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) the Department for Science, Innovation and Technology (DSIT), the Department for Energy Security and Net Zero (DESNZ), the Department of Business and Trade (DBT) and some of their partner organisations, all of which are also UK public bodies and contracting authorities. As contracting authorities, they are all are subject to UK public procurement rules and UK Government 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 contractual spend in the 2023-24 financial year was just under £27.5 million across 172 suppliers (70% of this figure is with the top five suppliers IBM, Oracle, AMS, Hays & PwC) providing mainly IT hardware, software and associated support, staff including contingent labour and professional 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 both 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, including low value procurements.
  • The incorporation of Modern Slavery contractual obligations and adherence with the Act across UKSBS’s 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., NEC4 for Construction/FM).
  • Incorporating the recently published PPN 02/24 (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 03/24, which relates to PPN 02/23 (replacing PPN 03/22) for all open competition above threshold procurements for both UK SBS and its clients to which PPN03/24 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 Government Policy teams to incorporate into the UKSBS procurement Library (for all procurements after April 2022) a Modern Slavery Assessment Tool (RAMS) which is mandated by the Integrated Corporate Services team (ICS) for all DISIT, DESNZ 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.
  • Working with the Cabinet Office Procurement Policy Working Group on a new MSA assessment tool that DSIT and DESNZ will be considering for incorporation once cross Government departmental agreement is reached.
  • Continued discussions with regards to Modern Slavery via 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.

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.

Internal Operations

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 withhold 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 communications and training campaign regarding Modern Slavery 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. There were no whistleblowing incidents raised in 2023/24.

UKSBS Policies

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 phoneline.

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.

With support from an external consultant, UKSBS 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 (approx. 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, People and Executive teams are also required to undertake the training. As at the date of this statement, 95% 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 is undertaken 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 2024 with a ‘learn-over-lunch’ style event with an external speaker.

Next Steps

In 2024/25, UKSBS will undertake the following activities and report on them within future modern slavery statements:

Incorporate the requirements of the latest PPN 03/24 via the DCRB process into its sourcing library suite of documents.

  • Work closely with colleagues in the Cabinet Office with regards to the new Regulations and Government digital platforms that will supersede the current PPN in force and ensure that UKSBS’ documentation reflects the new regime.
  • 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.
  • 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.
  • Upload the UKSBS Modern Slavery Statement to the government’s modern slavery statement registry.

This statement was approved by the UKSBS Board on 18 July 2024.

Richard Semple
Chief Executive
Signed on behalf of the UKSBS Board.​​​​​​

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