DD2552 Modern Slavery Statement

The Modern Slavery Act 2015

1.1. The Modern Slavery Act 2015 was designed to eliminate slavery, servitude, forced or compulsory labour, and human trafficking (‘modern slavery’) in organisations and their supply chains by:

i. increasing transparency as to what steps, if any, any organisation is taking to combat slavery and trafficking

ii. consolidating criminal offences for slavery and trafficking

iii. remedying victims

iv. providing for greater identification and reporting of slavery and trafficking

v. creating new civil sanctions

vi. creating an Independent Anti-slavery Commissioner.

1.2. One of the main provisions of the Act, relating to (i) above, is section 54, which requires every organisation carrying on a business in the UK with a total annual turnover of £36m or more to produce a modern slavery statement. The statement must cover the prior financial year – and so be refreshed annually – and government guidance is that it should be published as soon as possible and no later than six months after the end of that financial year. It should describe what action the organisation has taken to ensure their supply chains are free from modern slavery and must be published on the organisation’s website with a link from its homepage.

The GLA’s modern slavery statement

1.3. It is proposed to adopt the same approach this year as in previous years: that the GLA adopts one statement covering the Authority (though not commercial in of itself) and two of its companies: GLA Holdings and GLA Land and Property Limited (GLAP), which are commercial for the purposes of the Act. This reflects the priority the GLA places on tackling modern slavery, and the interconnectedness of the objectives and functions of the three entities. The GLA has assessed whether a statement is required for its other subsidiaries and concluded that this is not the case. Since London Treasury Limited and SME Wholesale Finance Limited do not procure goods, certainly not at scale or where there are risks of modern slavery, there would not be value in expanding the remit of the GLA’s statement to incorporate these two subsidiaries. The turnover for London Power Co in 2020-21 did not meet the threshold required for issuance of a modern slavery statement.

1.4. The GLA’s statement continues to be closely aligned with that adopted by Transport for London (TfL) and its subsidiaries. The logic for this is that the GLA’s procurement function is provided by TfL – and the main focus of the statement is tackling modern slavery in supply chains. In addition, the GLA Group shares a Procurement Policy, a refreshed version of which was published by the Mayor in March 2021. The Policy prioritises five objectives, one of which is ‘embedding fair and inclusive employment practices’ (including tackling modern slavery).

1.5. The content of the statement is not prescribed in legislation and the government’s guidance does not detail a recommended approach. The GLA has chosen to structure its statement in a similar way to previous years so it describes:

• the purpose of the GLA, its companies and the nature of their supply chains
• the extant policies and procedures to reduce the risk of modern slavery in supply chains
• spend categories that present risks of human rights abuses
• due diligence arrangements
• training and awareness-raising
• goals for 2021-22.

1.6. The proposed format and content of the 2020-21 statement is broadly in line with previous statements. The TfL statement it draws on was approved in draft by its Board on 28 July 2021.

GLA Holdings and GLAP approval

1.7. The Boards of GLAP and GLA Holdings were advised that a statement was in preparation at their respective meetings on 6 July 2021 and authorised the Executive Director of Resources to agree the final form of the statement.

1.8. The Executive Director of Resources is also required to agree the statement for the GLA and this agreement can be given through the General Delegation set out in Mayoral Decision-Making in the GLA.

2.1. Publishing a modern slavery statement will:

• meet legal requirements falling on the GLA and two of its companies
• demonstrate the GLA’s commitment to tackling modern slavery
• serve to reinforce the GLA’s approach to tackling modern slavery.

2.2. The Act requires the statement to be published on each company’s homepage with a link from a prominent place on the homepage. Neither of the GLA’s companies has a website of its own. The statement will therefore, as previously, be published within the ‘Governance and Spending’ section of the GLA’s own website (london.gov.uk).

3.1 The driving purpose of the statement is to demonstrate our commitment and reinforce our approach to tackling modern slavery. Groups that are protected by the Public Sector Equality Duty are disproportionately likely to be subject to modern slavery, and so the statement explicitly promotes equality and fosters good relations between those groups.

Key risks and issues

4.1 There are no significant risks that will flow from taking this decision. Indeed, adopting the statement will remove the risk of the GLA not being compliant with section 54 of the Act and reduce the – already low – risk of modern slavery within its and its companies’ supply chains.

4.2 In any contracts that TfL procurement identifies as having a high ethical sourcing risk, suppliers are required to conduct audits of their factories and sites using an independent, third-party auditor.

Links to Mayoral strategies and priorities

4.3 The Mayor places a high priority on making London a fairer and more equal city, including: challenging equality and intolerance; opening up opportunity; making London accessible for all; sharing the rewards of prosperity; and leading by example. Adopting a modern slavery statement strongly supports all these objectives.

4.4 Adoption of the statement is one of the responsible procurement initiatives that makes a contribution towards the Mayor’s Good Work Standard.

4.5 There are no conflicts of interest to declare from any of those involved in the drafting or clearance of this Decision Form.

5.1 There are no direct financial implications in respect of this decision.

6.1. As the requirements of the Modern Slavery Act 2015 relate to GLA’s workforce and its supply chain, it is appropriate for approval of the statement to be given by the Executive Director of Resources, given his areas of managerial responsibility.

6.2. It should also be noted that, in addition to publication of the statement referred to above, local authorities, including the GLA, are required by section 52 of the Act to notify the Secretary of State upon developing reasonable grounds to believe that a person may be a victim of slavery or human trafficking. Vigilance in this regard is therefore required.

Appendix 1: Modern Slavery Statement 2020-21