For nearly 100 years, Save the Children has worked to ensure all children survive, have access to a quality basic education, and are protected from all forms of violence. Together with the 28 national members, Save the Children International (SCI) works in over 120 countries worldwide to inspire breakthroughs in the way the world treats children and to achieve immediate and lasting change in their lives. SCI provides development and humanitarian programming and campaign, policy and advocacy work to drive change for children, including those living in some of the most difficult and dangerous places in the world.
SCI welcomed the introduction of the UK Modern Slavery Act 2015, and the milestone it represented in ensuring that organisations take steps to act against this grave violation of human rights. Modern slavery and human trafficking practices regularly prey on the most vulnerable in society and children often suffer from this terrible exploitation and abuse.
Focusing on measures to prevent and detect modern slavery, and ensuring that those it works with do the same, is consistent with SCI’s vision, mission and values. Measures to counter modern slavery and human trafficking are embedded into the work we do around the world, particularly in relation to our child protection work. Recent work includes a regional project to support migrant children and young workers in Mali, Côte d’Ivoire and Burkina Faso in which we shared information on safe migration, and preparation of a study on the subject of modern slavery and trafficking in Côte d’Ivoire.
Last year’s annual Modern Slavery statement explained SCI’s structure and supply chains, identifying where the potential risks were, details of SCIs policies and the steps we planned to take to improve its processes and prevent and detect modern slavery within its business and supply chain. As an organisation deeply committed to the values of accountability and transparency, we sought to use this statement as an update on our progress.
Our values and policies
As detailed in last year’s statement, our Modern Slavery and Human Trafficking policy sets out SCI’s zero- tolerance approach to modern slavery and its commitment to ensuring that modern slavery is not taking place in its business and supply chains.
At SCI, our core values include accountability, collaboration and integrity. We are committed to acting ethically and with integrity in our business dealings and relationships. We are dedicated to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in its supply chains. We do this through a framework focusing on awareness, prevention, reporting and responding. We hold our partners, suppliers and sub-contractors accountable to the same high standards to which we hold ourselves.
SCI has a number of other policies in place which help us to combat Modern Slavery, including our Child Safeguarding Policy, Fraud, Bribery and Corruption Policy, Procurement Policy, Code of Conduct for Inter-Agency Procurement Group Agencies and Suppliers and in our comprehensive resources aimed at ensuring compliance with US Government and USAID Anti-Human Trafficking Provisions.
We have been taking the following steps to help improve our existing structures and systems and raise awareness, prevent, detect and respond to risks of modern slavery:
Due diligence processes
Enhanced due diligence: As part of our improvements we are developing tools to identify high risk environments and implementing enhanced due diligence measures. The inclusion of modern slavery risks in these tools is in development. This supplements our existing processes, which require that all potential new suppliers be vetted locally and globally and that local teams, who understand the local context, consider risks associated with a potential supplier and make risk based decisions for each sourcing activity.
Template supplier contracts: We have embedded our Modern Slavery and Human Trafficking Policy as a mandatory policy into our spectrum of template supplier contracts and tender invitations. Each of these agreements are available for global use for the procurement of goods/services for the organisation. Strict provisions have also been embedded in, and are fundamental to, our construction contract template, as we recognise the higher risk of modern slavery in this industry.
Template partner agreements: As part of a current review, we are working on embedding our Modern Slavery Policy into template partner agreements. We have already been doing this in on a case-by-case basis, but the review will harmonise our approach.
Procurement manual: We have integrated our Modern Slavery and Human Trafficking Policy as a mandatory policy, with which suppliers are contractually obliged to comply.
Identifying, assessing and managing risks of modern slavery
Risk assessments: Keeping the children and people we work with is one of Save the Children’s top priorities. Our safeguarding risk assessments consider the risks of modern slavery and trafficking insofar as they affect children. SCI has various risk assessment tools, which assist our staff to identify risks and effective mitigations, including tackling the risk of modern slavery amongst potential suppliers and partners. We are committed to strengthening these tools. We are currently working on a comprehensive Child Safeguarding risk management tool which will further improve these processes, that will be completed by the end of 2018. As part of our review of partnership agreements, we are working on incorporating risks of modern slavery into a revised partner assessment tool, and will work towards effectively integrating consideration of this risk into our processes in practice. Our current Child Safeguarding and Human Trafficking tool raises questions to help identify particular issues, particularly relating to risks of human trafficking amongst children.
Supplier visits: We carry out inspections of suppliers as needed, and particularly for high risk programmes such as nutrition and pharma. We have reporting mechanisms in place for reporting modern slavery concerns, detailed within our Modern Slavery Policy. Where an issue is reported in relation to a supplier and an investigation is commenced, the investigation team determines whether a visit to the supplier’s premises is necessary.
Supplier warnings: In our supply chain, we are introducing additional mechanisms to identify suppliers who have violated our ethical standards in the past (including where they have been involved in perpetrating modern slavery) and to ensure that they are not used by our organisation. This is in addition to existing internal reporting mechanisms we have in place to escalate issues which have been identified.
Reporting: SCI’s Modern Slavery Policy encourages suspicions and concerns to be reported through its procedures. Concerns involving children may also be reported through our child safeguarding reporting mechanism. Reports are monitored by our dedicated Child Safeguarding team and appropriate action is taken against perpetrators. The corrective action will be determined according to the details of the case, and may include suspension or termination of our arrangement with a partner/supplier, referrals to police, working with the local community, and disciplinary action taken against involvement of any SCI staff member. SCI has recently introduced new software to make reporting more accessible to staff and improve monitoring of cases from start to finish. This software currently enables modern slavery concerns to be reported through limited categories of child safeguarding or fraud. Modern slavery/human trafficking will be introduced as an independent reporting category within the software in due course. This process will enable SCI to categorise modern slavery and human trafficking concerns to be able to effectively and efficiently monitor and draw data under this specific category of abuse. An update to our global Whistleblowing policy is also underway, which should facilitate increased reporting across the organisation. Longer term, we will consider ways to facilitate suppliers and partners being able to utilise our whistleblowing mechanisms in order to raise concerns with us about practices within their own companies or that of their related third parties.
Awareness and training
Staff: Since last year’s statement, we have integrated Modern Slavery training into two of our mandatory new starter training courses:
(a) Mandatory global online human resources induction for new starters. This is accessible by our staff across the world and explains what modern slavery is, how staff might spot it, SCI’s policy and how to report any suspected incidents. Since September 2017, 91% of new starters in our headquarters, and 79% outside our headquarters have completed or are currently enrolled in this training (and are within the deadline for completing it). We anticipate that these figures will rise as new ‘in person’ human resources inductions are rolled out across the organisation. These inductions will clarify and reinforce that both completion of the global induction and adherence to the Modern Slavery Policy are mandatory.
(b) Mandatory Child Safeguarding Training. Preventing the exploitation and abuse of children is central to our organisation’s aims and our mandatory ‘in person’ Child Safeguarding training previously indirectly addressed the issue of modern slavery and trafficking of children. We have recently refreshed our in-person interactive training, which now includes enhanced information about modern slavery, including its prevalence, how it may be detected and reported. This revised training is delivered at our headquarters. This has also been shared globally with our child-safeguarding leads across the organisation, who adapt the training according to the specific requirements and needs in the regions and countries they oversee. Modern slavery information is also being incorporated into other safeguarding trainings for teams across the organisation (such as our supply chain, safety and security specialist and humanitarian teams), and in additional humanitarian training.
Suppliers: With over 100,000 suppliers globally, it is not feasible to have a centralised training programme for all our suppliers across our supply chain. Our country and regional offices identify risks arising through their supplier due diligence work that they engage in, and provide support and clarification where needed on modern slavery to suppliers. We also discuss our contractual requirements with regard to modern slavery with suppliers on a case-by-case basis.
Partners: Our International Safeguarding team is in the process of including information on Modern Slavery into mandatory partner safeguarding training.
SCI recognises that there is more to be done. In addition to the actions being taken as detailed above, SCI is committed to the continuing evaluation of our systems and processes to ensure that we can better raise awareness of, prevent, report and respond to issues of modern slavery across the organisation.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes SCI’s slavery and human trafficking statement for the financial year ending 31 December 2017. It was approved by the Board of Save the Children International in October 2018, and subsequently published on SCI’s website on 7 November 2018.
Interim Chair of the Board
Save the Children International