Save the Children International (“SCI”) and the Save the Children movement welcomed the introduction of the UK Modern Slavery Act 2015 as it is consistent with Save the Children’s values and missions. Since the introduction of the Act, SCI continues to implement initiatives to address modern slavery risk across our business, in our supply chain and with partners. We also continue to work with communities to drive change.
These initiatives are especially relevant given that the social and economic impacts of the COVID-19 pandemic continued in 2021. In particular, the ongoing disruption to education as a result of long periods of school closure, and increased pressure on family finances, are likely to have increased the risk of families resorting to negative coping strategies. This, together with heightened conflict and forced displacement in countries including Afghanistan, Syria, Ethiopia and elsewhere, exposed children to increased risks of child labour, exploitation and child trafficking.
In 2019, the United Nations (“UN”) declared that 2021 would be the International Year for the Elimination of Child Labour. As part of its engagements under this initiative, SCI pledged to intensify its efforts to contribute to the UN’s Sustainable Development Goals (“SDG”), including SDG 8.7 which commits to ending child labour in all its forms by 2025. To achieve SDG 8.7, SCI integrated the prevention of child labour into several of its core work streams. Namely through: (i) ensuring where possible that children were safely returned back to school and learning; (ii) promoting links between child labour prevention and social protection; and (iii) strengthening systems within supply chain to identify potential incidents of child labour and, where the risks of such incidents are identified, implementing procedures to mitigate the risk and address incidents. A summary of efforts can be found here.
Examples of our work with communities includes a number of projects aimed at preventing and responding to child labour (including bonded labour) and trafficking across the globe, with notable examples in Sri Lanka, Mozambique, Central America and West Africa:
- The establishment of “catch up clubs” to ensure children are not excluded from education, in light of the economic crisis caused by COVID-19;
- The establishment of an integrated community level case management model (“CONNECT”), to provide children with access to integrated services after the disruption caused by COVID-19. CONNECT seeks to mitigate the long-lasting impacts of COVID-19, after the prolonged closures of schools, which has heightened the risk of children being forced into labour;
- Training of law enforcement officers and social welfare workers to identify, interview and provide appropriate care to child victims of trafficking;
- Supporting the rehabilitation of child victims through information, mental health and psychosocial support, and reintegration into education, training and employment; and
- Working with governments to strengthen their systems, legal frameworks and policies to prevent and respond to trafficking, including advocacy to ensure appropriate care and de-institutionalisation of child victims.
Save the Children also works on child protection issues within supply chains, including prevention of child labour across the world, including in Vietnam, Cote D’Ivoire, Uganda, Sri-Lanka and the DRC.
A: OUR STRUCTURE AND SUPPLY CHAIN
As a global movement Save the Children is made up of 27 Members (national organisations) and 3 Associate Members. Members and Associate Members are part of the movement’s central body, Save the Children Association (SCA). Members lead on activities within their home territory and work with donors to develop programs abroad, which are delivered by the movement’s implementing body, Save the Children International (SCI), via in-country teams working on the ground.
SCI is a UK registered charity and company limited by guarantee, headquartered in London and functioning through SCI’s network of 5 regional offices and 56 country offices, 2 humanitarian response offices and 15 partner-led programs, operating in 76 geographical territories. 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.
Together with the 27 National Members and 3 Associate Members, SCI worked in 118 countries in 2021 to inspire breakthroughs in the way the world treats children and to achieve immediate and lasting change in their lives. All the members of Save the Children, with combined revenues of $2.46 billion, are working to deliver a shared strategy – Ambition for Children 2030.
This statement is SCI’s Modern Slavery Statement. It builds on SCI’s previous Modern Slavery Statements, available on our website here, detailing the steps we have taken to help prevent and eliminate risks of modern slavery in our business and supply chains.
(i) SCI’s business
SCI employs approximately 16,500 people across its offices globally, in addition to volunteers and contractors. We have human resources (“HR”) functions in the country and regional offices where we work, and primarily hire our workforce directly and locally, through the relevant local HR functions, although in some instances we use agencies to assist with our recruitment. Further information about how our recruitment procedures help prevent risks of modern slavery are detailed in sections B(i) and C(i) below.
(ii) SCI's supply chain
SCI has a very complex, dispersed supply chain. SCI is not, however, involved in manufacturing, agriculture or retail industries, which are typically high risk activities for modern slavery.
The scale of SCI’s supply chain operations is underlined by our Supply Chain Key Statistics:
- $350m - third party supplier spend;
- approximately 2,000 - supply chain headcount of which roughly 500 staff are responsible for procurement;
- 267 warehouses;
- 2701 vehicles in SCI’s fleet (including rented vehicles).
At least 80% of SCI’s procurement is sourced in-country by SCI’s 56 country offices. SCI recognises the risk of modern slavery in these countries and takes this very seriously. SCI has developed and commenced the roll out of an online global procurement platform, to automate many of the procedures involved in the procurement and accounts payable process, from the initial stages of sourcing a supplier, to the final payment being made. Part of this process involves the roll-out of a technology solution called “ProSave”, used end-to-end in the procurement process, from identifying suppliers through to making supplier payments. ProSave has now been rolled out to approximately two thirds of all country offices. The platform aims to simplify procurement procedures enabling greater visibility over SCI’s supply chain and enabling increased compliance.
(iii) SCI’s partnerships
SCI delivers approximately 18-19% of its portfolio through partners. These are often local and international not-for-profit organisations based in the countries in which SCI operates and delivers its programming. SCI has a Head of Partnerships at SCI’s headquarters in London, and regional and country office partnership advisors and focal points across our movement. We continue to work with partners to ensure that modern slavery is not present in their operations and programming and expect partners to sign up to our Modern Slavery commitments in our agreements.
B: OUR VALUES AND POLICIES
(i) Mandatory staff policies
The responsibility to uphold SCI as a safe organisation for children and adults is a shared responsibility of all of its employees.
As detailed in SCI’s previous modern slavery statements, our Modern Slavery and Human Trafficking policy adopts SCI’s zero tolerance of modern slavery and its commitment to ensuring that modern slavery is not taking place in its operations and supply chains. This approach is supported through the Safeguarding policy framework, which focuses on Awareness, Prevention, Reporting and Response
The Safeguarding Policy Framework reinforces SCI’s duty to prevent and manage the risk of modern slavery and all other forms of exploitation, abuse or harm being committed by our staff or representatives against program participants as well as children and adults in the communities in which SCI works. The policies included within this framework outline the principles and expected behavior and conduct so that every representative within SCI can better understand how to prevent harm, identify and detect exploitation and abuse, and ensure proper mitigation measures and protections are in place. These policies include: Modern Slavery and Human Trafficking; Code of Conduct; Child Safeguarding; Protection from Sexual Exploitation, Abuse and Harassment; and Anti-Harassment, Intimidation and Bullying. All staff must sign these policies when they start at SCI.
SCI’s Recruitment Policy and Procedure, Reward Policies and Relocation Policies embed the principles through which SCI recruits and help ensure that modern slavery is not present within SCI’s own business.
SCI has a whistleblowing policy and procedure in place and has a Global Whistleblowing Officer, who oversees the whistleblowing process. Several channels are available for staff members who wish to make a whistleblowing complaint, including an internal incident reporting system (see section C(ii) below), a designated whistleblowing email address, and an external hotline for those staff members and partners who do not feel comfortable using our internal reporting channels. During 2021, SCI updated its whistleblowing policy and procedure, with a view to the updates being rolled out in 2022.
SCI has a global on-boarding process for SCI’s contractors which ensures that such workers sign SCI’s mandatory policies, including the Modern Slavery and Human Trafficking policy, and complete SCI’s mandatory training prior to starting work with SCI.
(ii) Supply Chain and Partners
Our Modern Slavery and Human Trafficking Policy is embedded as a mandatory policy in our template partner agreements and our spectrum of key global template supplier contracts and tender invitations. Strict provisions have also been embedded in our construction contract template, as we recognise the higher risk of modern slavery in this industry. Other policies to which our suppliers are subject, such as our Child Safeguarding Policy, our Protection from Sexual Exploitation, Abuse and Harassment Policy, our Anti-Harassment, Intimidation and Bullying Policy and the Inter-Agency Procurement Group Agencies and Suppliers Code of Conduct, set out SCI’s expectations of suppliers and help reduce the risk of instances of modern slavery. SCI also has comprehensive resources aimed at ensuring compliance with US Government and USAID Anti-Human Trafficking Provisions.
In 2021, SCI continued to roll out improvements to its procurement manual, to provide more information to our local teams about modern slavery, including how to identify, report and ultimately prevent such risks within the supply chain. We have also continued to roll out SCI’s Procurement Policy alongside the enhanced manual. In January 2020, SCI deployed an updated version of Procurement Essentials, a functional training course, which included enhanced sections on all SCI’s compliance standards, including Modern Slavery. This is a mandatory training course for all procurement staff, equipping staff with a compliance checklist to use when assessing suppliers, linking to SCI’s overall policy on Modern Slavery.
C: OUR ACTIONS
(i) Due diligence processes
Staff awareness: Staff awareness about modern slavery is key to ensuring that suspicious behaviours and indicators of modern slavery are flagged early on and appropriately managed. Details of training currently available to staff are set out in section C(iii) below.
Recruitment practices: Our recruitment practices help prevent the risk of modern slavery within our business. Our recruitment agreements and policies are managed locally, based on global templates and principles but adapted for the relevant local context and applicable law.
We have a framework agreement which is used when we engage with recruitment agencies in the UK (with a view to global use in the future), in which SCI’s Modern Slavery and Human Trafficking Policy is embedded as a mandatory policy.
Some of the other measures which SCI has in place for employees include:
- Conducting vetting checks on prospective recruits before an offer of employment is made, and a disclosure and barring service and references check prior to start date (two-stage process);
- Conducting regular salary reviews to ensure that staff get paid a living wage in the countries where SCI operates, and benchmarking salaries to ensure that they remain competitive in the sector;
- Checking, but not withholding, identity documents and rights to work documentation;
- Providing information on workers’ rights in a language our staff can understand; and
- Not allowing for fines levied to be passed onto employees or for workers to be charged finders’ fees (for example, in the context of agency recruitment), and not deducting accommodation or transport costs from staff salaries.
SCI’s Supply Chain
In 2021, SCI continued the staged introduction of a global IT platform to manage supply contracts. Upload to the platform, which is now mandatory for all active suppliers in the countries where this has been rolled out, requires the supplier to confirm that it complies with SCI’s mandatory policies (including the policy on Modern Slavery and Human Trafficking). This platform gives SCI a more robust, and systematic, way of ensuring that requirements in SCI’s mandatory policies flow down to our suppliers. The deployment will be completed in 2022.
We ensure partner due diligence through conducting both mandatory partner vetting, and embedding questions concerning modern slavery and human trafficking in our mandatory Partnership Assessment Tool, to assess qualification of partners to deliver programs together with us. This helps us to consider and highlight potential issues around modern slavery in partners with which we are considering working. We ensure partners sign up to and commit to our policy on Modern Slavery and Human Trafficking in our partnership agreements.
(ii) Identifying, assessing and managing risks in modern slavery
Risk assessments: During 2021 SCI strengthened its risk management processes, including rolling out a new risk management policy and procedure. All SCI’s country offices have risk committees which meet regularly to identify, assess and mitigate the key risks they face. Safeguarding children and adults is a principal risk area, on which all country offices must report every quarter.
The consideration of risk management in project design has also been strengthened through the roll out of a new award risk management tool, which helps staff to identify risks at the proposal and design stage of an award, so that appropriate mitigations can be built into the program design. A key component of this tool is the safeguarding risk assessment, which was revised last year to include a new “risk directory”. This risk directory sets out potential risk scenarios and possible mitigations throughout all elements of program design and implementation. For supply chain, the risk directory requires specific consideration of the prevalence of modern slavery and human trafficking both in-country and in neighbouring countries.
Safeguarding Management: Our 2021 safeguarding priorities to strengthen safeguarding management and accountability at all levels and across all functions and departments within Save the Children will continue throughout 2022.
Supplier visits: Our local teams determine whether to conduct inspections of suppliers, and tend to focus on programs such as nutrition and pharma where product quality is critical. In our procedures, we apply a risk-based approach (with focus on modern slavery and human trafficking) to determine whether a visit is necessary. We have reporting mechanisms in place for reporting modern slavery concerns, detailed within our Modern Slavery and Human Trafficking 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, our databases record the vetting status of suppliers. Our vetting systems draw from a broad range of criminal records that are public as well as adverse media reports, which, if public, would identify perpetrators. If the supplier does not pass our vetting process we will not work with the supplier.
Reporting: Under SCI’s Modern Slavery and Human Trafficking Policy all suspicions and concerns of policy and contractual violations must be reported through official reporting channels. Any suspicions or concerns involving children and adult program participants of affected populations and/or relating to sexual exploitation and abuse, as defined in SCI’s Protection from Sexual Exploitation, Abuse and Harassment Policy, must be reported immediately. These policies require that reports are made either through SCI’s incident reporting platform, Datix, or through the whistleblowing channels referenced above. Following notification and investigation of a report, 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 and relevant regulators at the international, national and local level, and disciplinary action taken against any SCI staff member involved.
(iii) Awareness and training
In addition to our Modern Slavery and Human Trafficking Policy, SCI has a number of policies in place which are mandatory for staff to sign, and which help us to combat modern slavery. These include our Code of Conduct, Child Safeguarding Policy, Protection from Sexual Exploitation, Abuse and Harassment Policy and Anti-Harassment and Bullying Policy.
Regarding training, at present, SCI covers modern slavery risk as a component of its safeguarding training and as part of its human resources online induction for new starters. Statistics for completion of this training are below. Procurement training courses also cover modern slavery risk (see below). SCI is also in the process of developing an e-learning module focusing specifically on Modern Slavery Awareness. The rollout for this module had initially been planned for the latter half of 2020 but, due to the impact of the Covid-19 pandemic and its impact on SCI’s operations in countries around the world, the rollout is now expected to take place in 2022.
The below figures provide information in relation to training conducted in 2021:
- Mandatory safeguarding training (incorporating a section on modern slavery training) is now accessible by our staff across the world either in person or through webinars (with in person training largely suspended due to the Covid-19 pandemic). During 2021, 96% of SCI new starters completed this training during their induction period. This is an increase of 1% on the previous year.
- Mandatory global human resources online induction for new starters (incorporating elements of modern slavery) 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. During 2021, 88% of new starters completed the mandatory online induction.
Reports of child labour or modern slavery reported via SCI’s reporting channels are dealt with by the appropriate levels of the organisation. The SCI trustees and the Charity Commission are notified of any reports as appropriate. SCI anticipates that, through the efforts being made to increase awareness of this issue amongst its staff, partners and suppliers, and the access to reporting mechanisms, modern slavery can be exposed and rooted out where it exists.
SCI’s Supply Chain
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 engage with suppliers on a case-by-case basis to address queries regarding our contractual requirements (including with regard to our mandatory Modern Slavery policy). SCI provides training to suppliers in some contexts, and this is determined at the local level. In addition, SCI is also in the process of finalising and issuing a Sustainability Policy to its suppliers, which sets out its mandatory obligations (as well as recommendations). This Policy includes SCI’s expectations for its suppliers in relation to preventing and mitigating risk and occurrence of modern slavery and exploitation.
Our International Safeguarding team incorporates information on modern slavery into our partner safeguarding training which now covers adults and children.
D: OUR COMMITMENTS
SCI is committed to the continuing evaluation of our systems and processes to ensure that we can continue to raise awareness of, prevent, report and respond to issues of modern slavery.
Some of the actions which SCI will continue to focus on in 2022 include:
- Strengthening community engagement as part of our prevention work and adult safeguarding practices to help ensure that modern slavery aspects are integrated and risks mitigated.
- Enhancing awareness within SCI on modern slavery risk through the roll-out of a specific e-learning course.
- Continued delivery of safeguarding training, refresher training and guidelines to SCI’s supply chain staff globally, which incorporates information on modern slavery, helping local teams to identify and address risk areas in their contexts and providing awareness of existing tools and how to use them.
- The continued roll-out of a global platform to manage supply contracts.
- Finalising and issuing our Supplier Sustainability Policy which covers, amongst other key topics, our Modern Slavery expectations for our supplier base.
- Embedding our safeguarding risk tool 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 2021. It was approved by the Board of Save the Children International on 14 June 2022, and published on SCI’s website on 23 June 2022.