This statement is Save the Children International (“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 the risks of modern slavery in our business and supply chains.
SCI welcomed the introduction of the UK Modern Slavery Act 2015 as it is consistent with our values and mission. 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 of continuous high relevance, as we are still seeing recovery in many regions from the social and economic impacts of the COVID-19 pandemic. In addition, the global economic and energy-related crises, exacerbated by the war in Ukraine, and heightened conflict and forced displacement in other countries expose children to increased risks of child labour, exploitation and trafficking.
In 2022, Save the Children built on the pledge made during the 2021 International Year for the Elimination of Child Labour to intensify our efforts to contribute to the target made in the UN Sustainable Development Goal 8.7, which commits to ending child labour and forced labour in all its forms by 2025. In 2021, we did this in several ways (more information here), and we have further built upon this commitment, both in our advocacy and programming, in 2022.
Below are some highlights:
- We further strengthened our work in thematic areas and our global goals to ensure that children are safely returning to school, have access to safety nets and resilient livelihoods, and are living free from violence. All areas have linkages to ensuring children are safe from child labour, forced labour and that families avoid the negative coping mechanisms that can lead to trafficking and exploitation.
- Participation in the 5th Global Conference on the Elimination of Child Labour – promoting active participation of children leading up to, and during, the conference to influence the agenda to better reflect and include the views and perspectives of children.
- Save the Children has developed ways of measuring the risks of children being in child labour at different levels – rapid assessments – to better capture child labour as a negative coping mechanism and integrate it further in our work.
- We have closely followed the development of EU-level regulations and directives (the Corporate Sustainability Due Diligence and Corporate Sustainability Reporting directives and Ban on Products Produced with Forced Labour Regulation) to better reflect the nature and importance of children’s rights and promote a more victim-centred approach leading to change for children impacted negatively by corporate activity.
Examples of our work with communities include several ongoing projects aimed at preventing and responding to child labour and trafficking across the globe:
- training 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;
- 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;
- working with child migrants to help them understand the signs and risks of trafficking and exploitation; and
- the development of a life skills curriculum for migrant and displaced girls, entitled ‘Girls Decide’, which specifically addresses the risks of trafficking and how they can protect themselves from it.
Save the Children also works on child protection issues within global supply chains, including the prevention of child labour in all its forms across the world.
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 primarily by the movement’s implementing body, SCI, and 3 national offices 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 54 country offices, 2 humanitarian response offices, 3 advocacy offices and 11 partner-led programs – operating in a total of 75 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 dangerous places in the world.
Together with Member offices, SCA worked in 115 countries in 2022 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 US $2.7 billion are working to deliver a shared strategy – Ambition for Children 2030.
(I) SCI’S BUSINESS
SCI employs approximately 17,532 people across its offices globally, in addition to volunteers and contractors. We have human resources (“HR”) functions in the country and regional offices where we work, and primarily hire our workforce directly and locally, through the relevant local HR functions. In some instances, we use agencies to assist with our recruitment. Further information about how we manage modern slavery risk in our recruitment procedures is detailed in sections B and C below.
(II) SCI'S SUPPLY CHAIN
SCI has a complex, dispersed supply chain. SCI is not involved in the manufacturing, agriculture or retail industries, which typically involve high-risk activities for modern slavery.
The scale of SCI’s supply chain operations is underlined by our Supply Chain Key Statistics:
- US$ 400 million third party supplier spend; and
- approximately 2,000 supply chain headcount of which roughly 500 staff are responsible for procurement.
At least 80% of SCI’s procurement is sourced in-country by SCI’s country offices. SCI recognises the risk of modern slavery in these countries and takes this very seriously. In 2022, SCI completed the rollout of an online global procurement and payments platform to automate many of the procedures involved in the procurement and accounts payable process, from the initial stages of qualifying a supplier to the final payment being made. Part of this process involves the rollout of a technology solution called “ProSave” (using the market leading solution, SAP Ariba). The platform enables greater visibility over SCI’s suppliers and procurement/payment processes and enables increased compliance with systemised controls.
(III) SCI’S PARTNERSHIPS
SCI delivers approximately 20% 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 centre Partnerships team comprising a Head of Partnerships and two Partnerships Advisers, as well as regional and country office partnership advisors and focal points across our movement.
B: OUR VALUES AND POLICIES
(I) MANDATORY STAFF POLICIES
The responsibility to uphold SCI as a safe organisation for children, adults and colleagues is a shared responsibility of all employees.
SCI has in place a mandatory Modern Slavery and Human Trafficking Policy (“Modern Slavery Policy”), as well as various other mandatory policies, including a Code of Conduct, Child Safeguarding Policy, Protection from Sexual Exploitation, Abuse and Harassment Policy and Anti-Harassment and Bullying Policy.
SCI’s Modern Slavery Policy sets out SCI’s zero tolerance of modern slavery and our commitment to ensuring that modern slavery is not taking place in our 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 behaviour 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.
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 also has a whistleblowing policy and procedure in place and 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, 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.
All staff must sign these policies and attend mandatory training when they start at SCI. Staff are also required to complete refresher training throughout their period of employment.
SCI also has a global on-boarding process for our contractors which requires them to sign SCI’s mandatory policies, including the Modern Slavery Policy, and complete SCI’s mandatory training prior to starting work with SCI.
(II) SUPPLY CHAIN AND PARTNER POLICIES
Suppliers: In 2022, to supplement the continuous improvement and training of SCI’s core Procurement Manual and Global Procurement Policy, SCI deployed a Supplier Sustainability Policy to its 25,000 suppliers. The Sustainability Policy, which has been translated into SCI’s core languages, uses plain language to set out SCI’s expectations of suppliers in a range of areas including modern slavery, which is positioned as one of the key standards that suppliers must comply with. The Sustainability Policy also provides clear channels for suppliers and SCI staff to disclose any issues.
SCI also has comprehensive resources aimed at ensuring compliance with US Government and USAID Anti-Human Trafficking Provisions.
Partners: 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. Our Modern Slavery 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.
C: OUR ACTIONS
(I) DUE DILIGENCE PROCESSES, RISK ASSESSMENT AND MANAGEMENT
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 are adapted for the relevant local context and applicable law.
We use a framework agreement when working with recruitment agencies in the UK (with a view to global use in the future), which embeds SCI’s Modern Slavery Policy as a mandatory policy.
SCI also carries out various employee due diligence checks and reviews, including:
- vetting checks on prospective recruits before an offer of employment is made, including disclosure and barring service and reference checks prior to start date (two-stage process);
- 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;
- prohibiting fines levied to be passed on to employees and workers being charged finders’ fees (for example, in the context of agency recruitment), and not deducting accommodation or transport costs from staff salaries; and
- continuously improving the provision of a safe working environment, both physical and psychological.
Risk assessments: SCI continues to make refinements to its strategic risk management framework, to drive greater cohesion in the way risk – modern slavery being an example – is managed across the agency. Since late 2022, using an objective-centric approach, SCI has refined its strategic risk framework; defining 12 areas of focus, and objectives to be met across all of them so that risks are managed in a comprehensive and sustained manner. This new framework is currently being rolled out; and cross-functional risk committees are meeting regularly to identify, assess and mitigate the risks impacting the certainty of meeting the set objectives under each risk area.
SCI puts the rights and safety of children and adults first; to that end, safeguarding children, communities and staff is one of these 12 key areas of our risk framework. Our objectives are to proactively mitigate risks to children and adults in our programs and operations, through effective prevention, detection, reporting and response to safeguarding incidents, and support to survivors.
Supply chain contracts: SCI completed the rollout of our global IT platform to manage supply contracts. The platform is now mandatory for all active suppliers in the countries where this has been rolled out and requires the supplier to confirm that it complies with SCI’s Supplier Sustainability Policy and the other mandatory policies embedded therein, including SCI’s Modern Slavery Policy. This platform gives SCI a more robust and systematic way of ensuring that requirements our mandatory policies flow down to our suppliers.
Supplier due diligence: we have vetting systems in place for suppliers and our databases record their vetting status. 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. SCI will only work with suppliers that pass our vetting process. Our new procurement system contains a further control to ensure we only work with suppliers that have passed vetting.
Supplier visits: Our local teams determine whether to conduct inspections of suppliers, prioritising programs such as nutrition and pharma, where product quality is critical. We apply a risk-based approach in our procedures (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 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.
Partner due diligence: 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 the qualification of partners to deliver programs together with us. This helps us to consider and highlight potential issues around modern slavery in prospective partners. We also ensure that partners sign up to and commit to our Modern Slavery Policy in our partnership agreements.
Reporting: Under SCI’s Modern Slavery Policy, all suspicions and concerns of policy and contractual violations must be reported through SCI’s 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 each of the policies under SCI’s Safeguarding Policy Framework, must be reported immediately. These policies require that reports be made either through SCI’s incident reporting platform, Datix, or through whistleblowing channels. For communities reports are made via community feedback and response mechanisms or directly to safeguarding focal points. Following notification and investigation of a report, corrective action will be determined according to the details and findings 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. The SCI trustees and the Charity Commission are also notified of any reports as appropriate. The responses to reported concerns are monitored to ensure that timely and appropriate action is taken. This includes providing support to survivors.
(II) AWARENESS AND TRAINING
SCI’S STAFF
Staff awareness is key to ensuring that suspicious behaviours and indicators of modern slavery are flagged early on and appropriately managed. As previously indicated, SCI has several mandatory policies for staff. SCI staff are required to attend mandatory training on these policies, which is tracked through a Learning Management System (LMS).
SCI covers modern slavery risk as part of its safeguarding training and human resources online induction for new starters. Statistics for completion of these training courses are set out below:
- Mandatory safeguarding training is accessible by our staff across the world either in person or through webinars. During 2022, 96% of SCI new starters completed this training during their induction period.
- Mandatory global human resources online induction for new starters – Welcome to Save the Children – 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. During 2022, 91% of new starters completed the mandatory online induction. This is a 3% rise from 2021.
Procurement training courses also cover modern slavery risks.
SCI anticipates that, through the efforts made to increase awareness of this risk amongst its staff, partners and suppliers, together with access to reporting mechanisms, modern slavery can be exposed and rooted out where it exists.
SCI’S SUPPLY CHAIN
With 25,000 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 the 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 our mandatory Modern Slavery policy). SCI provides training to suppliers in some contexts, and this is determined at the local level. In addition, as previously indicated, SCI has issued a Supplier Sustainability Policy to its suppliers, which includes our expectations in relation to modern slavery. In 2023/24, further support will be provided to suppliers to assist their improvements in these areas.
SCI’S PARTNERS
Our International Safeguarding team incorporates information on modern slavery into our partner safeguarding training, which covers adults and children.
D: OUR COMMITMENTS
SCI is committed to the ongoing evaluation of our systems and processes to ensure that we continue to raise awareness of, prevent, report and respond to issues of modern slavery.
Some of the actions that SCI will continue to focus on in 2023 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 of modern slavery risk through training, including continued delivery of safeguarding training, refresher training and guidelines to SCI’s supply chain staff globally, helping local teams to identify and address risk areas in their contexts and providing awareness of existing tools and how to use them;
- strengthening safeguarding management and accountability at all levels and across all functions, including embedding our safeguarding risk tool across the organisation;
- developing a national supplier capacity-strengthening programme to help SCI’s suppliers improve their sustainability practices, including Modern Slavery; and
- the rollout of improved partnership procedures, tools and templates, which stipulate requirements in relation to modern slavery for partners.
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 2022. It was approved by the Board of Save the Children International on 13 June 2023, and published on SCI’s website on 26 June 2023.
Angela Ahrendts
Chair of the Board
Save the Children International
Date: 13.06.23