Anti-Slavery Statement 2019
The Modern Slavery Act 2015 (the “Act”) came into force in 2015. The Act requires commercial organisations with an annual turnover of more than £36 million to publish a slavery and human trafficking statement for each financial year. This statement is made pursuant to Section 54(1) of the Act and constitutes our slavery and human trafficking statement for the financial year ended 31 March 2019. The Board of Directors of Dŵr Cymru Cyfyngedig(1) approved this statement on 2 May 2019.
Our Structure and Business
Dŵr Cymru Cyfyngedig, a wholly owned subsidiary of Glas Cymru, is the Group’s principal trading company with an annual turnover of more than £36 million and is referred to as Welsh Water throughout this statement. Its principal activity is the supply of water and treatment and disposal of wastewater under the Instrument of Appointment made by the Secretary of State for Wales under the Water Act 1989. Unique in the water and sewerage sector, Glas Cymru is a company limited by guarantee and as such has no shareholders.
Welsh Water is the sixth largest of the ten regulated water and sewerage companies in England and Wales. It is responsible for providing over three million people with a continuous, high quality supply of drinking water and for taking away, treating and properly disposing of the wastewater that is produced, we are fully committed to delivering best quality service at least possible cost.
Welsh Water’s vision is to Earn the Trust of our Customers Every Day. We understand that ensuring the highest standards of governance is crucial to earning the trust of our customers. Good corporate governance helps to embed culture and strengthens and supports decision making at all levels of the business.
Welsh Water is committed to meeting the aims of the Act. We strongly oppose slavery, human trafficking and child labour and we work to raise awareness across the business and in our supply chains and any part of our business. Therefore we will not tolerate slavery and human trafficking in our supply chains or any part of our business. To be trusted to do the right thing is one of our core values. We would never knowingly engage with suppliers or contractors involved in slavery or human trafficking, and reserve the right to terminate our agreements with any third party found to have engaged in these practices.
Our Anti-Slavery Policy sets out Welsh Water’s commitment to acting ethically and with integrity in our supply chain arrangements, and the safeguards we have implemented to require that our suppliers and contractors comply with the Act. We regularly review the effectiveness of our policies and procedures, to ensure they remain fit-for-purpose.
Our Supply Chain and due diligence process
Our supply chain includes approximately 4000 suppliers of varying size and expertise from major capital programme delivery and operational support to works, services, and material supply to the UK only. In 2018-19 we paid approximately £637 million to our supply chain. Our electronic procurement system requires potential suppliers and contractors to confirm if they have committed any offence under Section 1, 2 or 4 of the Modern Slavery Act, an unsatisfactory response constitutes mandatory ground for exclusion. Our terms and conditions include contractual provisions relating to compliance with the Act. We implement these provisions in all new agreements, upon renewal of existing agreements and upon issue of purchase orders.
We have been made aware of one instance of a potentially unfair employment practice in our supply chain arising from the unauthorised use of a sub-contractor. We took immediate steps to regularise the position with our contractor and also to re-state the contractor’s obligation to pass on our requirements to sub-contractors.
We have implemented a Contract and Supplier Management process across the business and the potential for the provision of the required goods or services to give rise to a risk of Modern Slavery is a key aspect in determining the risk associated with the procurement and the consequential contract and supplier management actions that are required. Contracts are allocated into a Gold, Silver or Bronze contract management level with associated levels and frequency of monitoring specified.
Recruitment and Training
Our Human Resources Department maintains recruitment polices to protect against slavery and human trafficking in our own operations and we are working towards meeting the Welsh Government’s 12 commitments in its Code of Practice on Ethical Employment in supply chains. In 2018 we engaged with the Unseen charity to provide training to relevant colleagues and members of our supply chain. Measuring Effectiveness During 2019/2020 we will undertake a review of the effectiveness of the processes implemented to date to identify additional assessment or monitoring that may support an enhanced prioritisation of effort or resources.
Signed by: Chris Jones, Chief Executive 2 May 2019
(1) Dŵr Cymru Cyfyngedig is the only company in our Group which meets the turnover threshold to report under the Act.