Modern Slavery Statement

World Vision UK (WVUK) is a charity devoted to improving the lives of the world’s most vulnerable children through child-focused international relief, development, and advocacy. WVUK works primarily with children, families, communities, and churches. As well as various non-governmental organisations, international authorities and governments to achieve the best outcomes for children.

WVUK has a zero-tolerance stance on acts of modern slavery and human trafficking. It is pro-active in taking steps to prevent such acts occurring within its own supply chain and to ensure that on programmes it only partners with organisations that also observe appropriate ethical standards.

According to the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, WVUK complies with its obligations under the Act. However, as WVUK is not a commercial organisation within s54(2) of the Act (because its income is mostly derived from grants and other donations) and its turnover is below the threshold in s3(1) of the Act, it is not required to publish a statement. WVUK therefore publishes this statement on a voluntary basis.

This is a slavery and human trafficking statement within the meaning of section 54 of the Modern Slavery Act 2015 (the ‘Act’) for the financial year ended 30 September 2021 and outlines WVUK’s continued efforts towards tackling modern slavery and human trafficking in its supply chain and wider activities. The structure of this statement follows the order of section 54(5) of the Act.


Actions taken during the 2020 - 2021 financial year

During the 2020 - 2021 financial year, WVUK took the following steps to prevent modern slavery and human trafficking from taking place within our supply chains:

  1. WVUK continues to provide Board members and employees with the WVUK Safeguarding Policy, which is reviewed annually, and all recipients are required to confirm their adherence to the Behavioural Protocols listed within the policy. Protocol 2.2 Unacceptable behaviour (i) specifically calls out child labour and expects any WVUK representative to report any suspected or known incidents immediately to the Safeguarding manager.
  2. Third parties engaged by WVUK, where the third party, its employees or any person or entity engaged by them in connection with performance of a contract with WVUK may have access to beneficiaries, our systems or data while performing their contract with WVUK, are given the WVUK Safeguarding Policy and required to provide signed confirmation that they will adhere to the Behaviour Protocols.
  3. An independent legal review of WVUK’s Modern Slavery Statement was undertaken. Our statement was rated as ‘very good’.
  4. During the year, 41 employees undertook external professional training on the identification and measures for prevention of modern slavery, along with guidance on third party due diligence, risk mitigations and analysis and discussion of case studies to understand actions which would be undertaken where modern slavery is identified.


Structure, Activities and Supply Chain

WVUK is a private company limited by guarantee incorporated in England and Wales and a registered charity. The Board of Trustees of WVUK is responsible for the overall control of the organisation, its strategic direction and ensuring that it is properly managed.


WV Partnership

WVUK is part of the World Vision Partnership (WV Partnership), a network of entities in a voluntary partnership which works in close to 100 countries providing services to people regardless of religion, race, ethnicity or gender. The WV Partnership comprises World Vision International (WVI), a US-incorporated legal entity which provides strategic direction and governance of the WV Partnership, and its branch offices around the world, subsidiaries of WVI and other legal entities across the world which operate under the World Vision name and covenant of partnership but are not WVI subsidiaries (together the ‘WV Partnership entities’). WVUK forms part of the latter group.


Programme Delivery

WVUK is one of several ‘support offices’ which raise funds for the WV Partnership’s overseas relief and development programmes. Programmes financed by WVUK-raised funds are usually delivered by in-country WV Partnership entities, with appropriate technical and other support provided by WVUK. Most of WVUK’s expenditure on overseas programmes is therefore made through other WV Partnership entities. WVUK has a long-term relationship with other WV Partnership entities and there is a commitment to information-sharing and transparency within the WV Partnership. All WV Partnership entities share the same zero-tolerance stance in relation to modern slavery and human trafficking and comply with the WV partnership policy documents described below.
Programme expenditure is sometimes made through non-World Vision partners where this is appropriate for effective implementation. This statement sets out the steps WVUK takes to ensure that third parties engaged in WVUK-funded programmes are also taking appropriate steps to mitigate the risk of modern slavery and human trafficking. This includes putting in place appropriate community level feedback and complaints mechanisms.


UK operations

WVUK uses various suppliers to enable it to carry out its charitable activities, including in the areas of fundraising, marketing, IT, office facilities and employment. In all supplier contracts WVUK remains vigilant and has policies and procedures in place to mitigate the risk of human trafficking and modern slavery affecting its supply chain.


Policies and Procedures

WVUK’s internal policies, which support its Modern Slavery principles, include those listed below. In addition, WVUK also adopts the WV Partnership documents listed below.

WVUK

  1. WVUK Ethical Policy – ensures that through due diligence procedures due consideration is given to the track record of significant donors, partners and suppliers in areas including human and/or workers’ rights and use of bonded or child labour.
  2. WVUK Code of Conduct - emphasises WVUK’s commitment to conduct that is ethical and legal, that WVUK opposes illegal acts in any of its activities and that WVUK requires adherence by personnel to all applicable laws and organisational policies.
  3. WVUK Risk Management Policy - ensures effective management of risks to which WVUK is exposed through its activities.
  4. WVUK Whistleblowing Policy - refers to specific examples of misconduct, as well as illegal acts generally.
  5. WVUK Safeguarding Policy - reiterates that WVUK has zero tolerance for human trafficking and provides that, where appropriate, counterparties may be required to explain what processes and policies they have in place to safeguard against such practices.


Safeguarding Policy and Behaviour Protocols

The WVUK Safeguarding Policy prohibits all WVUK representatives from hiring children in any form of child labour (which is defined as work that is mentally, physically, socially or morally dangerous or harmful to children or that interferes with their schooling). The Safeguarding Policy is reviewed annually. The policy includes enhanced standards for reporting, prevention and managing responses to harm or abuse of beneficiaries and associates. All staff and trustees are required to read the policy annually and confirm their adherence to it.

The Behaviour Protocols are also reviewed annually and state clearly what is unacceptable behaviour, calling out sexual exploitation and abuse, all other forms of abuse, humiliating, degrading or exploitative behaviour, and the hiring of children for any form of child labour which includes ‘house help’.

WVUK is committed to continuous improvement of safeguarding efforts to protect all people and doing ‘no harm’ to others. The Behaviour Protocols have been communicated to and are signed by employees, trustees, consultants, contractors and third parties. All staff and trustees are required to review and sign the Behaviour Protocols annually to confirm their adherence to the required behaviours.


WV Partnership

The WV Partnership Global Supply Chain Management Procurement Manual requires consideration to be given to the principles of sustainable procurement, including social impact, when making procurement decisions. The WV Partnership Guide to Humanitarian Standards reminds staff involved in the implementation of programmes of the risk of trafficking and directs staff to use socially responsible businesses and local labour and ensure that procedures are in place to provide a safe working environment and appropriate remuneration. To support the WV Partnership Whistleblowing mechanism and procedure, the WV Partnership uses a leading third-party provider of ethical reporting services. A confidential telephone hotline and an online reporting tool are available to staff, partners in the field, contractors and others wishing to report suspected illegal or unethical conduct by the WV Partnership or its personnel. This includes reporting any concerns in relation to modern slavery and human trafficking which may be taking place within WVUK's business or supply chain. To make an online report, visit ethicspoint.



Due diligence

WVUK has due diligence procedures in place to minimise the risk of WVUK engaging directly with an organisation involved in unethical practices or of such an organisation being involved in any programme funded by WVUK.

For all new WVUK suppliers, regardless of value, WVUK undertakes Supplier Due Diligence, prompting WVUK staff to consider ethical purchasing as part of the selection of suppliers. For significant suppliers, an ethical due diligence checklist must be completed which requires staff to consider the track record of the supplier in areas including human and workers’ rights and use of bonded or child labour.

WVUK’s Supplier Due Diligence process includes a compulsory check on new suppliers’ modern slavery commitments. Where applicable to the size of their business, new suppliers must provide a copy of their Modern Slavery Statement to WVUK.

In the context of programmes, WVUK completes due diligence checks on all partners and requires those partners to carry out checks on their sub-contractors to confirm that neither the partner nor their sub-contractors have any association or involvement in excluded sectors.

World Vision has identified the following as excluded sectors and practices and avoids association with them: tobacco, weapons, gambling, pornography (including magazines, books, films and websites), exploitative credit (interest rates significantly above market average, usury, predatory lending), environmental degradation (particularly that which affects community health and livelihoods), unethical marketing techniques, infringement of workers’ rights, bonded or child labour, human trafficking, infringement of human and indigenous rights and conflict financing, sexual or racial discrimination,
In addition, partners are asked to provide WVUK with a copy of their ethical policies, including in relation to labour practices and human rights. Where a partner is going to be engaged by another WV Partnership entity in the programme country, WVUK requires that WV Partnership entity to carry out appropriate due diligence. WVUK staff review the results of this exercise to ensure that only entities which meet WVUK’s standards are involved in WVUK-funded programmes.

WVUK seeks to select banks and counterparties which are consistent with our values and charitable objects. Due diligence is conducted on any banking institution or other counterparty to seek assurance about their appropriateness in compliance with WVUK’s Ethical Policy. In addition, WVUK regularly reviews its investments and corresponding counterparties.


Agreements

WVUK’s agreements with downstream partners on programmes, both WV Partnership entities and non-World Vision partners, include obligations relating to workers’ rights, including that the partner will not employ, enslave, engage or otherwise use forced labour, trafficked labour or child labour.


Training available to staff

WVUK includes an induction training module for new employees that includes specific content on modern slavery. The module provides guidance on what modern slavery is, who is affected, what the signs are and what staff should do if they suspect that modern slavery is taking place.

At the start of grant funded projects, training is provided for staff and partners seeking to deliver projects in communities overseas, which includes modern slavery.


Conclusion

WVUK remains committed to keeping its policies, procedures and training under review and updating these as needed to maximise the contribution it makes to efforts to tackle modern slavery and human trafficking internationally.


This statement has been approved by the Board of Trustees of World Vision UK and signed on their behalf on 26 November 2021.


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