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 with children, families, communities, churches, other non-governmental organisations and national and 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.
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 2018 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 2017/18 financial year
During the 2017/18 financial year, WVUK took the following steps to prevent modern slavery and human trafficking from taking place within our supply chains:
1. WVUK applied for and were awarded a DFID UK Aid Connect grant focussing on “ Effective Approaches to End Worst Forms of Child Labour” The programme refers to the ‘worst forms of child labour’ (WFCL) as defined by Article 3 of ILO Convention No. 182, which occurs when children are sold, trafficked, in debt bondage, serfdom or forced labour, or are forcibly recruited into armed conflict, used in prostitution or pornography, or engaged in hazardous work. By any measure, many WFCL can be classified as modern slavery. This will enable us in the coming years to strengthen our work on tackling modern slavery.
2. WVUK re-wrote the Safeguarding policy and introduced Behaviour protocols. These state clearly what is unacceptable behaviour, including sexual abuse, other forms of abuse, humiliating, degrading or exploitative behaviour, the hiring of children for any form of child labour which includes ‘house help’. These protocols have been communicated and are signed by all employees, contractors, consultants.
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.
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 international coordination of the WV Partnership) and its branch offices around the world, subsidiaries of WVI and other legal entities across the world which are not WVI subsidiaries (together the “WV Partnership entities”). WVUK forms part of the latter group.
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 culture of 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.
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. WWUK does not work directly with any suppliers in sectors which are considered to be particularly vulnerable to human trafficking such as construction, farming or hospitality. However, WWUK 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 include those listed below. In addition, WVUK also adopts the WV Partnership documents listed below. All of these have a role to play in tackling modern slavery.
a) WVUK Ethical Policy – ensures that through due diligence procedures due consideration is given to the track record of significant donors, partners or suppliers in areas including human and/or workers’ rights and use of bonded or child labour.
b) WVUK Code of Conduct Policy - 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.
c) WVUK Safeguarding Policy - prohibits all WVUK representatives from hiring children in any form of child labour (which we define as work which is mentally, physically, socially or morally dangerous or harmful to children or that interferes with their schooling).
d) WVUK Risk Management Policy - ensures effective management of risks to which WVUK is exposed through its activities.
e) WVUK Whistleblowing Policy - refers to specific examples of misconduct, as well as illegal acts generally.
f) WVUK Contract policy and Contract Policy Implementation Guide - 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 and contracts should reference and require compliance with the WVUK Safeguarding Policy.
WV Partnership Global Supply Chain Management Procurement Manual - requires consideration to be given to the principles of sustainable procurement, including relating to social impact, when making procurement decisions.
a) 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.
b) The WV Partnership Whistleblowing procedure - WV Partnership uses a leading third-party provider of ethical reporting services to support the WV Partnership’s "whistleblowing" mechanism. A confidential telephone hotline and on online reporting tool are available to staff, partners in the field, contractors and others wishing to report suspected illegal or unethical conduct by 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, you can use the following link www.worldvision.ethicspoint.com.
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 requires a supplier selection questionnaire to be completed. This requires 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.
In the context of programmes, WVUK requires all non-World Vision partners it engages to complete a due diligence questionnaire. This questionnaire states that WVUK avoids any association with bonded or child labour, slavery and human trafficking and asks potential partners to confirm they have no association with such practices. 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’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 is introducing a new training module which includes a section on modern slavery. This module will become mandatory for all staff during the 2018/19 financial year. 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.
Going forward, WVUK remains committed to keeping its policies, procedures and training under review and updating these as needed in order 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 WVUK and signed on their behalf.