Modern Slavery Act 2015 (“the Act”) Statement (“Statement”)

2023 Modern Slavery Statement

This statement sets out the steps that we, the Commonwealth War Graves Commission (“CWGC”); a Royal Charter organisation which commemorates, in perpetuity, Commonwealth service personnel who fell in the First and Second World Wars, take, as we work to ensure that slavery and human trafficking is not present in our operations or supply chain. 

We also operate a charity, (the Commonwealth War Graves Foundation) which sells (via our website and visitor centres) a limited range of branded merchandise. 

The Modern Slavery Act 2015 (the “Act”) contains criteria which, where satisfied, oblige an organisation to make a statement.  These criteria may not apply to the CWGC (and so may not oblige the CWGC to make a statement), but we unequivocally agree with the objectives which underpin the Act, and we therefore wish to set out the steps the CWGC is taking in relation to the prevention and detection of modern slavery and human trafficking.  

This statement relates to our financial year 1 April 2022 to 31 March 2023 and is our second statement (our first covered the period ending with our financial year 31 March 2022).

Our commitment

We recognise that modern slavery and human trafficking are criminal offences. We are committed to ensuring that slavery and human trafficking does not take place in our operations or supply chain,  to acting in accordance with our values,  ethically and with integrity and to implementing and enforcing effective systems and controls, including in relation to the prevention of modern slavery and human trafficking in our operations and  supply chain.  

Organisational structure

We are based in the United Kingdom and operate on a global basis (with cemeteries, memorials, and graves under our care in more than 150 countries).   

We employ approx. 1,250colleagues , with our largest centres of operation in Belgium, France, and the United Kingdom. 
 
We divide our global operations into five geographical areas, namely Africa and Asia, Canada, and the Pacific, Central and Southern Europe, France, and the United Kingdom, each with an Area Director appointed to lead operations in their respective areas.  Our Area Directors report into our Director of Operations, who is a member of our Executive Leadership Team. 

Our Executive Leadership Team has overall responsibility to ensure our policies reflect our legal and ethical obligations, and that those who work for or with us adhere to these policies, including in relation to modern slavery and human trafficking. 

Our Executive Leadership Team report on compliance, including in relation to modern slavery via our Audit and Risk Committee, to  the Commission.  

Supply chain 

The success of our operations relies heavily on collaboration with local services, contractors and suppliers based in the countries in which we operate.  We work in accordance with our procurement policy and then based on standard contractual terms.   

Our direct supply chain includes suppliers of varying sizes and expertise levels, covering construction, support to works, supply of services and material supplies. 

We procure “standard” goods and services to support our global operations (including, for example, IT and technology goods and services, construction and horticultural and services and clothing for our workforce). 
We have a significant physical estate (cemeteries and memorials), much of which is historic and requires significant upkeep and repair.  This involves:

• physical construction work (for example, maintenance and repair of structures and walls) which we will typically outsource to professional construction suppliers; and 
• horticultural services (for example, the maintenance of the green areas within our physical estate) which we discharge via a combination or our own workforce and outsourcing.    

Our policies and standards on slavery and human trafficking

We have completed the drafting of our Ethical Policies Framework, which includes both a policy regarding modern slavery and a Speaking-Up policy (which encourages those who work for, or with us to raise any concern, and is, therefore, wider than what would be included in a more traditional “whistleblowing” policy).  

We have implemented, via a third-party supplier, a global “hotline” which supports colleagues and others to raise concerns about our operations and supply chain, which includes concerns as to modern slavery and human trafficking. This supports our “speaking up” culture.  

We are in the process of amending our procurement policy and process to take account of modern slavery (noting we have included diligence re modern slavery in our standard tender documents and any party who submits a tender to us confirms the steps that they are taking to address the issue of modern slavery and human trafficking).  

We have amended standard form contracts to include specific wording dealing with Modern Slavery risks.  

Risk assessment and management 

Through our risk management process, we work to identify, assess, monitor, and report on risks, including those that relate to modern slavery. We assess the effectiveness of the controls we have in place, the impact of these risks should they materialise and the likelihood of this happening. 

While drafting this statement, we considered the results of ongoing monitoring of controls, reports of any incidents as well as the outcomes from our risk management process.

We recognise that the potential for modern slavery and human trafficking exists in our operations and supply chain.  

Our supply chain for the procurement of goods and services is relatively simple and limited, with procurement activity transacted in accordance with our procurement policy (and material procurement in accordance with the Public Procurement Regulations).  There is potential for goods that we procure to have been manufactured in conditions where modern slavery could exist (for example, the manufacture of clothing), which we mitigate via our procurement and contracting process. 

We recognise that the potential for the risk of modern slavery exists where labour is provided as a service and that potential for risk is elevated where such labour is engaged in lower income countries.  As we procure services (principally construction and horticultural services) globally, including in lower income countries, and, on occasion, on a sub-contractor basis, we recognise that this risk is present in our operations (noting, as per the above, this is mitigated by our procurement and contracting processes). 

We recognise that the potential for modern slavery exists in our operations where accommodation is provided to those who provide labour as a service which is a particular risk for us as we provide accommodation in some locations, and we procure services from suppliers who provide accommodation. 

Through our assurance work during the year:

• We did not find any instances of modern slavery or human trafficking in our operations or supply chain in our financial year 2022/3.
• Whilst recognising the generality of the potential risk of modern slavery and human trafficking, we focused our initial compliance efforts on our Africa and Asia activities, where we assess that our risk is highest (and on the basis that we will take learnings from this Area into our other Areas). 
• We have undertaken two audits of our horticultural service contractors in this Area to specifically address the potential for modern slavery and human trafficking.  In conducting these audits, we have briefed our teams on what to look out for regarding the risk of modern slavery and human trafficking.  Whilst these audits did not flag any specific issues, we continue to focus on the risk of modern slavery and human trafficking. 
• To regularise the position and reduce risk, we converted a large, contracted workforce in Kenya (some  29 contractors) from contractor status to full-time employees. 

Continuously improving our effectiveness in combating slavery and human trafficking 

We have the following key goals to measure our performance and effectiveness in combatting slavery and human trafficking over the next 12 months: 

• Complete a Modern Slavery audit of all Areas, with any requisite remedial action taken. 
• Specifically audit where accommodation is made available to contractors. 
• Raise awareness of the risk of modern slavery and human trafficking and our Speaking- Up policy via our deployment of our Ethical Policies (and we will also audit on the deployment of our Speaking-Up policy, to ensure this is disseminated, in local languages, and with a local contact number, throughout our global estate).  
• Hire a compliance specialist into a Compliance Manager role, with this role having specific responsibility for the roll-out of our Ethical Policies (including Modern Slavery and Speaking-Up policies). 
• Amend our procurement processes to enhance our approach to ‘ethical procurement’. 
• Investigate any actual or potential incidents which would, if we were subject to it, be a breach of the Act. 
• Develop and implement a training programme to raise awareness of the potential for modern slavery and human trafficking and to ensure that where risk has been identified, our employees who are closest to that risk are trained specifically to reduce the risk and manage and address the potential consequences.   

This document constitutes our Slavery and Human Trafficking Statement, for the financial year ending 31 March 2023.

Claire Horton CBE

Director General

COMMONWEALTH WAR GRAVES COMMISSION

Date: 22 September 2023

About us 

The Commonwealth War Graves Commission (“CWGC”) is a Royal Charter organisation which commemorates, in perpetuity, Commonwealth service personnel who fell in the First and Second World Wars. We have six member governments: Australia, Canada, India, New Zealand, South Africa, and the United Kingdom.

Applicability of the Modern Slavery Act

As at the date of this Statement, the Act contains criteria which, where satisfied, oblige an organisation to make a Statement. Whilst these criteria may not apply to the CWGC (and so may not oblige the CWGC to make a Statement), we unequivocally agree with the objectives which underpin the Act, and we therefore wish to make a Statement to set out the steps the CWGC is taking in relation to the detection and prevention of modern slavery and human trafficking.

Context for this Statement

This Statement was completed in December 2021 and relates to our financial year 2021/2022 (noting that our final year runs 1st April to 31st March in each year), with actions established for the financial year 2021/2022 and for the end of the calendar year 2022. We will publish an update to this Statement after the end of our 2022/2023 financial year (therefore after March 2023). In this Statement, we set out the initial steps that we have taken, which focus on an audit of our operations to understand where the potential for risk of modern slavery or human trafficking exists, as identified in the Risks below. We will, from time to time, update this Statement (and noting that the Modern Slavery Act contemplates annual updates at the end of each financial year, but, as we are posting this Statement toward the end of our financial year, we would anticipate providing an interim update in the summer of 2022), to show our progress, in accordance with the KPI’s below.

Our Commitment

We oppose slavery and human trafficking in all its forms, and we are committed to acting ethically and with integrity in all our relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place in our operations or supply chain. 

Organisational Structure and Supply Chain

Organisational Structure

• We are based in the United Kingdom and operate on a global basis (with cemeteries, memorials, and graves under our care in more than 150 countries).
• We employ approx. 1250 employees, with our largest centres of operation in the Belgium, France, and the United Kingdom.
• We divide our global operations into distinct geographical areas with an Area Director appointed to lead operations in each of these areas. The Area Directors report into our Operations Director, who is a member of our Executive Management Team and who is based in our head office in Maidenhead, UK. 

Supply Chain

By way of broad overview of our operations and supply chain:

• We procure what we would term as standard goods and services to support our global operations (including, for example, IT and technology goods and services, construction and horticultural and services and clothing for our workforce).
• We have a significant physical estate (cemeteries and memorials), much of which is historic and requires significant upkeep and repair. This involves:
  • physical construction work (for example, maintenance and repair of structures and walls) which we will typically outsource to professional construction suppliers; and
  • horticultural services (for example, the maintenance of the green areas within our physical estate) which we discharge via a combination or our own workforce and outsourcing.
• We have a charity (the Commonwealth War Graves Foundation) which sells (via our website and visitor centres) a limited range of branded merchandise (cups, notebooks, badges and alike).

Policies

In support of this Statement, we will issue guidance and training as to the detection and prevention of slavery and human trafficking, to ensure that our commitment (as set out above) is broadly articulated, well understood by all who work for or with us and is integral to our operations.  This will include both a policy for employees and suppliers (as part of which, we will consider an Ethical Dealing policy/code of conduct for suppliers).  We have included the creation and implementation of this guidance/policies as a KPI (see below). 

Due Diligence

In preparing this statement, we have carried out initial due diligence on our operations and supply chain and have identified potential areas of risk (see Risks below), which will be the focus of our due diligence and action in the next financial year.   

Risk Assessment and Management

We recognise the potential for modern slavery and human trafficking exists in our operations and supply chain.  By way of overview:

• Our supply chain for the procurement of goods is relatively limited and straightforward, with procurement activity transacted in accordance with our procurement policy (and material procurement in accordance with the Public Procurement Regulations). There is potential for goods that we procure to have been manufactured in conditions where modern slavery could exist (for example, the manufacture of clothing), which we mitigate via our procurement and contracting process.
• Our supply chain for the provision of services largely mirrors that for the procurement of goods (noting that, with construction and other areas of work, we have major projects, which are commonly outsourced, again with our procurement and contracting process mitigating risk).
• It is recognised that the potential for the risk of modern slavery exists where labour is provided as a service and that potential for risk is elevated where such labour is engaged in lower income countries. As we procure services (principally construction and horticultural services) globally, including in lower income countries, and, on occasion, on a sub-contractor basis, we recognise that this risk is present in our operations (noting, as per the above, this is mitigated by our procurement and contracting processes).
• It is also recognised that the potential for modern slavery exists where accommodation is provided to those who provide labour as a service and as we provide accommodation in some locations, we recognise that this risk is present in our operations.

Actions the organisation has taken to prevent slavery and human trafficking in our business or supply chain measured against performance indicators.

In conducting initial due diligence to support the provision of this Statement, and assessing where risk might exist, we have not detected any issues which would lead us to conclude that modern slavery or human trafficking is present in our operations or supply chain.   However, we recognise that the work beyond our initial diligence, as set out in the KPIs (below) is required to enable us to better understand risks and then be able to take such additional steps as are required to manage these risks.

Key performance indications ("KPIs")
Measure	Measurement target - Financial Year End 21/22 (31 March 2022) or by Calendar Year End 2022 (31 December 2022)
Fully audit our operations on a risk-based prioritisation, beginning with Africa and Asia and addressing the procurement of labour services and the provision of accommodation in these continents (noting that audit beyond Africa and Asia will be undertaken subsequently).	Africa and Asia by the end of Financial Year 2022
Review and where required enhance contracting standards (so that, for new suppliers, when we procure goods and services, our suppliers are always subject to a contractual obligation to comply with the Act)	100% by the end of Financial Year 2022
Review on a priority basis existing contracts to ascertain if these contain appropriate wording re compliance with the Act	80% plus by the end of Year End 2022
Review procurement policy to ensure that it deals appropriate with the requirements of the Act	100% by the end of Financial Year 2022
Implement a policy for Modern Slavery Act compliance for our suppliers (potentially as part of an Ethics Policy), with publication of this policy on our website and distributed as part of the contracting process with new contracts (noting that auditing compliance against this policy will commence in a subsequent financial year)	100% by the end of Financial Year 2022
Implement a policy for Modern Slavery Act compliance for our staff (potentially included in Ethics Policy).	100% by the end of the Financial Year 2022
Implement a training programme for our staff, to ensure that all staff are aware of the Act, and of our policy, and how it might impact on our operations and supply chain and how to spot and report potential issues	100% for implementation of training programme by the end of the year 2022, with 90% plus of staff trained within this period.

Training

As per the KPI above, to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will, over the course of the financial year 2021 to 2022, develop and implement a training programme, to raise awareness of the potential for modern slavery and to ensure that where risk has been identified, our employees who are closest to that risk are trained specifically (including to recognise the risk of modern slavery).   

Raising concerns and Whistleblowing

We have implemented, via third party supplier Safecall Limited, a global “hotline” which supports colleagues and others to raise concerns about our organisation and operations (Safecall Limited provide in-country telephone numbers).  We have also implemented a Whistleblowing Policy, which ensures colleagues and others know that the CWGC embraces a “speak out” culture.  We will ensure that this service and policy is available, and that colleagues and others have access to it so that there is certainty and confidence as to identifying and raising concerns (including as to modern slavery and human trafficking). 

This Statement is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 31 March 2022. It has been approved by the CWGC’s Executive Management Team. 

Claire Horton CBE

Director General

COMMONWEALTH WAR GRAVES COMMISSION

Date: 10 December 2021

Statement updated 29 November 2022, to add that we will be publishing our updated Statement after the end of our financial year 2022/3, therefore after March 2023.