MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FINANCIAL YEAR 2024/5
1. Report Overview
1.1 This Statement sets out the work that the Commonwealth War Graves Commission (“CWGC”) and the Commonwealth War Graves Foundation (“CWGF”) (referred to collectively in this statement as “our”, “us” or “we”) have undertaken to combat Modern Slavery in our organisation and operations, during our financial year 1 April 2024 to 31 March 2025 and an overview of how we will continue this work for the financial year to come (1 April 2025 to 31 March 2026).
1.2 This is our fourth annual Modern Slavery Statement.
1.3 During this financial year, we have continued to make good progress with our work.
1.4 We are not aware of any instances of Modern Slavery in our operations or organisation.
2. Our Commitments
2.1 We recognise that Modern Slavery and Human Trafficking (which we refer to as Modern Slavery in this Statement) are criminal offences and offend against basic human rights.
2.2 We are committed to:
2.2.1 upholding our CARE values and acting ethically and with integrity,
2.2.2 working proactively to identify and manage risks and issues relating to Modern Slavery in our operations and supply chain,
2.2.3 implementing and enforcing effective systems and controls in relation to the prevention of Modern Slavery in our operations and supply chain; and
2.2.4 ensuring that those who work for or with us are aware of the risks of Modern Slavery and are also aware of, and join us with, our commitments to combat this (including via our provision of training to our colleagues).
2.3 During 2024/5, we have also committed to the United Nations Sustainable Development Goals (SDGs), by selecting five of the SDGs which are most relevant to our activities, including our on-going work as relate to human rights. More information on these can be found on the CWGC Website here.
3. Organisational Structure
3.1 We are based in the United Kingdom.
3.2 The CWGC operates in accordance with its Royal Charter, is overseen by its Commissioners (and delegated committees), and managed by its Executive Leadership Team (“ELT”).
3.3 The CWGF, a Charity Incorporated Organisation of the CWGC, is overseen by its Trustees and managed by the Director of the Foundation (who is a member of the ELT).
3.4 The ELT has overall responsibility for our work in relation to combating Modern Slavery, with the General Counsel and the Head of Ethical Compliance having day to day responsibility for managing this work.
3.5 Our work is global (with cemeteries, memorials, and graves under our care in more than 150 countries and territories).
3.6 We employ approx. 1350 colleagues, with our largest centres of operation in Belgium, France, and the United Kingdom.
3.7 We divide our global operations into five geographical areas, namely Africa and Asia, Canada, and the Americas, Central and Southern Europe, France, and the United Kingdom and Northern Europe, each managed by an Area Director. Our Area Directors report into our Chief Operating Officer, who is a member of our ELT.
4. Policies and Training
4.1 Our Anti-Modern Slavery Policy sets out our approach to combatting Modern Slavery.
4.2 Our Fair Treatment at Work Policy sets out our core ethical commitments to colleagues and to those who work for or with us, including the right to work in a safe working environment and to be treated fairly.
4.3 Our Speaking Up Policy outlines our shared commitment to acting in accordance with our CARE Values and ensuring integrity, transparency, and honesty, in compliance with law and regulation and our Speaking Up Process outlines how colleagues may Speak Up, including about matters relating to Modern Slavery.
4.4 Our Supplier Code of Conduct sets out the standards of conduct and practice that we require of our Suppliers and those that work with them (sub-contractors, etc.). We will not work with Suppliers who are not able to meet the requirements of our Supplier Code of Conduct (but we recognise that it may be appropriate and right for us to provide guidance and support to enable Suppliers to improve their own practices to ensure legal and ethical expectations are met and to allow Suppliers time to make the required adjustments).
4.5 During the financial year, we have:
4.5.1 worked to communicate the requirements of our Supplier Code of Conduct to existing Suppliers,
4.5.2 redesigned and relaunched our Speaking Up Policy to further simplify, supported by QR Codes to ensure ease of accessibility,
4.5.3 designed and launched a Modern Slavery awareness training module, tailored to the risks of the organisation. The training offers colleagues an understanding of what Modern Slavery is and the potential risks that exist in our operations, providing an overview of roles and responsibilities, and our associated policies and procedures. This training will form part of our new starter induction training,
4.5.4 delivered a Modern Slavery awareness workshop to management in our Africa and Asia Area. The workshop was designed to build knowledge about the types and signs of Modern Slavery, focussing specifically upon, and gathering insights about, the risks faced in their countries and territories of operation; and
4.5.5 as part of ethical compliance reviews and training, raised visibility with colleagues and Suppliers as to the risk of Modern Slavery in the sourcing of goods and services, and the mechanism for reporting concerns via our Speaking Up Process.
5. Risk Management, Monitoring and Reporting
5.1 We have mapped the Walk Free Global Slavery Index prevalence and vulnerability data to our countries of operation. This coupled with our knowledge of the type of goods and services that we are procuring from Suppliers enables us to better understand the risk landscape as relates to Modern Slavery and to factor this into our decision making.
5.2 We list Modern Slavery risks and associated controls on our legal and operational risk registers and review these regularly.
5.3 We monitor compliance with our Anti-Modern Slavery, Fair Treatment at Work Policies and Supplier Code of Conduct through:
5.3.1 the identification of issues and concerns reported via our Speaking Up Process,
5.3.2 monitoring of the supplier set up process,
5.3.3 regular discussions with Area management,
5.3.4 scheduled inspections of migrant worker accommodation; and
5.3.5 conduct of country compliance reviews.
5.4 We provide an Ethical Compliance update to senior management on a quarterly basis as part of our quarterly management meeting and will continue to develop our approach to monitoring and reporting.
5.5 During the financial year, we have implemented a mechanism for monitoring migrant worker accommodation in Malaysia and Singapore to ensure that this accommodation is acceptable (in line with in-country legislation and health and safety requirements) and conducted inspections of our operations in Kenya, Tanzania and of Suppliers in other locations.
6. Our plans for 2025/6
6.1 In our next financial year we will continue our efforts to combat Modern Slavery, which will involve on-going work in many of the areas outlined above, and will also include:
6.1.1 A risk-based approach, prioritising where risks may exist, and including, for example:
6.1.1.1 Attention for our sites where accommodation is provided; and
6.1.1.2 Review of the use of any so called “casual labour”.
6.1.2 Investigating and taking appropriate action in relation to any actual or potential incidents where identified,
6.1.3 Enhancement of our supplier due diligence and monitoring approach,
6.1.4 Improving the centralised visibility of our supplier contracts and further enhancement of our supplier data; and
6.1.5 Continuing to raise the potential risks of Modern Slavery via training and engagement, including the delivery of Modern Slavery awareness training to colleagues who work outside of office-based functions.
This document constitutes our Modern Slavery and Human Trafficking Statement, for the financial year ending 31 March 2025.
Claire Horton CBE
Director General
COMMONWEALTH WAR GRAVES COMMISSION
Date: 1st June 2025