MODERN SLAVERY AND HUMAN TRAFFICKING STATEMENT FINANCIAL YEAR 2025/6
1. About this statement
1.1. This statement is published under section 54 of the Modern Slavery Act 2015. It explains the steps CWGC, CWGF and CWGE (together, “we”) have taken to prevent Modern Slavery and human trafficking in our operations and supply chains during the financial year 1 April 2025 to 31 March 2026.
1.2. During this reporting period, no incidents of Modern Slavery were identified.
2. Our Organisational Structure and Supply Chain
2.1. The CWGC is headquartered in the United Kingdom and operates globally, with cemeteries, memorials and graves in more than 150 countries. We employ approximately 1,350 colleagues across a diverse range of roles, including direct employees and those working for or with us via third parties.
2.2. The CWGC operates in accordance with its Royal Charter, is overseen by our board of Commissioners (and delegated committees), and managed by its Director General and her Executive Leadership Team (“ELT”).
2.3. The CWGF, a Charity Incorporated Organisation of the CWGC, is overseen by its Trustees and managed by the Director of the Foundation (who reports to the Director General and is a member of the ELT).
2.4. During 2025/26, we created the Commonwealth War Graves Enterprises (CWGE), a wholly owned subsidiary trading company of CWGF. It is overseen by its own Board of Directors which include The Director General, The Chairman and two Trustees of the Foundation and the Commission’s General Counsel
2.5. We divide our global operations into five geographical areas: Africa and Asia; Canada and the Americas; Central and Southern Europe; France; and the United Kingdom and Northern Europe. Each area is managed by an Area Director. Our Area Directors report to our Chief Operating Officer, who reports to the Director General and is a member of the ELT.
2.6. Our global supply chain supports our operations and includes a broad range of suppliers, engaged to deliver goods and services necessary to maintain cemeteries, memorials and graves worldwide.
3. Our Commitment
3.1. We recognise that Modern Slavery and human trafficking (which we refer to as Modern Slavery in this Statement) are serious criminal offences and violations of fundamental human rights.
3.2. We are committed to:
3.2.1. Upholding our CARE Values and acting ethically and with integrity in all that we do,
3.2.2. Working proactively to identify and manage risks and issues relating to Modern Slavery in our operations and supply chains,
3.2.3. Implementing and enforcing effective systems, controls and training in relation to the prevention of Modern Slavery in our operations and supply chain, and
3.2.4. Protecting the welfare and dignity of all those who work for or with us.
4. Organisational Policies
4.1. Our commitment is embedded within our CARE Values and dedicated Policies and Frameworks:
4.1.1. Our Anti-Modern Slavery Policy sets out our approach to combatting Modern Slavery.
4.1.2. 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.
4.1.3. 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.
4.2. Our Policies and Processes are reviewed every two years and then on a needs basis if law or regulation changes to ensure these remain aligned with applicable legislation and recognised good practice; they are translated into multiple languages to enable accessibility for colleagues.
4.2.1. During this reporting period, we have continued work to embed our Speaking Up Policy and Process, improving understanding across our global workforce of how to raise concerns.
4.2.2. We also refreshed our materials to ensure continued awareness of Speaking Up. With the support of Area Management, we deployed new posters across all base sites, distributed pocket cards to colleagues, and delivered “toolbox talk”-style briefings organisation-wide, at all levels. These sessions raised awareness of the Speaking Up process, covering what to report, how to report, and what happens after submission, including visibility of concerns. Briefings were delivered via full staff meetings or standalone sessions by Area Management (Area Directors, Regional Managers and Country Managers) in local languages to ensure accessibility and understanding.
5. Risk Assessment and Due Diligence
5.1. Modern Slavery risks, together with associated mitigating controls and actions, are identified, assessed and recorded within relevant Area and Functional Risk Registers. These risks are actively managed and reviewed on a quarterly basis to ensure controls remain effective and emerging risks are addressed in a timely way. We recognise heightened Modern Slavery risk where:
5.1.1. Accommodation is provided to migrant workers,
5.1.2. Casual, seasonal, contingent or migrant workers are used (either by us directly or via a supplier); and
5.1.3. Operations take place in jurisdictions with a greater prevalence of, or vulnerability to Modern Slavery (based on the Walk Free Global Slavery Index).
5.2. Accommodation
5.2.1. Work has continued to review the living conditions and welfare of migrant workers in Malaysia and Singapore (which we employ via a local supplier), recognising that accommodation provided to migrant workers is recognised as a risk for Modern Slavery. No issues were identified through the reviews undertaken.
5.3. Labour (casual, seasonal, contingent or migrant workers)
5.3.1. During 2025/26 we have deepened our understanding of the use of so called casual (day) labour within our operations and we have developed a process for this which will introduce strengthened controls for casual and temporary labour, including recruitment, verification, pay arrangements, supervision and record keeping. A record of casual labour use has also been established.
5.3.2. This work forms part of a wider programme of continuous improvement to ensure fair treatment, transparency and accountability in labour practices across our global organisation.
5.4. Operations in jurisdictions with a greater prevalence of, or vulnerability to Modern Slavery
5.4.1. Our managers in region/in country provide an important source of control and assurance in relation to modern slavery risks at local level. We work with local and area management teams to support awareness of modern slavery risks and engage with colleagues regularly to ensure such risks remain visible, reportable, monitored and managed.
5.4.2. During this reporting period, this approach was evidenced through an investigation led by local management into a contractor providing horticultural services to the CWGC, which was initiated due to concerns relating to potentially fraudulent activity and horticultural standards. During this investigation, our local manager engaged directly with the contractor’s workers, who raised concerns regarding delayed pay and their treatment by the contractor. While these concerns were not substantiated as instances of modern slavery, it is recognised that such could be indicators of a potential modern slavery risk (and more generally flag concerns as to employment practices), and it is positive that the investigation identified these potential concerns. As a result of the investigation and of our findings, the contractual relationship was terminated, and the affected workers were transferred to an alternative, existing contractor of the CWGC operating to appropriate standards. We continue to strengthen our supplier due diligence, monitoring, and escalation processes.
6. Training and Communication
6.1. Training
6.1.1. CWGC has a bespoke Modern Slavery Awareness training module, mandatory for management and colleagues who work in jurisdictions with a greater prevalence of, or vulnerability to Modern Slavery (based on the Walk Free Global Slavery Index). The training explains Modern Slavery risks in our operations and supply chain, outlines individual and organisational responsibilities, and reinforces relevant policies and Speaking Up reporting routes.
6.1.2. We will review the module in 2026/27 to enhance global accessibility, including expanded translation capability.
6.2. Ethical Compliance Newsletter
6.2.1. In August 2025 we created and published the first edition of our Ethical Compliance Newsletter for colleagues globally. The first edition focused on Modern Slavery. The newsletter aimed to:
6.2.1.1. Raise awareness of Modern Slavery risks,
6.2.1.2. Reinforce individual and managerial responsibilities,
6.2.1.3. Encourage professional curiosity in procurement and supplier engagement; and
6.2.1.4. Promote Speaking Up channels.
6.2.2. The newsletter was distributed in multiple languages to maximise accessibility and impact across our whole international workforce, both inside, and outside office-based locations.
7. Supply Chain Management
7.1. Supplier Code of Conduct
7.1.1. 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.).
7.1.2. Suppliers of goods and services to the CWGC are contractually obliged to comply with our Supplier Code of Conduct. We share it with suppliers at the point of engagement, they are required to confirm compliance as part of the vendor set-up process, supported by a clear contractual obligation to comply, and it sets our expectations on Modern Slavery, labour standards, human rights, and ethical and legal practice.
7.1.3. The Supplier Code of Conduct is translated into multiple languages to ensure accessibility. This also includes a pictorial version for use where literacy challenges may exist.
7.1.4. We will not work with suppliers who are unable to meet the requirements of our Supplier Code of Conduct. Where appropriate, we may provide guidance and support to help suppliers strengthen their practices, meet legal and ethical expectations, and implement necessary improvements over a proportionate period, particularly in jurisdictions where local norms differ from our standards.
7.2. Raising Visibility of Procurement and Contract Requirements
7.2.1. During 2025/26, Managing Public Money training was successfully delivered to over 200 colleagues in office-based functions across the globe as part of the CWGC’s wider financial and procurement control framework.
7.2.2. The training has strengthened understanding of delegated authority and procurement requirements, resulting in improved compliance with the Procurement Policy, which in turn mandates the use of the Supplier Code of Conduct, and more consistent use of the Contracts Register. Together, these measures strengthen assurance over procurement activities and enhance our understanding of our supplier base.
7.3. Supplier Due Diligence
7.3.1. During 2025/26, enhanced due diligence was undertaken on a supplier who we have engaged to maintain our cemeteries in a region of North Africa, where CWGC travel is restricted due to FCDO advice. An independent third‑party review was commissioned in the region to provide assurance over modern slavery risks. No modern slavery concerns were identified.
7.3.2. We have also worked with our marketing and CWGF teams to enhance the due diligence performed on suppliers of goods sold for resale at Visitors Centres in Belgium and France and via online channels. This works toward ethical sourcing and compliance with local legislative requirements with particular focus on items of high risk such as food/drink, clothing and toys.
8. Monitoring, Reporting and Effectiveness
8.1. Compliance with our Modern Slavery and Fair Treatment at Work Policies and Processes is monitored through:
8.1.1. The quarterly update and review of Risk Registers (at Corporate and Local level),
8.1.2. The provision of an Ethical Compliance update to senior management on a quarterly basis as part of our quarterly management meeting,
8.1.3. Engagement with Area and Functional Management,
8.1.4. The completion of ethical compliance reviews and site inspections by the Head of Ethical Compliance; and
8.1.5. The management and monitoring of Speaking Up reporting.
8.2. During 2025/26 we invested in a third-party horizon scanning tool to enable early identification of new and emerging legislation (including as relates to Modern Slavery).
9. Looking Ahead
9.1. During our financial year 26/27 we will continue to maintain our organisational focus on preventing Modern Slavery and we will:
9.1.1. Build on our accommodation assurance work,
9.1.2. Continue to keep visible the possibility of modern slavery in our organisation and operations and of the requirement to always speak up where concerns are identified,
9.1.3. Review of our Modern Slavery Policy and training materials (which will include a review of our Modern Slavery Awareness module to ensure accessibility to all relevant colleagues),
9.1.4. Continuing to develop our understanding of risk by mapping suppliers against recognised external risk indices (such as prevalence and vulnerability indicators by country), alongside improved internal data derived from procurement, due diligence and monitoring activity; and
9.1.5. Embed horizon scanning into Area/Functions.
10. Approval
10.1. This statement constitutes our Modern Slavery and Human Trafficking Statement, for the financial year ending 31 March 2026.
Claire Horton CBE
Director General
COMMONWEALTH WAR GRAVES COMMISSION