Modern slavery statement 2020-21

As the largest Welsh Government Sponsored Body, we hold ourselves to the highest standards of ethical conduct in all our activities and are committed to continuous improvement. NRW does not engage in, or condone, the practices of human trafficking, slavery or enforced labour.

Our values are at the heart of who we are as an organisation. They outline what is important to us, what we are like as people and what we are here to do:

  • we are passionate about the natural environment of Wales
  • we care for each other and the people we work with
  • we act with integrity
  • we make a difference now and for the future
  • we are proud to serve the people of Wales

We are committed to improving our business practices to combat modern slavery and human trafficking and to ensure that we are not complicit in any human rights violations. We are committed to zero tolerance of slavery, human trafficking and child labour practices.


For the purposes of this statement we have adopted the following definitions:

  • 'Slavery' is where ownership is exercised over a person. Someone is in slavery if they are:

    • forced to work through mental or physical threat

    • owned or controlled by an 'employer', usually through mental or physical abuse or the threat of abuse

    • dehumanised, treated as a commodity or bought and sold as ‘property’

    • physically constrained or have restrictions placed on their freedom.

  • 'Servitude' involves the obligation to provide services imposed by coercion.

  • 'Forced or compulsory labour' involves work or service extracted from any person under the menace of a penalty and for which the person has not offered themselves voluntarily.

  • 'Human trafficking' concerns arranging or facilitating the travel of another with a view to exploiting them.

This statement will be published in the Transparency in Supply Chains (TISC) register on the the TISC webpage

Our Supply Chains

NRW’s supply chains predominantly fall within the following categories:

  • Civil Engineering
  • Fleet & Facilities
  • ICT equipment and services
  • Professional services
  • Land Management
  • Hydrometry & Telemetry
  • Forest Operations

NRW has many existing contracts and frameworks for specific categories of expenditure. The National Procurement Service (NPS) is a central purchasing body whose role is to set up contracts and framework agreements for use by the Welsh Public Sector. We also utilise the Crown Commercial Service (CCS) and Eastern Shires Purchasing Order (ESPO) frameworks where appropriate. Decisions on whether to purchase from a suitable NRW contract or framework agreement are made by the Procurement Lead or Category Lead.

We honour the Living Wage for all our employees, full time or part time.

Our policies

We are committed to making sure that there is no modern slavery or human trafficking in our supply chain or in any part of our business. We continue to develop our policies and procedures to reflect our commitment to acting sustainably, ethically and with integrity in all out business relationsips.

We aim to develop, implement and enforce effective systems, processes and controls to ensure that no child labour, slavery or human trafficking is taking place linked to our activities. This is a significant undertaking and will cover many areas of NRW’s business.

NRW mitigates the risk of modern slavery occurring in its workforce by ensuring that directly employed staff are recruited via robust HR recruitment policies. There is a whistle-blowing policy in place for members of staff to raise any concerns about wrongdoing as well as guidance for staff experiencing domestic abuse. Staff employed on a temporary basis are, where possible, recruited through NRW’s approved suppliers Pertemps and Hays.

Our future commitments

This is NRW’s first Modern Slavery statement. It provides a benchmark for us to build on and develop in the future, and we will review our progress and statement annually at the end of each financial and operational year.

Over the 2020-21 operational year we will facilitate a discussion across the organisation about the Modern Slavery Act (2015) with a view to developing a more detailed plan and priorities for the following year. Specific activities that we commit to in 2020-21 are:

  • We will sign up to the Welsh Government’s ‘Code of Practice for Ethical Employment in Supply Chains’ and adopt a holistic approach aimed at tackling blacklisting, false self-employment, unfair use of umbrella schemes and non-guaranteed hours (zero hours) contracts and paying the real Living Wage, in addition to Modern Slavery and human rights abuses.

  • We will carry out an assessment in the areas of Procurement, Commercial, Leases, Human Resources and Facilities & Fleet Services to review our current compliance with the commitments in the Code of Practice.

  • We will initiate discussions across the organisation to identify other areas of the business that could potentially be affected by issues related to Modern Slavery.

  • Once these assessments and discussions have concluded, we will prioritise the commitments according to NRW’s current position and develop an action plan with timescales to set out the activities and actions that we will undertake to implement each commitment.

  • We will appoint an Anti-Slavery and Ethical Employment Champion.

  • We will ensure that our whistle-blowing mechanism also allows for people outside our organisation to raise suspicions of unlawful and unethical employment practices.

  • We will incorporate consideration of the Modern Slavery Act (2015) into the development and review process for all our corporate policies and procedures.

  • We will investigate what training opportunities exist in this area and might be appropriate for NRW staff.

This statement will be reviewed annually and has been approved by the Board.

Signed by:Clare Pillman, Chief Executive of Natural Resources Wales 

Dated: 21.05.20

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