This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that RNIB has taken and is continuing to take to ensure modern slavery or human trafficking is not taking place within our operations and supply chain during the financial year ending 31 March 2019.
The statement applies to RNIB and the following subsidiary organisations:
- Action for Blind People
- Blind Centre for Northern Ireland (BCNI)
- Cardiff Institute for the Blind (CIB)
- Glynn Vivian Home of Rest for the Blind
- MPH Accessible Media Limited
- National Library for the Blind (NLB)
- RNIB Business Services LLP
- RNIB Charity
- RNIB Direct Services Lottery Limited
- RNIB Enterprises Limited
- RNIB Feel Good Friday Lottery Limited
- RNIB Specialist Learning Trust
- Talking Newspaper Association of the United Kingdom
RNIB acknowledges its duty to notify the Secretary of State of any individual encountered in England and Wales who it believes is a suspected victim of slavery or human trafficking.
RNIB is committed to respect human rights as laid out in the International Bill of Human Rights and the UK Modern Slavery Act 2015. RNIB has a zero-tolerance approach to Modern Slavery of any kind within our operations and supply chain. We will not appoint or work with any supplier who cannot demonstrate the same high level of commitment to this Act that RNIB applies, and we fully support the investigation and reporting of any supplier found to be in breach of our policy and approach to anti-slavery and human trafficking.
Organisational structure and supply chains
As one of the UK’s leading sight loss charities and the largest community of blind and partially sighted people, employing c.1800 people, and supported by c.5000 volunteers we provide support and advice to blind and partially sighted people in the UK. With income of around £120 million, we provide a wide range of diverse goods and services sourced through our global supply chain. RNIB fully supports the Modern Slavery Act and takes its role seriously in ensuring that its supply chain is assessed and thoroughly checked to ensure compliance.
We aim to procure under the Code of Ethics of the Chartered Institute of Purchasing and Supply. Suppliers of goods and services to RNIB must comply with legislation, regulation and standards relating to the relevant industry, including for example, child and forced labour, health and safety of workers, non-discrimination, employment law, human rights, fraud, bribery and corruption. We ask all our suppliers to adhere to our Modern Slavery and Human Trafficking policy and our Supplier Code of Conduct.
If we find evidence of a failure to comply with our policies, or a breach of the Supplier Code of Conduct, we will in the first instance try to work with them to improve standards and employee welfare. However, we reserve the right to terminate an arrangement with any supplier immediately for appropriate transgressions or where there is no willingness to make the necessary improvements.
As part of our risk-based approach to achieving compliance with the Modern Slavery Act, RNIB undertakes due diligence when considering taking on new every day and preferred suppliers and commits to regularly reviewing existing relationships. The organisation’s due diligence includes:
- Reviewing every day suppliers to assess and monitor product, sector or geographical risks of modern slavery and human trafficking.
- Ensuring any new every day or preferred suppliers / contractors provide confirmation of their compliance with the Act.
- Promoting and educating compliance of the Act through our procurement policy and associated procedures.
- Reviewing our supply chain as a regular component of risk assessment and management to ensure that continued compliance is achieved.
- Ensuring contracts agreed with our suppliers reflect agreement and compliance with the Act.
- Taking appropriate reporting steps if we suspect any evidence of slavery or human trafficking has arisen in our supply chain.
Relevant policies and practices
RNIB has in place the following policies and procedures that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:
- Modern-Slavery and Human Trafficking policy - reiterating our stance against all forms of modern slavery, the policy outlines procedures and processes which are designed to guard against the occurrence of modern slavery or human trafficking in our business operations and supply chain.
- Supplier code of conduct and internal procedures to ensure these are applied to our everyday procurement activities – Wherever possible RNIB insists on ethical standards from all suppliers. Suppliers are required to confirm that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
- Procurement policy - outlines due process for the procurement of goods and services. A Questionnaire is used to assess whether an organisation satisfies minimum levels of economic and financial standing and technical and professional capability.
- Whistle blowing policy - encourages RNIB’s representatives (staff, volunteers, trustees) to raise any concerns related to the direct activities, or the supply chains of, the organisation without fear of reprisals. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
- Safeguarding policy - ensures people accessing RNIB’s services are not harmed in any way through the organisations actions. The policy promotes an understanding and awareness of safeguarding with customers (or their representatives, parents, carers) and RNIB’s representatives and covers the process for raising concerns about possible abuse or neglect by a staff member, volunteer or any other person.
- Recruitment policy and procedure – Where external agencies are used to support recruitment RNIB will only engage with recruitment agencies which share our commitment towards anti-slavery and the prevention of human trafficking.
RNIB representatives are required to familiarise themselves with this statement, our supplier code of conduct and our Modern Slavery and Human Trafficking policy. Specific training on eradicating slave labour or human trafficking is available, on request, to relevant members of staff. Any queries or questions must be directed to the procurement team who will be happy to assist.
Our approach for continued improvement
- Managed review of internal procurement policies, procedures and guidelines that reinforce and compliment this statement.
- Chartered Institute of Procurement and Supply professionals supported to achieve Chartered Status and complete annual professional development in ethics and modern slavery.
- Risk categorisation on our preferred suppliers and planned audits with significant spend strategic vendors.
- Further develop our risk methodology for modern slavery with external/internal auditors.
- Review and improve our tracking and monitoring of supplier assessments using new procurement technology.
- Introduction of new Terms and Conditions in 2020 to incorporate termination for breaching any aspect of our Supplier Code of Conduct.
This statement has been approved by the RNIB Board who will ensure it is reviewed and updated annually.
Chief Executive, RNIB
Date: 13 February 2020