Modern Slavery Statement

FOREWORD

The Money Advice Trust wishes to ensure that we do not knowingly participate with any

activity or organisation that involves any form of modern slavery.

Modern slavery is a term used to encapsulate various forms of servitude, forced or

compulsory labour and human trafficking. The Money Advice Trust and its operating

names National Debtline, Business Debtline and Wiseradviser (all referred to as

“the Trust”) are committed to conducting our business responsibly and have a zerotolerance

approach to the issue across our business and supply chain.

It is estimated that around 40 million innocent men, women and children have been

forced into various forms of modern slavery, around the world. The estimated number

of victims of modern slavery in the UK has markedly increased in recent years to

approximately 136,000 individuals (2018 Global Slavery Index). This has been estimated

to generate £116bn in profits each year, across the world. A third of this is generated in

developed countries, including the UK.

We realise that modern slavery is a complex and growing global issue that affects

millions of people around the world. The Trust is committed to ensuring its practices

combat slavery, including forced, bonded or compulsory labour and human trafficking.

We strive to ensure that modern slavery is not taking place anywhere in our own

business or in our supply chains.

This statement, pursuant to the UK Modern Slavery Act 2015 (the ‘Act’), is our first under

the Act and relates to the financial year ending 31 December 2020. We fully support

the aims of the Act and associated standards such as the UN Guiding Principles on

Business and Human Rights (UN Guiding Principles) and are committed to tackling

slavery and human trafficking wherever we can.

The following statement includes our current policies and practices and the steps we

plan to take over the coming 12 months, to further improve our commitment to meeting

the principle and the Act.

Ian Witcombe

Company Secretary

SUMMARY

The Trust is aware that by producing this statement on modern slavery, we are

committing to ensuring our working practices and those of our partners minimise the

impact our business activities to help combat modern slavery in the UK.

This first modern slavery statement is the first step in helping to set out the Trust’s

pathway to achieving this within all our services and activities.

The preparation work we have completed within our policies, procedures and practices

so far has seen changes made to the following areas:

Anti-corruption and Bribery Policy • Code of Conduct • Recruitment and selection • Right to work Procedures • Safeguarding Policy • Whistleblowing Policy

In reviewing these polices and processes we were able to ensure that the processes

relating to each of these polices, minimised the risk of the Trust breaching the Modern

Slavery Act (2015) principles.

The Trust is aware that there are areas it can further improve to reduce the risk of

breaching the Acts principles. The main areas we are now working on are.

Creating a supply chain mapping process, to identified risks within this and with

our suppliers, • Update and improve our procurement process, to ensure that we are assessing

the risk posed by procuring services and supplies, • Due diligence audit to assess the risk associated with procurement and

contracts for services and supplies, • In doing the above we will aim to create a risk assessment process to monitor

and track all areas of risk and give them a risk rating that can be used as part of

the procurement or contract decision making process, • Improved contracting process, to build in modern slavery conditions and ensure

the Trust can terminate, or amend the contract if modern slavery breaches are

identified that significantly increase our risk and exposure to being linked with

modern slavery practices, • To create and provide training programmes to raise awareness and

requirements for all staff, ensuring the risk to the Trust is minimised, in relation to

modern slavery.

The plan for the next 12 months is outlined in the full statement, with the main aims

being to train all staff and put process and practices in to place to reduce the impact of

our future activities being associated with breaches of the modern slavery principles

through procurement and contracting.

INTRODUCTION

The term “modern slavery” refers to the offences of human trafficking, slavery,

servitude, and forced or compulsory labour. This can then be considered under five

headings:

The sexual exploitation of adults • The trafficking of adults into conditions of labour exploitation • The trafficking of adults into conditions of criminal exploitation • The trafficking of minors into conditions of sexual, criminal or labour exploitation • Other forms of exploitation

Human trafficking involves the recruitment, transfer or obtaining of an individual

through coercion, abduction, fraud or force, to exploit them. Although human trafficking

often involves an international cross-border element, it is also possible to be a victim

of modern slavery within our own country. There are several broad categories of

exploitation linked to human trafficking including sexual exploitation, forced labour,

domestic servitude, organ harvesting, child related crimes, forced marriage and illegal

adoption.

Modern slavery includes victims who have been brought from overseas and vulnerable

people in the UK who are forces to work illegally against their will across many different

sectors.

This statement sets out the Trust’s actions to understand all potential modern slavery

risks related to our business interests and to put in place steps that are aimed at

ensuring that there is no slavery or human trafficking in any part of the Trust or its supply

chains. This statement relates to actions and activities during the financial year 1 January

2020 to 31 December 2020.

We will endeavour to publish our annual statements before the 30 June each year.

This is designed to follow our annual report (and any other annual publications we need

to make available on our website each year).

As part of money advice sector, we recognise that we have a responsibility to take a

robust approach to slavery and human trafficking. The Trust is absolutely committed to

preventing slavery and human trafficking in its corporate activities, and to ensure that

our supply chains are free from slavery and human trafficking.

THE TRUST’S

Vision

People across the UK tackle their debts and manage their money with confidence

Mission

Supporting people and small businesses to deal with their debt, training the free advice

sector to help them, and improving the UK’s money and debt environment

Values

Be balanced, Be supportive, Be innovative

THE TRUST’S STRUCTURE

The Trust works to help people across the UK to tackle their debts and manage their

money with confidence. We do this by providing telephone and web-based debt advice

through National Debtline and Business Debtline to support people and small businesses

to deal with their debt. We also train debt advisers in the free advice sector through

Wiseradviser, and campaign to improve the UK’s money and debt environment. Our

expert advice services are available in England, Wales, Scotland and Northern Ireland,

This activity supports our charitable objectives which are the relief of poverty including,

but not limited to, that arising from indebtedness and the advancement of public

education in all matters relating to the management of personal finances. The Board has

developed strategic plans to ensure that the Trust provides public benefit and achieves

its aims as set out in its governing document. The Board confirms that it has complied

with the duty in section 17 of the Charities Act 2011 to have due regard to public benefit

guidance published by the Charity Commission in determining its activities.

Our policies and procedures are designed to ensure that ethical behaviour forms

the basis of our ways of working. We ensure all staff are trained in safeguarding,

which includes being aware of what modern slavery is and how it can happen. We

will continue our programme to update all relevant policies to include appropriate

references to the risk of modern slavery. We also operate numerous risk controls to

protect staff and clients’ personal information, and to ensure that our systems and

services are not used to perpetrate or facilitate crime, including modern slavery.

We have circa 260 staff. The Trust carries out appropriate pre-employment checks prior

to commencement and staff complete mandatory training to ensure they understand

and comply with our values and policies. Appropriate references to modern slavery are

incorporated into relevant aspects of our recruitment processes and training. We are a

Living wage foundation recognised employer, with all our staff receiving at least a real

living wage.

OUR SUPPLY CHAIN

The Trust uses a wide range of suppliers to conduct its business, with the majority of

these being from within the UK. They supply a wider range of services and goods to

ensure that we can continue to deliver our services to our clients.

The Trust recognises the importance of its role in implementing the guidance of the

Modern Slavery Act. Those involved in procurement are aware of the risk of modern

slavery specifically, and our Financial Procedures on procurement and tendering, set out

our requirement for buying goods, services and sets out the due diligence required to

be completed on suppliers. The Trust’s code of conduct and whistleblowing polices are

designed to encourage staff to report any concerns.

An ethical procurement and tendering process will be developed in the coming year

building on the existing process and will include a specific section on risk of modern

slavery in our supply chain. The ethical procurement and tendering process will be used

to further draw the attention of our people to the risk relating to modern slavery and child

and forced labour, ensuring that they have access to the necessary information and most

importantly how they can report any concerns they have.

RESPONSIBILITIES

Responsibility for our anti-slavery initiatives is as follows:

Policies: Each department has been allocated responsibility for ensuring that

all policies, within their specialisms, are up to date with the latest legislation

and good practice. These policies are reviewed and signed off by the

appropriate executive committee and in appropriate cases signed off by the

Board and consulted about with our Trade Union Representatives, before being

implemented. All polices are developed and reviewed in-line with good practice

and the Trust’s Values, which are ‘Be Balanced’, Be Supportive, Be Innovative.

Risk assessments: We are currently developing a process for supply chain

mapping and creating a human rights risk assessment.

Investigations: All suspected breaches of the Modern Slavery Act are reported

to Head of Risk and Compliance, who would arrange further investigation and

if appropriate share this with the relevant external authority, to take further action.

Due diligence: The Trust carries out due diligence on all new suppliers and

contracts. This process is outlined in the Trust’s Financial Procedure policy and

Guide to Entering a Contract document. These checks are carried out by our

Finance Manager and the individual who is responsible for signing the contract

or agreement.

Training: We are currently developing training for staff who are involved

in agreeing contracts and procuring new suppliers, this includes a section

on our Code of Conduct, and we are building capacity across key staff to

enhance supplier engagement regarding human rights. Additional training and

engagement activities will be developed as appropriate as we continue to

advance our human rights and modern slavery program.

POLICIES

The Trust’s staff have access to the following polices, which are reviewed on an annual

cyclical programme.

Recruitment Policy
Code of Conduct
Whistleblowing Policy
Anti-corruption Policy
Financial Procedures (including procurement procedures)
Guide to Entering into Contracts
Safeguarding Policy
Environmental Policy

Through these policies and the measures below we aim to prevent modern slavery

occurring at the Trust or in our supply chains:

All staff have undertaken mandatory training in safeguarding which covers

modern slavery.

Staff are aware of how to report incidents of concern and are encouraged to

do so. They can do this through their managers or through our whistleblowing

procedure.

Safeguarding incidents are reported to the safeguarding panel.
An appropriate procurement process is in place to satisfy ourselves all suppliers

meet our policies and procedures.

Pre-employment checking to minimise the risk of modern slavery within our

recruitment process.

FUTURE ACTIONS

Due diligence

We undertake due diligence when considering using new suppliers, and regularly

review existing suppliers. We aim to incorporate the following into our due diligence

process:

mapping the supply chain broadly to assess product or geographical risks of

modern slavery and human trafficking.

evaluating the modern slavery and human trafficking risks of each new supplier

[this may be part of a more general human rights or labour rights assessment].

reviewing on a regular basis all aspects of the supply chain based on the supply

chain mapping.

conducting supplier audits or assessments through our own staff and or thirdparty

auditor, which have a greater degree of focus on slavery and human

trafficking where general risks are identified.

creating an annual risk profile for each supplier.
participating in collaborative initiatives focused on human rights in general, and

slavery and human trafficking, ensuring our investments are managed ethically

and do not cause conflict with our commitment to the principles of modern

slavery.

using an ethical supplier database, where suppliers can be checked for their

labour standards, compliance in general, and modern slavery and human

trafficking.

invoking sanctions against suppliers that fail to improve their performance in

line with an action plan or for those who seriously violate our supplier code of

conduct, use the termination of the business relationship.

Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we are:

requiring all staff to have completed training on modern slavery by mid 2022;
developing a system for supply chain verification expected to be in place by mid

2022, whereby we evaluate potential suppliers before they enter the supply

chain; and

reviewing our existing supply chains expected to be completed by mid-2022,

whereby we evaluate all existing suppliers.

Training

We require staff working with new suppliers or contracts to sign up to one of a

number of training sessions that are being planned between late 2021 and early

2022.

Our modern slavery training covers:

Our organisation’s purchasing practices, which influence supply chain conditions,

and which should therefore be designed to prevent purchases at unrealistically

low prices, the use of labour engaged on unrealistically low wages or wages

below a country’s national minimum wage, or the provision of products by an

unrealistic deadline.

how to assess the risk of slavery and human trafficking in relation to various

aspects of the business, including resources and support available.

how to identify the signs of slavery and human trafficking.
what initial steps should be taken if slavery or human trafficking is suspected.
how to escalate potential slavery or human trafficking issues to the relevant

parties within our organisation.

what external help is available, for example through the Modern Slavery Helpline,

Gangmasters and Labour Abuse Authority and “Stronger together” initiative.

what messages, business incentives or guidance can be given to suppliers and

other business partners and contractors to implement anti-slavery policies; and

what steps our organisation should take if suppliers or contractors do not

implement anti-slavery policies in high-risk scenarios, including their removal

from our supply chains.

Awareness-raising programme

As well as training staff, we have raised awareness of modern slavery issues by

circulating a series of emails to staff, as well as links on our intranet pages.

These will explain to staff:

the basic principles of the Modern Slavery Act 2015;
how employers can identify and prevent slavery and human trafficking;
what employees can do to flag up potential slavery or human trafficking issues to

the relevant parties within our organisation; and

what external help is available, for example through the Modern Slavery Helpline.

TRUSTEES’ APPROVAL

This statement was approved on 23 September 2021 by our Trustees, who

review and update it annually.

Adam Sharples

Chair