In accordance with section 54, part 6 of the Modern Slavery Act 2015 (the Act), this statement sets out the steps that the Fundraising Regulator has taken to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our business. This statement relates to our financial year ending August 2022 and was approved by the senior management team in September 2022.
Overview
The Act requires commercial organisations supplying goods or services with a turnover of more than £36 million to prepare and publish an annual slavery and human trafficking statement. The statement must set out the steps an organisation has taken, if any, during its financial year to ensure that slavery or human trafficking is not taking place in its business or supply chain. Although our turnover is c. £2.4 million in 2022, and nowhere near £36 million, we believe it is important for the regulator, given its position of influence, to be seen to be actively complying with the rules.
What is modern slavery?
Modern slavery is an international crime, affecting millions of people around the world – a growing global issue that transcends age, gender and ethnicities. Sadly, vulnerable people from overseas as well as across the UK, are forced to work illegally against their will across many different sectors from agriculture, construction, hospitality, retail, manufacturing and more.
Our organisation structure and supply chains
The Fundraising Regulator is a private company limited by guarantee, incorporated in England and Wales. It is the voluntary regulator for charitable fundraising and has over 5,000 fundraising bodies registered and signed up to the Code of Fundraising Practice.
Our business largely uses professionally qualified people employed directly by the regulator. Our HR policies ensure fair recruitment and treatment of our people across the UK. Our external suppliers are mostly UK based companies in low-risk sectors (such as professional services) as well as suppliers in the events and travel sector, which are potentially higher risk.
Our policies in relation to slavery and human trafficking
The Fundraising Regulator has established a zero-tolerance position on violations to the UK’s anti-human trafficking and anti-modern slavery laws. If we find breaches of these laws within our supply chain, we will look to support companies in their efforts to comply with the legislation.
Our internal values of collaborative, learning, quality and supportive are the pillars of our culture. They embody everything that we do at the Fundraising Regulator and how we do business. They outline the expectation of our people’s behaviour with colleagues, registrants and suppliers.
We seek to treat everyone fairly and consistently, creating a workplace and business environment that is open, transparent and trusted. Our policies and procedures relating to the Modern Slavery Act are in line with our culture and values.
Any staff member with concerns about modern slavery should raise concerns with their line manager. Anyone external who has concerns about modern slavery should raise them through our complain about us function.
Our specific procedures to address the risk of modern slavery include:
- comprehensive employment policies that protect our people from unfair treatment and promote a fair and inclusive workplace
- a Board led strategy that promotes equality, diversity and inclusion
- a process for handling complaints raised by people outside of the regulator
- robust recruitment processes in line with relevant employment laws
- market-related pay and rewards, reviewed annually
- wellbeing initiatives to support our people’s physical and mental wellbeing and lifestyle choice; and
- a procurement policy for how we deal with suppliers, making clear the standards we expect.
Due diligence processes, risk assessment and management
When we implement our policies and procedures, we include due diligence on suppliers that we engage with, in line with our procurement policy. A heightened risk area is the use of hotel and conference facilities. To mitigate against this risk, we assess the companies that we deal with as part of the decision-making process for events and travel.
When we contract with a new supplier, a thorough due diligence process takes place to ensure that the firm has a good reputation with appropriate practices in a number of areas, including people and culture.
Key performance indicators to measure effectiveness of steps being taken
We log complaints received together with the actions taken. To the date of this statement, the Fundraising Regulator has had no identified instances of modern slavery.
Awareness raising on modern slavery and trafficking
The Fundraising Regulator provides periodic awareness sessions to its staff on modern slavery through its all-staff team meetings. The Fundraising Regulator takes responsibility for this statement and its related objectives and will review and update it in accordance with the Act.
This policy was first updated in September 2022 and will be reviewed twice a year.