This statement is designed to satisfy the requirements of Section 54 of the Modern Slavery Act 2015 (“Act”), by setting out the approach of the British Council to modern slavery, human trafficking, forced labour and labour rights violations in its supply chains.
We continue to take our responsibility to prevent modern slavery and trafficking within our supply chain seriously.
Our status, operations and supply chain
• The British Council is registered as a charity under registration numbers 209131 (England and Wales) and SC037733 (Scotland), and is incorporated by Royal Charter.
• We work in over 100 countries, connecting millions of people with the United Kingdom through programmes and services in the English language, the arts and education.
• This statement relates to the British Council and its subsidiary entities.
• The British Council has a diverse and substantial supply chain, with procurement carried out both centrally and within local markets across the globe and is guided by its corporate policies.
Current Procurement policy and processes
• The British Council follows UK public sector procurement legislation and ensures that all potential and incumbent suppliers are dealt with professionally, fairly and ethically and that we uphold the principles of sustainable procurement at all times. Our procedures also comply with UK law and address environmental management, health and safety and equality legislation.
• Suppliers are evaluated on criteria including their approach to risk; environmental sustainability; health and safety; modern slavery and safeguarding.
• We require our suppliers to maintain their standards while supplying us. We have a variety of channels both internally and externally facing which facilitate the raising of concerns over supplier behaviour.
Identifying and Managing Risk
• With over 60,000 global suppliers, delivering a wide range of goods and services, we use a structured approach to ensure that the high-risk categories and countries are identified, and that relevant and proportionate due diligence is carried out to ensure that risk can be identified and appropriately managed.
• British Council has used publicly available international data on modern slavery and analysed spend to identify our highest risk categories of spend as defined below.
- Hotels, venues and events services;
- Building operations (including security, cleaning, catering, maintenance, gardening); and
- Temporary labour providers.
• As part of the British Council’s due diligence process, the supplier approval process will incorporate a review of controls undertaken by the supplier.
Managing Risk and Adherence to the Act
• Our standard supplier contract and grant agreements include modern slavery and human trafficking undertakings. We expect our supply chain to respect and comply with all applicable laws, including the Act, and under our standard contracts and grants, the British Council reserves the right to terminate its arrangements with a supplier which is found to be in breach of the Act.
Social responsibility and human rights
• The British Council is committed to respect for human rights and to acting in a socially responsible manner in our operations and programming. We are current members of the United Nations Global Compact. All our work seeks to support and respect the protection of internationally proclaimed human rights and to ensure that our staff, offices and supply chains are not complicit in human rights abuses.
• As part of our commitment to the Foreign Commonwealth and Development Office Code of Conduct and our determination to address this issue of global importance, we are exploring joining the Ethical Trading Initiative.
• We recognise the importance of ensuring all of our staff understand how modern slavery manifests itself and how to report when it does. This is especially relevant to the British Council, given that we are operating in many diverse and multifaceted contexts.
• We plan to deliver a modern slavery awareness raising training package to staff by November 2021.
• To build capacity within our supply chain, by November 2021 we will publish the awareness raising / training content so we can direct high risk suppliers to it.
Key performance indicators (KPIs)
• By end of March 2022, the British Council will be in a position to report on the following:
- percentage of suppliers falling into the high-risk categories (see Identifying and Managing Risk section above) to have completed modern slavery questionnaires at evaluation stage; and
- numbers of staff globally who have accessed our new modern slavery awareness raising digital training package.
• The British Council is committed to continuous improvement in this area and will review and monitor and, where necessary, enhance our standards, policies and procedures, as well as improve the training and communications about the Act
• This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. The statement has been approved by the Board of Trustees of the British Council on 17 September 2021 and signed on its behalf by the Chairman, Stevie Spring.