This is UNISON’s second statement, made under section 54 of the Modern Slavery Act 2015 for the financial year ending 31st December 2017.
UNISON recognises the transparency in supply chains (TISC) requirement as a positive step in identifying and addressing the issues of modern slavery and human trafficking. To drive improvements and change we seek to collaborate and learn from others in this area.
This statement is an update on progress made since the union’s first statement.
UNISON’s structure, business and supply chains
UNISON has over 1,200 employees and an annual turnover in excess of £36m. UNISON operates as a trade union to represent workers providing public services. The union is organised nationally, regionally and at branch level. UNISON’s head office is in London and there are 32 regional offices and over 800 branches. UNISON is a complex organisation with a wide range of third party suppliers.
As a trade union, UNISON is concerned with working conditions and employment rights of its 1.3m members, working people in the UK and workers’ rights globally.
The union’s third party supply chains include goods and services for the effective running of the organisation as well as the provision of affiliated services for our members.
UNISON procures services and goods from third party providers predominantly based within the UK or EU.
UNISON slavery and human trafficking policies
UNISON is committed to ensuring there is no slavery or human trafficking within any part of its business or its supply chains. The union strives to achieve this through its recruitment policies and procedures and supplier due diligence processes. For our third party suppliers we aim to focus on high risk industries in this area and collaborate with others to concentrate our resources and increase our leverage with brands.
UNISON’s Procurement Policy (last updated in 2016) reflects the union’s commitment to act ethically.
UNISON has a Supplier Code of Conduct (updated in 2016) which sets out the Ethical Trade Initiative (ETI) Base Code as the minimum labour standards it expects from its suppliers as well as requiring compliance with the Modern Slavery Act.
ETI Base Code
- Employment is freely chosen
- Freedom of association and the right to collective bargaining are respected
- Working conditions are safe and hygienic
- Child labour shall not be used
- Living wages are paid
- Working hours are not excessive
- No discrimination is practiced
- Regular employment is provided
- No harsh or inhumane treatment is allowed
UNISON has an international policy to support workers in the global south to access their rights and campaign in support of public services. UNISON works with international human rights and labour rights’ groups, and offers support to international partners to challenge labour and human rights’ violations in countries identified as priority countries through the union’s policy. UNISON’s international policy is determined by the National Delegate Conference (NDC).
UNISON is affiliated to a number of organisations including Electronics Watch, Anti-Slavery International, Banana Link, War on Want, Labour Behind the Label (part of the Clean Clothes Campaign) and Global Justice Now.
In September 2017 UNISON added its name to the Anti-Slavery Charter. In signing the Charter, UNISON reaffirmed its commitment “to empower those vulnerable to slavery, to advance emancipation, and to promote access to decent work”.
UNISON recognises that trade unions are essential to global efforts to tackle modern slavery by representing members and campaigning for decent work.
The union provides immigration advice to its members in the UK and organises migrant workers to provide support, assistance and create a network for members that may be more vulnerable to exploitation.
As the largest public service union in the UK, UNISON is campaigning for reforms to public procurement practices, to eradicate modern slavery:
- UNISON has developed guidance and training to assist branch international officers to campaign for public service providers to develop ethical procurement policies.
- The union is supporting calls for the Transparency in Supply Chains requirement of the Modern Slavery Act to be extended to public services.
- The union is supporting calls for an ILO convention of decent work in supply chains and a United Nations binding treaty on transnational corporations.
- UNISON has commissioned research to identify best practice in ethical local government procurement.
UNISON due diligence procedures in relation to slavery and human trafficking in its business and supply chains
UNISON employs solely within the UK. Our recruitment procedures ensure that all prospective employees are legally entitled to work in the UK. All successful applicants must produce on their first day, one of the following: their passport, their driving licence or their birth certificate (original documents only, no photocopies). In addition, in order to comply with the Asylum and Immigration Act 1996 requirements, evidence of the right to reside and work in the UK, including work permits and visas, is sought from all successful applicants and checked by HR. If UNISON is in the process of applying for a work permit for a prospective member of staff they cannot legally start work until it has been received.
UNISON is an accredited Living Wage Employer. Our Living Wage accreditation ensures all direct and indirect employees are paid at least the Living Wage. UNISON carries out reasonable and practical due diligence in the sourcing of goods and services. The union’s supplier vetting process requests information from potential suppliers to assess their suitability as a supplier and provide evidence of their compliance of labour standards, the Modern Slavery Act and the Asylum and Immigration Act, as well as covering other areas of company information, policies and procedures. This enables the procurement team to identify and assess any potential risks.
Identifying, assessing and managing risk
UNISON understands that its largest exposure to modern slavery and human trafficking will come from its third party supply chains.
Key suppliers are expected to share the same values as UNISON and declare their compliance with UNISON’s Supplier Code of Conduct, which includes the Ethical Trade Initiative (ETI) Base Code as minimum labour standards.
UNISON does not permit its key suppliers to subcontract work except where prior permission has been obtained.
As contracts are renewed with key suppliers we ensure that Modern Slavery Act requirements are included within the terms and conditions of contract.
UNISON’s terms and conditions of purchase include a clause confirming UNISON’s commitment to ensuring slavery and human trafficking is not taking place. UNISON reserves the right to terminate its contracts if the supplier breaches the clause and slavery or human trafficking is found.
UNISON is committed to better understanding its third party supply chains. We have written to our key suppliers and requested that they complete a supply chain questionnaire to provide transparency and greater understanding in this area. This is assisting our work in reviewing our existing suppliers for any risks and profiling our top 100 suppliers (by annual spend), by reviewing their industry sector, location and labour practices. This will help us ensure that procurement resources can be focused on higher risk suppliers/categories to drive improvements in these sectors.
In 2017 UNISON became the first trade union to affiliate to Electronics Watch, a monitoring body for organisations that buy electronic equipment. UNISON recognises the electronics industry as a high risk area for labour and human rights abuses and by affiliating to Electronics Watch the union will work with public sector buyers to increase leverage on manufacturers and brands to drive improvements.
Staff training about slavery and human trafficking
UNISON’s central procurement team have all been trained in procurement ethics, including the issues of modern slavery and human trafficking and briefed on the requirements of the Modern Slavery Act.
Information has been circulated to all staff to raise general organisational awareness.
Summary of Progress and Improvements
Procurement team purchasing ethics training – 2015/2016
Procurement policy reviewed and updated – 2016
Supplier Code of Conduct reviewed, updated and better embedded in procurement processes – 2016
Supplier Questionnaire updated to include Modern Slavery due diligence – 2016
Information circulated to staff – 2016
UNISON terms and conditions updated to incorporate clause regarding Modern Slavery Act Compliance – 2016
UNISON signed Anti-Slavery Charter – 2017
UNISON affiliation to Electronics Watch – 2017
Key suppliers written to regarding Modern Slavery Act, UNISON’s Supplier Code of Conduct and supply chain questionnaire requested to be completed – 2017
Attended exploratory meetings with the TUC and other trade unions to share best practice, learning and possible areas for future collaboration – 2017
Risk profile top 100 Suppliers – Started 2017 and will continue in 2018
UNISON will carry on building on the work carried out to date. We will continue the conversations we’ve started; continue to engage with our third party suppliers, campaign for improvements and also seek to learn from others and explore different areas and ways of collaboration.
This statement shall be reviewed and published annually.
Josie Bird, Chair of finance & resource management committee (NEC)