Modern Slavery Statement

This document is also available in Welsh (Cymraeg). 

The National Library of Wales (“the Library”) is committed to improving our practices to combat slavery and human trafficking. We have a zero-tolerance approach to human trafficking and modern slavery.

 

Modern Slavery Statement 2023/2024

 

1. Introduction
2. Organisation Structure and Business
3. Due Dilligence 
4. Supply Chain and Procurement 
5. Safeguarding
6. People
7. Recruitment
8. Monitoring Effectiveness
9. Governance

1. Introduction

This Statement sets out the Library’s commitment to recognising and preventing slavery and human trafficking in all its business activities and within its supply chains. It outlines the steps taken to ensure compliance with the Modern Slavery Act 2015 (MSA) and minimise the risks of any association with practices which undermine the principles of safety and dignity for our users and staff, particularly with respect to people from vulnerable groups.

The most vulnerable groups in the UK include migrant workers, illegal migrants, asylum seekers and individuals, such as homeless people and people with learning disabilities. We continue to investigate and monitor how modern slavery and human trafficking may affect users, staff and our business and supply chains and ensure that we respond effectively through our policies and our actions.

This Statement covers our current position on modern slavery and activities undertaken during the financial year 2023/24. The Statement is expected to minimise the risks of slavery and human trafficking in the business and supply chains.

2. Organisation Structure and Business

The National Library of Wales, is the national legal deposit library of Wales and is one of the Welsh Government sponsored bodies. It is the biggest library in Wales, holding over 6.5 million books and periodicals, and the largest collections of archives, portraits, maps and photographic images in Wales. The Library is also home to the national collection of Welsh manuscripts, the National Screen and Sound Archive of Wales, and the most comprehensive collection of paintings and topographical prints in Wales. As the primary research library and archive in Wales and one of the largest research libraries in the United Kingdom, the National Library is a member of Research Libraries UK and the Consortium of European Research Libraries.

At the very core of the Library is the mission to collect and preserve materials related to Wales and Welsh life and those which can be utilised by the people of Wales for study and research.

The Library employs approx. 220 employees of whom 100% work in the UK (working full and part time).

The Library’s approach to being a responsible business sees the importance of:

• Responsibly managing our supply chain
• Treating users, customers, and suppliers fairly and with respect
• Allying ethical procurement with value for money

3. Due Dilligence

The Library has taken time to understand the implications of the MSA and identify the areas within our business and supply chain where the greatest risk exists. These are:

• Procurement – modern slavery can occur in a supply chain through inadequate or inappropriate procurement practices. Our supply chain consists of services and goods, with the highest risk areas being associated with our building and maintenance activity.
• Supporting user of the Library - we may also come across slavery and/or human trafficking in connection with the user of our services, particularly those from minority or socially excluded groups who may be subject to forced labour and/or domestic servitude, and potentially in connection with our workforce. 

The Library has identified the main risks in respect of these key areas and put measures in place to mitigate them. These include:

• Mandatory training for every employee involved in procurement explaining the implications of the MSA and what they should do to recognise and report potential incidences.
• Screening our procurement documentation to ensure that adequate safeguards are in place at each stage in the process i.e. soft market testing, pre-qualification questionnaires and formal tender. Our documentation already reflects our commitment to being a responsible business by incorporating requirements on social value. We have now extended this practice to all new suppliers irrespective of whether they have been through a formal procurement process or not.
• Ensuring the Library has the correct checks and balances within recruitment systems, such as eligibility to work in the UK and Disclosure and Barring Service (DBS) or Disclosure Scotland checks.

4. Supply Chain and Procurement

The Library does not have any direct supply chain outside the United Kingdom.

For major contracts, the Library operates a centralised supply chain using an approved procurement system, which requires the use of pre-approved suppliers. This means that there are more rigorous controls in place prior to expenditure being committed as well as improved visibility for retrospective checks.

5. Safeguarding

The Library’s Safeguarding Vulnerable Children, Young People and Adults Policy (updated in 2022) includes reference to modern slavery as a type or pattern of behaviour which constitutes abuse of a person at risk. The Library requires all relevant employees to complete training on safeguarding adults and children. A guide to the MSA is available to all employees on the safeguarding pages of the Library’s intranet, alongside the safeguarding policies and procedures.

6. People

Our People Policy makes explicit reference to the MSA. The policy also emphasises that The National Library of Wales is committed to dignity at work and fair treatment of all colleagues. We also have a Whistleblowing Policy and Employee Code of Conduct.

7. Recruitment

The Library’s Recruitment and Selection Policy contains relevant requirements in terms of checking eligibility to work in the UK and carrying out of necessary checks such as DBS (Disclosure and Barring Service) checks for all new staff members.

8. Monitoring Effectiveness

Whilst a wider range of performance indicators will be considered in the future, the main method of monitoring effectiveness within the supply chain will be the pre-qualification criteria for suppliers, which includes a requirement to have measures in place to minimise the possibility of modern slavery in their business and supply chain. Whether or not an organisation publishes it modern slavery statement is a standard question asked in our on boarding process as part of due diligence before any supplier is set up.

Elements of contract management which are built into performance dashboards are mindful of not creating environments where modern slavery (particularly in the shape of bonded labour) may become a way a supplier or production site tries to deal with unrealistic short time pressure and related expectations on their operations or supplying partnership.

9. Governance

Responsibility for compliance with the MSA rests at the highest level with responsibility for the Statement assigned to the Chief Executive. Specific responsibilities have been assigned to the heads of departments which are identified as key risk areas:

• Supply chain
• Vulnerable staff and users
• People Services - Volunteering

 

The Government has introduced new measures to strengthen the Modern Slavery Act 2015 and ensure that large businesses and public bodies tackle modern slavery risks in supply chains. It is now a requirement for organisations with a budget of £36 million or more in all sectors to publish their modern slavery statements on a new digital government reporting service. The National Library of Wales does not fall within this category but will consider publishing its modern slavery statement on a voluntary basis.

Chief Executive