Modern Slavery and Human Trafficking Statement

1. S 54 of the Modern Slavery Act 2015 (“the Modern Slavery Act“) requires certain large organisations to develop a Modern Slavery and Human Trafficking Statement each year detailing the steps which the organisation has taken to ensure that modern slavery is not taking place within its business or supply chains. The National Gallery is not an organisation which is required to comply with s 54 of the Modern Slavery Act, but welcomes the opportunity to state its policy regarding modern slavery.
2. Modern slavery is both a crime and violation of human rights, and may take the form of actual slavery, enforced servitude, forced and compulsory labour and human trafficking. The National Gallery is committed to acting ethically and with integrity and transparency in its business dealings and relationships and to putting in place effective systems and controls to guard against modern slavery taking place within its own business or its supply chains. To this end, the Gallery has adopted an Anti-Slavery Policy.
3. The Gallery’s supply chains include those companies providing goods or security, cleaning, maintenance, IS and building services to the Gallery. The Gallery would also regard those companies which are licenced to run the shops, catering outlets or other public facilities within the Gallery (“concessionaires“) as forming part of its supply chains.
4. The Gallery in 2017 introduced wording into its standard terms with suppliers of goods and services requiring contractors and suppliers to comply with all applicable laws in respect of modern slavery and human-trafficking; to either comply with the Gallery’s Anti-Slavery Policy, or have in place its own policies in relation to modern slavery and human trafficking; not to engage in any activity which would give rise to an offence under sections 1, 2 or 4 of the Modern Slavery Act 2015, if such activity, practice or conduct were carried out in the UK; and to make the same requirements of its own sub-contractors.
5. The Gallery works closely with the National Gallery Company Ltd (the concessionaire which runs the shops and oversees the running of the restaurants in the Gallery) to ensure a similar approach to due diligence is taken by the Company to that taken by the Gallery.
6. Dissemination of the Gallery’s Anti-Slavery Policy within the organisation has taken place through Heads of Department and the Policy is available to all staff. New staff are made aware of the Policy through the Gallery’s on-boarding process.

   Review of Progress

7. During 2020/2021 all suppliers responding to contract opportunities over £50,000 were required to provide information on their own Modern Slavery policy or to confirm compliance with the Gallery’s policy. No supplier failed this requirement, and the Gallery has not been required to exclude any supplier on this basis.
8. Due to the COVID-19 lockdowns, it was not a priority to develop or roll-out a comprehensive training program for the staff. The Procurement and Contracts Manager carried out appropriate learning activities. The Gallery’s training provider has an e-learning module covering modern slavery and associated issues, and the incorporation of this into the mandatory training requirements of staff will be investigated during 2021/2022.
9. Due to COVID-19 and the associated office shut down, the Gallery did not carry out the tender for the employee staff caterer. This tender will be carried out in 2021/2022.

   Goals for Further Development

10. The Gallery anticipates tendering for a high-risk contract – staff catering provision – and will ensure that the contract management processes specify requirements for the caterer to monitor its food sourcing chains for modern slavery risks.
11. The Gallery will be tendering for a high-risk contract – employee catering provision – and will ensure that the contract management processes specify requirements for the caterer to monitor its food sourcing chains for modern slavery risks.
12. Propose mandatory training in modern slavery for all staff.

Director of the National Gallery