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Modern Slavery and Human Trafficking Statement

Financial Year April 2024 – March 2025

Introduction

The National Gallery was established by Parliament in 1824 for the benefit of the public. It houses a uniquely important collection of some 2,400 pictures which tell a coherent story of European art spanning seven centuries, from Cimabue to Degas. The Board of Trustees of the National Gallery holds the pictures in trust on behalf of the nation. The Gallery’s objectives are to preserve the collection by maintaining the highest standards of care and conservation, to enhance the collection by acquiring great pictures and to display it in a sensitive manner for the enjoyment and understanding of the public. The Gallery undertakes high-level research that it publishes through a variety of media and as a national and international leader in its field it works in partnership with museums and academic institutions in the UK and overseas. The Gallery aims to engage the widest possible audience in the experience of its collection by opening free of charge every day to everyone, by lending some of its works to temporary exhibitions, through special public programmes and by digital means. It aims to be a resource on art for the whole world to inspire present and future generations.

National Gallery Global Limited is a commercial company which contributes financially to the National Gallery. It is owned by the National Gallery. Its business activities are broad ranging and include the following activities:

  • Retail operations in the National Gallery
  • The National Gallery online shop
  • The National Gallery Picture Library
  • Publishing books, developing and sourcing merchandise based on the National Gallery Collection and exhibitions
  • Licensing the National Gallery spaces for commercial event hire or filming
  • Developing global brand partnerships with licensees or other retailers
  • Managing commercial contracts with specialist restaurant and café operators.

As a publicly funded, high profile organisation, the Gallery recognises that it has a responsibility to take a robust approach to modern slavery, human trafficking, forced and bonded labour, and labour rights violations.

The Gallery is absolutely committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains are free from slavery and human trafficking.

This statement sets out the actions of The National Gallery group to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2024 to 31 March 2025.

Organisational structure and supply chains

This statement covers the activities of The National Gallery and its trading arm, National Gallery Global Ltd.

Countries of operation and supply
The Gallery operates in the United Kingdom and puts on collaborative exhibitions with international peer organisations. National Gallery Global Limited operates shops within the Gallery as well as ecommerce sales around the world.

The supply chain for the group is predominantly based in the UK, but does include worldwide sourcing and tier two suppliers, including countries in Europe and the USA, India, China, Taiwan, Türkiye, Indonesia, South Korea, and the Philippines.

The Gallery has on-going relationships with stakeholders across the globe. High risk areas are subject to scrutiny by the Board of Trustees and the Audit Committee, supported by Internal Audit. A supply chain risk assessment has been conducted on areas identified, by nature, as of specific potential risk regarding the Act, namely the Gallery’s merchandise and personnel suppliers, and those located overseas. The assessment indicated the Gallery’s suppliers in these three areas to be of low risk. Notwithstanding this, written confirmation of compliance with the Act is requested, and received, from all suppliers with whom the Gallery has an ongoing relationship.

High-risk activities
The following activities are considered to be at high risk of slavery or human trafficking:

  • Construction activities
  • Facilities management services (such as security and cleaning)
  • Garment or textile production
  • Electronics
  • Catering and hospitality services

Relevant policies

The Gallery operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Procurement policy: The Gallery is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The Gallery works with suppliers to ensure that they meet expectations and improve their worker's working conditions. However, serious failures of conduct will lead to the termination of the business relationship. 

    All contracts let by the Gallery require suppliers to have their own Modern Slavery policy or to comply with the Gallery’s policy as well as contractual requirement to comply with the Modern Slavery act. The Gallery makes use of frameworks managed by bodies (such as the Crown Commercial Service and the London Universities Purchasing Consortium) that require suppliers to respect ethical standards (such as the Base Code of the Ethical Trading Initiative) when engaging with international supply chains, and which identify and audit supply chains which represent a medium- to high-risk of modern slavery.

  • Whistleblowing policy: The Gallery encourages all its workforce, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The Gallery's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.

  • Employee code of conduct: The Gallery's code makes clear to employees the actions and behaviour expected of them when representing the Gallery. The Gallery strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.

  • Selection and Recruitment policy: The Gallery has a clear process for recruitment of directly employed staff, and uses only specified, reputable employment agencies to source temporary labour and always verifies the practices of any new agency it is using before accepting workers from that agency. All staff are required to undergo Baseline Personnel Security Standard (BPSS) which includes checks of identity, nationality and immigration status, employment history (including a 3-year career gap analysis), and unspent criminal convictions to ensure an individual’s suitability.

Due diligence 

The Gallery undertakes due diligence when considering taking on new suppliers and regularly reviews its existing suppliers. The Gallery's due diligence and reviews include:

  • evaluating the modern slavery and human trafficking risks of each new supplier;
  • conducting supplier audits or assessments, which have a greater degree of focus on slavery and human trafficking where general risks are identified;
  • taking steps to improve substandard suppliers' practices, including providing advice to suppliers and requiring them to implement action plans;
  • invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

Training

The Gallery requires procurement staff to undergo training and maintain awareness of modern slavery risks, such as the Chartered Institute of Procurement and Supply’s Ethical Procurement and Supply course. Procurement staff provide training to contract managers with responsibility for medium- and high-risk contracts. 

Performance indicators 

The Gallery: 

  • requires procurement professionals to have completed training, or refresher training on modern slavery by 31 December 2025;
  • will review its top five medium- or high-risk contracts or supply chain area for supplier compliance with modern slavery policy, to be completed by 31 March 2026; and
  • will develop a Supplier code of conduct by 31 March 2026, to clearly set out the Gallery’s expectations that its suppliers adhere to the highest standards of ethics. 

Executive approval 

This statement has been approved by the Gallery’s Executive Committee, who will review and update it annually.

 

Gabriele Finaldi 
Director of the National Gallery
23 July 2025