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 has embarked on a process of due diligence in respect of existing suppliers (whose contracts were in place before the introduction of the new clauses referred to in 4 above) with a view to identifying significant contracts (valued at more than £50,000) in areas other than those identified as low risk, and writing to such suppliers to seek confirmation of their commitment to ensure compliance with the Modern Slavery Act within their own organisations, and to seek to reduce the risk of modern slavery within their own supply chains. In the region of thirty suppliers have been contacted seeking these confirmations and responses are being evaluated as they are received. Where adequate assurances are not obtained, the Gallery will terminate the contract (where it is legally able to do so), and will decline to enter into further contracts with the counterparty.
6. The process of due diligence started in 2017 did not focus on contracts for supply of professional services, which were regarded as less high risk than other contracts. In 2018 however the Gallery will extend its processes as outlined in 4 and 5 above to its contracts with suppliers of professional services.
7. 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.
8. 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.
