Transport for London Identifies High-Risk Areas with Modern Slavery Risk Assessment

The Greater London Authority (GLA) Group spend around £9.5 billion on it’s procurement activities every year. The Group is comprised of the Functional Bodies which sit under the Mayor of London’s authority:

Transport for London (TfL which provides procurement services for the GLA and some shared services for the group), London Fire Brigade (LFB), Metropolitan Police Service (MPS), London Legacy Development Corporation (LLDC), Old Oak and Park Royal Development Corporation (OPDC), Mayor’s Office for Policing and Crime (MOPAC) and the GLA itself.

The GLA Group has a vast and varied supply chain – both local and international – and manages and commissions numerous construction sites that require many workers, across several sites, to ensure that work is completed. This includes affordable home building programmes, fire and police station redevelopments, significant capital programmes such as the Northern Line Extension and facilities management across the Group’s estate.

In recognition that Modern Slavery is on the rise in the construction sector and on building sites, the GLA Group identified the need to develop a standardised risk-assessment process that could identify high-risk areas where modern slavery may occur on their construction sites and in their supply chain, and implement a standardised process to minimise this risk.

Although much progress had been made to address this internally through sustainable procurement guidelines, engaging with industry peers, ongoing internal training and the production of annual Modern Slavery Statements, it was recognised that specialised external expertise should be brought in to ensure an effective process could be set-up and implemented.

Prior to the project there were no identified instances or issues as a direct result of modern slavery; the Group wanted to be proactive in their approach to tackling the issue and lead the way in demonstrating to organisations how the risk of modern slavery could be minimised. Additionally, the GLA Group recognised that organisations were increasingly under scrutiny over how they were managing issues related to forced labour and saw this as an opportunity to inform and upskill their workforce to be able to address these challenges through procurement.

The GLA Group wanted to draw on specialised external expertise to enable them to design a risk assessment framework that would allow for high-risk areas to be identified and a process set in place to minimise this risk.

Prior to this, the approach to managing modern slavery risks had evolved over time meaning there were inconsistencies across sites and often requiring continual support from subject matter experts to ensure these were performed correctly. Thus, the need for a standardised risk-assessment process that could be understood by relevant procurement leads and applied consistently across the organisation was recognised.

Through a series of interviews and an analysis of current processes, Action Sustainability identified medium to high-risk categories within the GLA Group where modern slavery may occur and designed a process to help manage this risk.

This included the creation of a risk assessment form, the development of tender questions based on the level of risk for each procurement category and a guide on how to evaluate responses. This guide demonstrated what good practice looks like and enabled employees across departments to understand where risk may arise and how this should be appropriately responded to. Procurement materials were also provided externally, to help guide suppliers on how to identify risk and address issues related to Modern Slavery.

During the initial design of the procurement guidance, a lengthy handbook document was created. This was considered too extensive for procurement staff and likely to deter some staff from reviewing and including relevant requirements.

In recognition of this, and drawing on knowledge of high-risk category areas, the specific tender approaches were prioritised and extracted from the in-depth handbook to provide a succinct guidance document with key messages. This made the content easier to engage with, more user-friendly and hence encouraged procurers to engage with this work.

The work completed by Action Sustainability improved understanding on how risk could be better assessed; for example, through the design of tender questions and guidance for both, materials labour, in recognition of how different the risk of modern slavery is in each. The resources provided have also given insight into how to support the supply chain and work more collaboratively to address issues related to modern slavery and have allowed procurement staff to easily interpret the risk on their spend categories.

The work completed by Action Sustainability has enabled the GLA Group to better manage the risks associated with modern slavery and provide further support on how these issues can be addressed.

Furthermore, the GLA Group have built upon the work provided through continuing to raise awareness of modern slavery through the creation of a SharePoint site where resources on guidance and advice on how to identify and manage the risk of modern slavery. They’ve also begun communicating more about the issue through offering training through the Supply Chain Sustainability School to suppliers and an internal blog which was released on modern slavery awareness day.

The project built awareness of the issues of Modern Slavery with staff and improved overall competence on working with and dealing with issues associated with modern slavery. Additionally, the creation of a standardised tender approach and guidance document has saved time for the procurement team who originally needed to engage with the subject matter experts for each tender. They can now drop the standard approach into their procurements, creating consistency and standardisation.

Based on the work which was completed, an internal Modern Slavery Delivery group has been established to ensure consistency of applying the lessons from the work across the Group.  This has allowed a consistent company-wide approach to assessing risk and tackling modern slavery to be implemented and ongoing lessons learned to be implemented as best practice materials and approaches continue to emerge.