Modern Slavery and Human Trafficking Statement 2021-2022

1. Introduction

1.1 From the wool trade to the industrial revolution, from the Suffragettes to graphene, change has always been at the heart of Greater Manchester's story. As we grow and develop as a City Region we recognise the fundamental injustices that permeate some areas of our society and we, Transport for Greater Manchester (TfGM), are committed to upholding the highest standards of ethical conduct and integrity by tackling those injustices wherever we can.

1.2 Modern slavery is a criminal offence and a violation of fundamental human rights. It takes various forms, such as servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

1.3 As a public sector organisation, TfGM recognises that we have a responsibility to take a robust approach to slavery and human trafficking. We are committed to acting ethically and with integrity in all of our business dealings and relationships and in implementing and enforcing effective systems and controls to combat modern slavery and human trafficking.

1.4 We are committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

1.5 Section 54 of the Modern Slavery Act 2015 (" MSA ") requires any commercial organisation with a turnover of £36m or more that carries out business in the UK to produce a slavery and human trafficking statement for each financial year. This is TfGM's fifth Modern Slavery and Human Trafficking statement, and it explains the steps TfGM has taken during the 2021 -2022 financial year to identify, prevent and mitigate modern slavery and human trafficking in our operations and supply chains, and sets out our aims for the 2022 -2023 financial year.

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2. Organisational Structure and Supply Chain

2.1 TfGM is the transport delivery arm for The Greater Manchester Combined Authority (GMCA) and its Greater Manchester Transport Committee (GMTC). TfGM co-ordinates public transport and other types of travel -- such as driving and active travel -- throughout the ten district areas of Greater Manchester.

2.2 We work closely with bus, tram and train operators to help put the customer first and improve journey experiences. We also own Metrolink -- the UK's largest light rail network. By investing in new, modern transport interchanges and smarter travel information, TfGM is making it easier to travel on public transport. We also promote and invest in walking and cycling as a healthy and sustainable way to travel. With our partners at National Highways and the ten local authorities in the Greater Manchester area, we work to keep our roads safe and to tackle congestion.

2.3 We are also planning for a more sustainable future. Through implementation of the Greater Manchester 2040 Transport Strategy, we aim to make the city and region a cleaner, greener and healthier place to live, work and relax in.

2.4 Our commercial activities support the delivery of all of our operating businesses and cover a range of categories including subsidised bus services, the operation of the Metrolink light rail network, transport related consultancy, information technology related goods and services, commercial partnerships and sponsorships, in addition to construction and civil engineering. In 2021/2022, we spent over £307 million on goods, works and services, with over 580 suppliers. Our supply chains include businesses from all regions of the UK and beyond including organisations whose headquarters are across the globe.

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3. Our Priorities

3.1 Everything we do at TfGM is organised around our areas of priority, which we call our "Four Pillars". These pillars give us consistency and focus, allow us all to see how our work fits into the organisational priorities, and helps us track our progress.

3.2 The pillars are:

Adapting and Building Back Better

This pillar is about rebuilding confidence and ensuring that public transport and active travel are at the heart of Greater Manchester's social and economic recovery. It brings together a focus on understanding how and when people travel after COVID-19 and how interventions will help people to choose travelling by public transport, cycling or walking; as well as bringing transport networks back to a 'new' normal level and ensuring that TfGM maintains financial sustainability throughout the recovery phase.

Towards Our Network

This pillar is about delivery and integration, as we move into the operational phase for some of our major change programmes. It is about delivering the key components of an integrated transport system.

Planning Our Future

This pillar is about planning and developing. It will ensure that we maintain our focus on the major planning, development and funding challenges and opportunities which will complete the transformation of our transport system into the longer-term transport network that we aspire to.

Making us Future Ready

This pillar is about people and processes. It focuses on the internal TfGM change and development programmes that will be needed to support the achievement of the three pillars above and ensure that TfGM is in the right shape and that it has the right resources and capabilities to deliver upon our ambitions. 

3.3 Although the Four Pillars represent the major changes we are seeking to make to the transport network and to the organisation, they are underpinned by the need to continuously improve the core services of the organisation. Supporting and improving, and in some cases changing, how we provide our current services and network is just as important as the new services and networks we are looking to build.

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4. TfGM Policies and Procedures

4.1 As a major purchaser, TfGM has a responsibility to ensure that any buying activities and those of our suppliers are responsible. TfGM has a range of policies and processes which reflect our commitment to acting ethically and with integrity to prevent slavery and human trafficking in its operations.

4.2 Current policies / procedures which apply include:  

Procurement / Legal

• We expect that all of our contractors, suppliers and other business partners have their own policies in place relating to working practices or modern slavery, or for evidence to be available to ensure their standards are in accordance with TfGM's expectations. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

• We test prospective suppliers at tender stage to ensure that they are compliant with the requirements of the MSA, including reporting requirements contained within s. 54 of the MSA; compliance with all applicable anti-slavery and human trafficking laws, statutes and regulations; maintenance of policies and procedures relating to the MSA; and reasonable endeavours to mitigate modern slavery within its supply chain.

• We utilise the Social Value Portal and the National Themes, Outcomes, Measures (TOMs) Framework in order to measure and manage the contributions that TfGM and our supply chain make to society.

• We have built social value considerations into our internal governance approvals to ensure we are maximising delivery against the GMCA Social Value Framework 2020.

• We expect and request that our contractors either sign a declaration or commit to terms confirming that in performing their obligations to TfGM under the terms of their engagement they shall:

• comply with all applicable anti-slavery and human trafficking laws, statutes and regulations from time to time including but not limited to the Modern Slavery Act 2015;

• have and maintain throughout the term of their engagement with TfGM its own policies (which TfGM may request sight of from time-to-time) and procedures to ensure their compliance;

• not engage in any activity, practice or conduct that would constitute an offence under sections 1, 2 or 4 of the Modern Slavery Act 2015; and

• ensure that each of its subcontractors and suppliers shall comply with its anti-slavery policy and with all applicable anti-slavery and human trafficking laws, statutes, regulations from time to time in force, including but not limited to the Modern Slavery Act 2015.

• Should TfGM look to procure or import products or services which could pose an increased risk of slavery or human trafficking, we undertake further consideration of supply chains in order to take account of the potential risks.

Human Resources

• TfGM, as an employer, is committed to paying the Real Living Wage.

• This approach has been validated through TfGM recently being awarded 'Member' status of the Greater Manchester Good Employment Charter.

Finance

• We aim to pay supplier invoices within 30 days to ensure we are not unintentionally increasing modern slavery risks arising from suppliers not being able to pay second tier suppliers or workers' salaries.

Commercial

• We regularly review and update our policies. This includes TfGM's Advertising policy which prospective advertisers, their parent company, associated businesses and their supply chain must adhere to. You can review TfGM's Advertising policy here: TfGM Advertising Policy | Transport for Greater Manchester.

• In addition to the Advertising policy in place for prospective advertisers, we   undertake separate ethical checks for agencies, partners and sponsors where a contracted paid-for partnership is being entered in to with TfGM. This is a growing area and is supported by colleagues in GMCA, utilising guidelines and best practice from the Good Employment Charter and the Social Value Framework.

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5. Awareness and Engagement

5.1 TfGM understands that there is a need for employees within the organisation to understand and identify modern slavery and human trafficking. As such, TfGM has produced a training module to raise awareness and increase compliance with the Modern Slavery Act 2015.

5.2 The training module is available to all TfGM employees but it specifically targets employees whose roles require additional awareness on the issue. The module includes:

• The principles of the Modern Slavery Act 2015 and TfGM's obligations under s. 54;

• How all parts of the business influence purchasing practices which influence supply chain conditions;

• What employees can do to flag up potential slavery and human trafficking issues to the relevant parties within the organisation; and

• What external help is available, e.g. through the Modern Slavery Helpline.

5.3 A number of TfGM's Procurement team are members of the Chartered Institute of Procurement & Supply (CIPS) whilst other members of the team are studying for their CIPS professional qualifications. Modern slavery is included within a CIPS students' studies and forms part of the CIPS Chartered Status accreditation, by way of a mandatory ethics test. 

5.4 A presentation is delivered annually to various directorates during our "Core Brief" to raise awareness of modern slavery. These presentations are timed to coincide with the publication of TfGM's Modern Slavery Statement.

5.5 In-depth bespoke training is provided for employees who work within areas identified as high risk.

5.6 We are also an active partner of the Greater Manchester Independent Inequalities Commission which was set up to look at inequality in Greater Manchester and come up with ways to improve inequality.

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6. Modern Slavery and Human Trafficking and the COVID-19 Pandemic

6.1 We continue to live with COVID-19 and, unfortunately, during times of uncertainty it is often the most vulnerable members of society who are exposed to a greater risk of exploitation.  In an attempt to mitigate modern slavery risks during the pandemic, TfGM has, and continues to, amongst others, taken the following steps:

• Conducted additional due diligence, as necessary, when procuring goods and services;

• Utilised the new Covid Scenario Forecast platform on the Company Watch website as part of the procurement process; and

• TfGM's Finance team has worked hard to expedite the payment of supplier invoices in order to help ensure that workers within the supply chain receive their wages.

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7. Future Proposals

7.1 TfGM hopes to build on its existing steps to prevent, identify and mitigate the risks of slavery and human trafficking by improving our current systems to:

• Identify and assess potential risk areas in our supply chain;

• Mitigate the risk of modern slavery and human trafficking occurring in our supply chain;

• Monitor potential risk areas in our supply chain; and

• Protect whistle-blowers.

7.2 We undertake, and will continue to undertake, due diligence when considering new suppliers and we will continue to regularly review existing suppliers. TfGM's due diligence and reviews include:

• Taking steps to improve substandard supplier practices, requiring them to implement action plans;

• Invoking sanctions against suppliers that either fail to improve their performance in line with an action plan or seriously violate our supplier conditions of contract, including the termination of the business relationship;

• Where we believe there is an increased risk of modern slavery and human trafficking, TfGM will conduct additional due diligence on second tier suppliers; and

• We will continue to develop appropriate clauses and wording for all relevant documents, including contracts.

7.3       As part of our wish to implement wider contract management improvements within the organisation, TfGM shall continue to introduce additional requirements with regard to modern slavery awareness. 

7.4       We will continue to utilise the Social Value Portal in order to measure and manage the contributions that TfGM and our supply chain make to society. 

7.5       We will continue to work with the GMCA and the GM local authorities on our aspirations to adopt, where possible, a policy for suppliers on all procurements over the regulated threshold to pay the Real Living Wage and to sign up to be 'supporters' of the Good Employment Charter.

7.6       TfGM will continue to share knowledge with other local authorities (predominantly within Greater Manchester) and will also seek to work with other organisations to help combat modern slavery within Greater Manchester and beyond.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes TfGM's modern slavery and human trafficking statement for the financial year ending 31 March 2022. The publication of this statement was delayed due to the organisation prioritising the immediate needs of the Greater Manchester public during the COVID-19 pandemic.

Performance Board approved this statement on 18th August 2022.

Name: Kath Wilson
Position: Head of Legal Services

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