Modern Slavery StatementPublished: 09 June 2023
Freedom of information class:
RoS is committed to combating slavery and human trafficking and, as such, we consider modern slavery to be a critical issue.
Modern slavery is a global issue consisting of the exploitation of human beings for commercial gain. The International Labour Organisation has estimated that there are 24.9 million victims of forced labour globally. The Global Slavery Index estimates there to be 1.1 million victims of modern slavery.
Modern slavery is a criminal commercial enterprise.
Businesses have a duty to work to avoid complicity by ensuring that:
- supply chains are free of exploited labour
- working conditions are fair and safe, with workers being of suitable age
Modern Slavery Act 2015
Section 54 of the Modern Slavery Act 2015 (MSA) requires any commercial organisation with annual budget of £36m or more that conducts business in the UK to produce a slavery and human trafficking statement for each fiscal year.
This statement explains:
- the steps Register of Scotland (RoS) has taken during the 2021-2022 fiscal year to identify, prevent and mitigate modern slavery and human trafficking in our operations and supply chains
- our aims for the 2022-2023 fiscal year.
RoS is committed to combating slavery and human trafficking and, as such, we consider modern slavery to be a critical issue. We have a zero-tolerance approach to all forms of modern slavery and human trafficking.
Our service offering means that we consider that the form of modern slavery applicable to our working practices is labour exploitation. Considering the type of business activity we undertake, we consider that the primary modern slavery risk in our core service delivery is low. However, we endeavour to do all we can to ensure we have a robust Code of Conduct and Ethical Standards in place.
The Modern Slavery Act 2015 (the Act) recognises the following as a crime and a violation of fundamental human rights:
- forced or compulsory labour
- human trafficking
Registers of Scotland’s responsibilities
RoS recognises its responsibilities under the Act. In compliance with the provisions of Section 54 makes the following statement regarding the steps that will be taken during fiscal year ending 31 March 2023 to ensure that no modern slavery or human trafficking is taking place in any part of the organisation or its associated supply chains.
This statement summarises the actions and activities conducted by RoS to better understand the:
- potential risks of modern slavery and human trafficking
- systems and controls that will be introduced to mitigate those risks.
This statement will subject to annual review.
2. About RoS
RoS keeps public registers of land, property, and other legal documents in Scotland.
Find out more about RoS.
3. Our Statement
RoS is committed to protecting and respecting human rights across RoS’s activities and will take, where reasonable, appropriate steps to influence others to ensure slavery and human trafficking does not take place.
Our Human Resources Policies confirm our commitment to workplace rights for employees to ensure an environment based on dignity and respect, which does not condone or allow:
- discrimination of any other unacceptable behaviour.
Additionally, our Whistleblowing and raising a concern policy provide staff with the means to report improper conduct or unethical behaviour.
In compliance with the Procurement Reform (Scotland) Act 2014, RoS’s Procurement Strategy 2022 – 2025 , sets out our principles and approach to ensuring responsible and sustainable procurement practices.
Approach to sustainable procurement practices
Conditions of contract
Seeking to ensure that Conditions of Contract which enhance health & safety and equalities will be included.
Encouraging ethical sourcing practices amongst:
- our suppliers
- partner organisations
- the broader market.
Fair employee practices
Ensuring forced, bonded, or compulsory labour practices are not used, and employees are free to leave their employment after reasonable notice. Employees must not be required to lodge deposits of money or identity papers with their employer.
Employees 16 years or under
Mandating that work undertaken by people of 16 years or under without consideration for their personal development, safety, education, or health is prohibited. This will be supported by policies and programmes, which promote the development of any employed child. Placing children in employment deemed to be hazardous (in accordance with International Labour Organisations (ILO) definitions) shall not be tolerated.
4. Our Supply Chains
Our supply chain includes Training Providers, IT suppliers, Facilities Management providers, sub-contractors, and consultants. With all suppliers, RoS encourages ethical sourcing which mitigates the risk of modern slavery further down our supply chains.
We include contractual clauses which allow us to audit contractors which include rights to site visits.
5. Our Procurement Activity and Due Diligence
The risk of Modern Slavery in RoS’s activities is considered low. However, we recognise the potential risks linked to the extended and indirect supply chain of goods and services.
For RoS, such risks are reduced as procurement of goods and services are increasingly sourced through framework agreements (such as Scottish Procurement or Crown Commercial Services). All our prime contractors are also required to complete a Single Procurement Document (SPD) which includes a question on forced labour.
Additionally, RoS considers Fair Work Practices as part of our contract strategies and, where appropriate, includes either scored Fair Work criteria or a contractual obligation on suppliers.
For contracts tendered by RoS of £50k value and over which are procured out with frameworks, Fair Work Practices questions are included in selection and award criteria. For contracts of lower value, contract managers will have an awareness of signs of modern slavery through training and awareness.
6. Staff Training and Awareness
To ensure an important level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business RoS will work towards producing a guidance note to support this statement.
Partnered with internal comms, this guidance note is intended to improve the understanding and awareness of modern slavery across the organisation.
7. Our Effectiveness in Combating Slavery and Human Trafficking
We use the following to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:
- effective use of the HR Resourcing Policy
- completion of audits conducted by internal and external auditors
- level of communication and personal contact with first tier supply chain and their understanding of, and compliance with, our expectations