Modern slavery statement

National Trust Modern Slavery Act Statement

The National Trust and National Trust Enterprises (hereafter 'The Trust') are committed to tackling the risk of modern slavery in its organisation and supply chains. We actively promote inclusion and diversity, and any unfair or discriminatory treatment of people is profoundly at odds with what we stand for as a conservation charity.

We recognise that modern slavery is a growing issue, and that the current global context increases the risks of human trafficking and forced, bonded and child labour. This year we have continued in our actions to better understand the modern slavery risk in our business, and to develop a plan to effectively manage those risks.

The Board of Trustees and National Trust Enterprises Board of Directors have approved this statement.

The National Trust

The National Trust for Places of Historic Interest or Natural Beauty is a registered charity (no. 205846). It is incorporated and has powers conferred on it by Parliament through the National Trust Acts 1907 to 1971 and under the Charities (National Trust) Order 2005.

As Europe’s largest conservation charity, we look after nature, beauty and history for everyone to enjoy. We do it with the help of millions of members, and thousands of volunteers, staff, donors, and suppliers. Without this support, we could not care for the miles of coastline, woodlands, countryside and the hundreds of historic buildings, gardens and precious collections we protect.

Our approach

Following an independent review last year, we have taken time to engage with stakeholders and develop a proportionate and effective response. Our Executive team attended a workshop facilitated by a leading consultancy, at which we reiterated our commitment to tackling modern slavery and confirmed the priority actions to undertake, including:

• Ensuring we have a clear modern slavery policy.
• Providing appropriate training for staff.
• Implementing incident response and remediation procedures.
• Publicising the national modern slavery hotline.
• Monitoring and reporting against suitable key performance indicators.

We have also developed specific plans for managing modern slavery risk associated with our supply chains, our staff and volunteers and our let estate. Each of these three areas is described in more detail as follows.

Our supply chain

As a conservation charity, good procurement is about much more than price, and we have a range of sustainability standards for distinct types of goods and services. Through these standards, we encourage consideration of the environmental, social and economic impacts of goods and services and their supply chain activities.

We work with thousands of suppliers who provide us with a diverse range of goods and services, including everything from the coffee we serve in our cafes and the equipment we use to cultivate our gardens, to the building contractors who maintain our historic properties. We recognise the challenges around modern slavery in complex global supply chains, and we are fully committed to understanding and minimising the risks of modern slavery associated with all types of goods and services we purchase. We reaffirm in our sourcing process and our terms and conditions the statutory obligation for every supplier to prevent modern slavery in their business.

Tackling Modern Slavery is a top priority within our sustainable procurement strategy, which brings together key stakeholders from teams and professions across the Trust to collaborate, engage and deliver the Trust’s priorities for sustainable, ethical procurement.

We will ensure that modern slavery is a priority consideration for the sourcing and management of higher risk products and provide guidance and training to staff who select and manage these.

We have created a new Buying Responsibly hub on our staff intranet, with information and resources on sustainable procurement impacts including Modern Slavery. This includes access for all staff to a specialist online database to give an independent perspective on the ethical issues for different consumer brands, goods and services. We have also published guidance for staff about buying safely and ethically from online retailers and marketplaces.

In 2024/25 we will continue to develop our capability for managing modern slavery risk, by further integrating modern slavery into our supplier selection and management policies, practices, and standards. We will be clear about our expectations for suppliers of higher risk goods and services to take steps to minimise the risk of labour exploitation.

• Clarifying responsibilities of staff that select and manage key suppliers.
• Introducing a Supplier Charter to make clear what we expect of suppliers.
• Mapping and assessing modern slavery risks in higher-risk supply chains.
• Introducing a procedure for detailed risk assessment and monitoring of key suppliers.

Our Commercial supply chain in focus

Our Food and Beverage team manage 85 key suppliers of food and non-food items for our visitor cafes. We include specific modern slavery requirements in every supplier contract, and through active relationship management ensure ongoing compliance to these. In 2024/25 we will implement independent monitoring for our food & beverage business. These services are provided by SEDEX, a leading provider of data-driven insights, tools, and services to help buyers and suppliers continuously improve environmental, social, and governance outcomes.
Suppliers of goods for resale in our shops, whether carrying our brand or a third-party brand, must follow our Retail Sourcing Standards. These Standards set out 11 clear principles, based on the Ethical Trading Initiative base code, to:

• Prohibit forced labour, child labour and any harsh or inhumane treatment, and
• Ensure adequate health and safety, clear employment terms, fair pay, reasonable working hours, freedom of association, equality, positive community engagement, and compliance with environmental regulations.

Retail suppliers must also be supplier members of SEDEX for ongoing monitoring, and we take a risk-based approach to independent ethical audits of manufacturing sites. These specific measures for retail also apply to any licenced product that carries our brand.

This financial year, we initiated our Ethical Compliance Project to look closer at supply chain mapping and traceability, so we can identify and manage potential modern slavery and human rights risks. The project is founded on principles of fair labour practices, environmental stewardship, business integrity and human rights. It will provide us with fully traceable supply chain data to track performance against the Trust’s policies and relevant legislation. We will use this to enhance our ethical sourcing practices with tighter controls and monitoring using SEDEX. We have engaged widely to shape the project, with input from our central buying team, our property-based Retail staff, and our suppliers. We have already evidenced significant increases in supplier compliance to our Retail Sourcing Standards.

In 2024/25, we will continue to target increased compliance for both centrally managed and locally managed suppliers of goods for resale. We will do so through a combination of our internal sourcing practices, the use of the SEDEX monitoring services, and staff induction and refresher training. We will also introduce use of the World Bank Governance Indicators to understand country of origin risk factors for our products and specify additional traceability requirements for high-risk countries. Finally, we will take action to develop non-compliant suppliers and cease trading with them where issues are unresolved.

Our let estate

The Trust works with over six thousand tenants who lease our properties as homes or business premises. We are committed to mitigating the risks of our properties being used to house or employ victims of modern slavery and we strive to equip our staff with the knowledge and tools to recognise, report and respond to any issues or concerns.

We perform background checks on potential new tenants who will be living in our property. This includes fulfilling legal requirements to check new adult occupants have a lawful right to rent in the country. However, we recognise that modern slavery can also affect those who are not subject to right to rent checks. We credit check all named tenants and report fraudulent applications where appropriate.

Our tenancy agreements require our tenants to comply with all relevant laws relating to their use of the property. This includes not using the property for anything which would breach the Modern Slavery Act.

We perform regular tenancy inspections which help to identify any unusual circumstances or behaviours which may be indicative of modern slavery. We recognise that workers may be at higher risk of exploitation in businesses which use temporary or seasonal labour such as some types of farms and hospitality businesses. On many estates we are embedded in the local community and maintain relationships with neighbouring properties who inform us of concerns about the use or occupation of our properties. We also monitor rental payments to identify any unusual or irregular behaviours and take appropriate action.

Our Estate Management teams complete our annual organisational-wide safeguarding training which ensures they have the knowledge and tools to recognise, report and respond to concerns or potential incidents of safeguarding.
In 2024/25 we will:

• Review existing and potential training options to include tenanted properties and modern slavery.
• Ensure our Let Estate teams have access to modern slavery resources and guidance for landlords.

Staff and volunteer wellbeing

The Trust has a clear framework of values and rules and encourages the reporting of any concerns or breaches so that they can be dealt with appropriately in accordance with our policies and procedures. This is regardless of whether the concern comes from an employee, volunteer, or member of the public. In 2023 we launched a Volunteer Charter to clarify and reinforce the role and responsibility of volunteers to report concerns via the available channels.

We are committed to creating an environment where all our people will feel safe from harm and abuse. This includes children, adults at risk and anyone who comes into contact with the Trust. We have established a network of Designated Safeguarding Leads in all regions, with national oversight by our Safeguarding and Wellbeing Lead. Our safeguarding training for staff and volunteers as well as our instruction, procedures and framework ensure we recognise, report, and respond to all concerns or potential incidents of safeguarding.

We offer an independent and confidential Speak Out hotline where staff and volunteers can raise any concerns confidentially and anonymously if they wish. Our Employee Assistance Programme also provides staff and volunteers with a secure way of seeking advice about a range of topics including modern slavery or human trafficking issues personally affecting them or their families. In addition, we have established several staff networks which aim to help the Trust achieve greater diversity and equality and provide peer support to their members and allies.

In 2024/25 The Trust will continue to review its employment policies and practices, including its approach to Modern Slavery, considering any emerging legislation, case law or case reviews.