This statement is made pursuant to Section 54 of the UK Modern Slavery Act 2015 and sets out the steps BAE Systems plc and its UK subsidiaries have taken to identify and prevent slavery and human trafficking in our business and supply chain, in the UK, during the year to 31 December 2022.
Approval by subsidiaries
The BAE Systems Modern Slavery Act Response 2023 has been approved by the board of directors of the following subsidiaries:
- BAE Systems (Military Air) Overseas Limited
- BAE Systems (Oman) Limited
- BAE Systems (Operations) Limited
- BAE Systems Applied Intelligence Limited
- BAE Systems GCS International Limited
- BAE Systems Global Combat Systems Munitions Limited
- BAE Systems Marine Limited
- BAE Systems Surface Ships Limited
They all delegated authority to Charles Woodburn to sign this response on their behalf.
What we achieved in 2022
- Identified potential improvement actions and reviewed progress at regular UK modern slavery working group calls;
- Provided a human rights and modern slavery briefing for the UK modern slavery working group;
- Provided mandatory modern slavery awareness training to targeted employees who are responsible for procurement in our UK businesses;
- Monitored the roll out of Real Living Wage to tier one contractors who are regularly working on our sites across the UK;
- Rolled out revised UK Standard Conditions of Purchase incorporating provisions on modern slavery and the Real Living Wage;
- Revised and launched our Supplier Principles – Guidance for Responsible Business (Supplier Principles), which includes clearer expectations regarding human rights and modern slavery;
- Supported the Joint Supply Chain Accreditation Register (JOSCAR) Governance Group to update the JOSCAR supplier prequalification questions to enhance the modern slavery section;
- Conducted risk based assurance with suppliers representing more than 30% of our global spend, to confirm adoption of our new Supplier Principles;
- Continued to assess our tier 1 suppliers against high risk commodities and locations;
- Implemented key performance indicators in the UK; and
- Strengthened our Ethics Helpline modern slavery reporting process.
What we plan to do in 2023
- Extend roll out of modern slavery awareness training to targeted employees who are responsible for procurement in our UK businesses;
- Deliver a modern slavery awareness brief at our Global Supply Chain Town Hall;
- Continue to engage our suppliers on our Supplier Principles – Guidance for Responsible Business;
- Continue to conduct risk based assurance with suppliers to confirm adoption of our new Supplier Principles;
- Continue to assess our tier 1 suppliers against high risk commodities and locations;
- Develop and communicate a formal Modern Slavery Escalation Procedure within our UK businesses to escalate reports of and concerns relating to human trafficking and slavery;
- Refresh our procurement lifecycle management guidance to support supplier assessment and management in respect of ESG, sustainability and modern slavery;
- Benchmark our UK modern slavery practices against external best practice; and
- Develop debt bondage focused due diligence for key labour providers to our UK businesses.
