UK Modern Slavery Act

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 United Kingdom (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 2024.

Approval by subsidiaries

The BAE Systems Modern Slavery Act Statement 2025 has been approved by the board of directors of the following subsidiaries¹:

• BAE Systems Applied Intelligence Limited
• BAE Systems GCS International Limited
• BAE Systems Global Combat Systems Munitions Limited
• BAE Systems Marine Limited
• BAE Systems (Military Air) Overseas Limited
• BAE Systems (Oman) Limited
• BAE Systems (Operations) Limited
• BAE Systems Surface Ships Limited
• BAE Systems Services Limited

They all delegated authority to Charles Woodburn to sign this response on their behalf.

What we achieved in 2024

• Reviewed our internal benchmark exercise with a view to making recommendations for adoption within our UK business;
• We completed a deeper dive benchmark review against the publicly available information from four peer organisations in order to identify areas of strength and opportunity. From this exercise, we have identified a number of potential activities for 2025 that will help us continue to improve on our modern slavery risk identification and mitigation activities in our business and supply chain. These include:
  • Continue to build on the scope of our supplier risk assessment activities;
  • Build on delivery of modern slavery awareness;
  • Further clarify our related documentation, roles and responsibilities;
  • Where appropriate, engage with third party organisations in our planning, assessment, mitigation and continual improvement activities; and
  • Review and refresh our existing Supplier Code of Conduct (formerly Supplier Principles - Guidance for Responsible Business).
• Updated our business guidance;
  • We updated our supply chain documentation, including those related to modern slavery to offer guidance to our business on how to consider these aspects at each stage of the procurement process.
• Continued to deploy modern slavery awareness e-learning across relevant areas of our UK business;
  • We embedded our modern slavery awareness training modules into our internal training systems and delivered awareness to over 700 procurement personnel.
• Continued to engage our suppliers on our Supplier Code of Conduct;
  • We continued to communicate our expectations to suppliers through our Supplier Code of Conduct document, as well as through content on our new Supplier Knowledge Sharing web page.
  • In addition, we developed and launched a set of Supplier Code of Conduct engagement cards across a number of areas of our business, providing guidance to our supply chain population on holding meaningful and impactful supplier conversations around each of our principles.
• Continued to conduct risk-based assurance with suppliers to confirm adoption of our Supplier Code of Conduct;
  • We completed our annual Supplier Code of Conduct Assurance Review which covered 34% of our global spend.
• Assessed our tier 1 suppliers against high risk commodities and locations.
  • We completed three planned supplier risk assessments during 2024, covering the identified high risk commodities and locations. This included an annual debt bondage risk assessment conducted with five of our key agency suppliers, as well as two global tier 1 supplier risk assessments (conducted at mid and year end) with commodities and locations assessed against the US Department of Labor Trafficking Victims Protection Reauthorization Act (TVPRA) List of higher exposure risk goods and locations.

 
What we plan to do in 2025

• Follow-up on our 2024 benchmarking observations through a prioritised set of activities that continually strengthen our practices and approaches;
• Engage across our UK business to communicate, educate and deploy the revised Supply Chain guidance and identify opportunities to develop further;
• Continue to maintain appropriate awareness currency across our business;
• Continue to engage our suppliers on our approach to mitigating modern slavery in our supply chain;
• Review and update our Supplier Code of Conduct;
• Continue to conduct risk-based assurance with suppliers to confirm adoption of our Supplier Code of Conduct; and
• Continue to assess our supply chain against high risk commodities and geographies.