The Modern Slavery Act came into effect in March 2015. As one way of tackling the problem of modern slavery, the act requires that all commercial organisations, with a turnover of more than £36 million, provide an annual ‘slavery and human trafficking’ statement.
Modern Slavery Statement 2024
1. Statement of commitment of the Board of the Pension Protection Fund
The Board of the Pension Protection Fund (PPF) remains committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain.
2. Structure of the organisation
The Board is a statutory corporation established by section 107 of the Pensions Act 2004. The Board operates from two locations. The main office is in Croydon, Surrey & the Board’s investment team office is based in the City of London.
The Board holds, manages, and applies the PPF and the Fraud Compensation Fund which are statutory funds. The function of the Board is to:
- Pay Pension Protection Fund compensation to members of eligible defined benefit pension schemes, when there is a qualifying insolvency event in relation to the employer, and where there are insufficient assets in the pension scheme to cover the PPF level of compensation.
- Administer the Financial Assistance Scheme (FAS) and the Fraud Compensation Fund (FCF).
We work with a range of suppliers including suppliers of facilities and corporate services, professional services, administration services and investment fund managers. We also maintain investor relationships concerning our statutory investment and ancillary activities.
3. Policy
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business or within our service providers.
As part of this commitment, and in line with our regulatory obligations, we publish this annual statement outlining the policies, procedures and training we have in place to prevent incidences of modern slavery and human trafficking occurring in our business and supply chains, how we investigate suspected incidences and how we address confirmed incidences.
4. Our approach to supplier due diligence and risk assessment
As a public sector organisation we carry out assessments on our direct suppliers in accordance with the Public Contracts Regulations 2015 (and have done so since the implementation of these Regulations). Details of actions completed by the PPF to identify and prevent modern slavery are described below:
- Supplier approaches to preventing slavery and human trafficking and relevant policies are reviewed and assessed for their completeness.
- Checks are completed on whether organisations (or any person within it) have been convicted under slavery laws in the countries in which they operate within the last five years.
- Supplier’s Modern Slavery statements, as published on their website, are checked, and reviewed.
- A governance forum for vendor assurance is held monthly. Modern slavery risk is reviewed and assessed at this forum which determines the requirement for any further assurance including site visits.
- Annual review of our Group 1 suppliers that allows us to identify and monitor possible issues around slavery and human trafficking.
- Where we identify issues, we seek further information and work with our suppliers to improve their practices and procedures. If a supplier does not take steps to resolve the situation, this could lead to the termination of contracts.
- Every new supplier is assessed as high/medium/low for modern slavery risk and considered as part of the decision to award a contract. This rating is also used in our ongoing assurance programme to identify high risk suppliers who will be prioritised for onsite visits. Fund managers are also included in our modern slavery assessments.
- Where a supplier is rated high or medium, we have developed a questionnaire requesting further information and assurance as to how the supplier is managing its modern slavery risks.
- Our assessment of suppliers is also supported by our Modern Slavery Supplier Standard document which sets out the principles and processes under which the Commercial Services Team will assist with identifying and managing the risk of Modern Slavery in our supply chain.
- Modern slavery is covered as part of our ongoing compliance monitoring and training programme.
5. Supplier Code of Conduct
We maintain a Supplier Code of Conduct which, as a public corporation, meets the same standards set out in the Government Supplier Code of Conduct.
This requires suppliers to operate in accordance with the Code and outlines amongst other things, how we manage human rights, and the behaviours and practices we expect suppliers to demonstrate to ensure compliance with our policies.
6. Our business-wide due diligence and risk assessment framework
We operate a business wide risk framework which considers broader business integrity issues. We invest funds in a range of industry sectors across multiple jurisdictions. Our investments are considered in line with the PPF Responsible Investment Strategy which is part of our wider sustainability strategy. Fund managers, as direct suppliers, are subject to the modern slavery checks outlined in section 4 above. We have ongoing monitoring and due diligence processes in place to mitigate key supplier risks including slavery and human trafficking.
7. Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking our Commercial Services staff, who are responsible for the central management of all our supplier contracts, undertake yearly Chartered Institute of Procurement and Supply (CIPS) ethical procurement training, covering awareness of human rights and understanding of the risks of modern slavery in supply chains. In addition, the Modern Slavery Act 2015 is included in the Compliance and Ethics corporate induction for all new starters.
8. Our effectiveness in combating slavery and human trafficking
We promote a company-wide sense of responsibility to prevent modern slavery and human trafficking in our business operations.
Our work around modern slavery is complemented by our existing framework of policies including the Code of Conduct and Whistleblowing policy which reinforce cultural and ethical business practices.
We remain in regular contact with all our suppliers, working with them, raising awareness, and seeking assurance there is no modern slavery occurring within any of our suppliers.
We continually assess and review our processes for assessing and managing our risks arising from modern slavery and human trafficking to ensure modern slavery and trafficking is not taking place within our organisation or supply chain.
This statement is made in accordance with section 54(1) of the Modern Slavery Act 2015 and constitutes the Board’s slavery and human trafficking statement.
Signed on behalf of The Board of the Pension Protection Fund.
Michelle Ostermann, Chief Executive Officer
June 2024