Introduction
Palladium International Limited supports the Modern Slavery Act 2015 in all parts of our business. We are committed to preventing the existence or prospect of modern slavery within our organisation and our supply chains, through the continuous refinement of our own policies and engagement with our suppliers.
Our annual statements demonstrate our commitment to exceeding legal compliance and proactively tackling modern slavery in our supply chains. In 2019 and 2020 we consulted the UK Government’s Modern Slavery Unit to obtain feedback on our approach. Guidance received informs this statement.
Our 2019 statement was ranked in the top 60% of the UK government’s 100 largest suppliers. We have scored highly since, increasing from 81% in 2021 to 84% in the December 2022 assessment.
We are committed to continuous improvement and this year’s statement provides a clear roadmap of our goals for 2024.
This statement is made pursuant to section 54(1) of the UK’s Modern Slavery Act 2015 and is Palladium’s updated modern slavery and human trafficking statement for the calendar year starting 1st January 2024.
Our structure, business and supply chains
Palladium International Limited is a private limited company registered in England and is part of the Palladium group of companies (referred to in this Statement as the Group). The Group is owned by Global Infrastructure Solutions Inc (GISI). The Group operates with a global corporate leadership and functional team supporting regional business units in Asia Pacific (APAC), Europe Middle East Africa (EMEA) and the Americas. It has established regional business offices in, among other places, Australia, India, Indonesia, Netherlands, Spain, United Kingdom, United States, and United Arab Emirates.
The Group includes global impact firms, working to link social progress and commercial growth. Since 1968 the Group has worked with corporations, governments, foundations, investors and communities to formulate strategies, build partnerships, and implement solutions that generate lasting social, environmental and financial benefits.
The Group’s core business services include business strategy consulting, programme and project management, impact investing and capacity building.
The Group has global practice areas in health; education and workforce development; economic growth; climate, environment and natural resources; governance, law and justice; humanitarian aid; impact measurement; inclusive growth; innovative finance, infrastructure; and, nature-based solutions.
As the Group we deliver evidence-based solutions with large-scale impact through more than 306 current projects with more than 3,000 employees operating in over 90 countries, and working with more than 50,000 organisations. Currently Palladium works with more than 600 organisations across 90 countries. Our supply chain consists of external businesses, self-employed consultants and business partner organisations located within the UK and overseas.
Assessing and Addressing Risks of Modern Slavery
The Group is committed to the principle that all humans have the right to be free from violence, abuse, and exploitation of any kind. Further, we embrace and respect the cultural and social diversity of the countries in which we work and place great importance on operating with honesty and integrity. As such, we do not tolerate, condone or accept human rights abuses within its business operations or supply chains.
The nature of our work, particularly in developing, and post-conflict countries means we recognise that some of our supply chains operate in high-risk environments for modern slavery including countries with high levels of poverty, a lack of awareness and understanding of human trafficking and modern slavery, and weak national systems to monitor and respond to human rights abuses including incidences of modern slavery.
Across our operations, we are working to build a supply chain that is free of modern slavery through diligently and regularly updated policies, guidelines, business processes, training and other mechanisms to detect and prevent modern slavery.
Governance Framework
Overseen by our Chief Diversity Officer and Executive Officers, the Group’s activities operate under a Sustainable Business Framework with policies, guidelines, standard operating procedures, business processes and tools that cover Diversity and Inclusion, Safeguarding , and the Environment which, although distinct fields, have shared goals and commitments.
Within this framework, the Group’s Code of Conduct expressly prohibit the transportation, sale or otherwise trafficking of human beings for profit or otherwise. Regardless of the jurisdiction in which the organisation is registered or doing business, these activities are prohibited. In addition, the Group’s representatives and Business Partners must not: 1) Allow transactions with, and the provision of resources and support to, individuals and organisations associated with human trafficking; 2) Procure any sex act on account of which anything of value is given or received (commercial sex act); and 3) Use forced labour in the performance of any work.
Our overarching governance structure also includes the following policies and guidelines relevant to the Group’s commitment to mitigate, and where possible, eradicate circumstances conducive to modern slavery:
Policies
Guidelines
The requirements of these policies and procedures are passed down to our Business Partners (suppliers, subcontractors, consultants) through a Business Partner Code of Conduct which must be acknowledged with every Group contracting agreement.
These governance documents are regularly reviewed and updated for currency and compliance.
Reporting against our KPIs
In 2020 we committed to report against corporate KPIs in our annual slavery statement. These KPIs include ambitions to train staff and raise corporate awareness of modern slavery, improve internal reporting mechanisms of incidents of modern slavery, and build the capacity in our supply chain to improve their modern slavery policies. In 2023 we sought to increase the ambition of these KPIs.
Details of our KPIs and in-year performance are detailed below.
KPI 1: Training and capacity building of UK employed staff on modern slavery issues and awareness.
Target: 80% of UK employed permanent staff attend online training, completing a test before and afterwards to record whether their understanding of the issues and awareness has increased.
Achievement to Date: Modern slavery is covered within our mandatory annual code of conduct training module available on our Learning Hub. As of December 2023, 177 (98%) of UK-based staff have undertaken the modern slavery training as part of this code of conduct mandatory annual training.
In May 2022 we designed stand-alone corporate Modern Slavery training. We had aimed to get this published on our Learning Hub in 2023, but this was delayed and is something we will aim for all UK staff to have access to in 2024 via the Learning Hub.
The training modules were also adapted for projects and specifically for downstream grantees to use. This was piloted and tested with UK funded programme teams and 26 grantee organisations in Colombia, Mexico, South Africa, Malaysia, Indonesia, and Kenya under Palladium’s UK Partnering for Accelerated Climate Transitions (UK PACT) programme funded by the UK Foreign, Commonwealth and Development Office (FCDO). The training was modified in response to feedback, with the main revision being the inclusion of the reading list for further research.
The training includes an overview of the global situation of modern slavery, training on how to identify those at risk; it emphasises the responsibility to report and provides instructions on how to report. The training also provides resources so that trainees can use to find data on the prevalence of modern slavery in specific countries, as well as the national legislation and context-specific vulnerabilities.
In 2024 we aim to update this project level training and encourage other projects to embed it as part of their due diligence on grantees.
KPI 2: Whistle-blowing hotline and reporting mechanisms monitored for cases involving modern slavery and cases dealt with appropriately and efficiently.
Target: 100% of cases recorded through reporting procedures handled appropriately and efficiently.
Achievement to Date: All safeguarding incidents reported were investigated and found to be unsubstantiated. None of these incidents reported to the hotline were attributed to Modern Slavery. As we move to using Navex EthicsPoint, we will have clearer definitions to categorise reported incidents so will be able to continue to monitor the data and report on this KPI in 2024 more easily.
KPI 3: Capacity building our major suppliers to develop modern slavery policies.
Target: 80% of Tier 1 suppliers , without a modern slavery policy or guidelines develop these documents within the first year of being contracted by Palladium.
Achievement to Date: All suppliers and contractors are required to pass our due diligence assessment before being contracted. Suppliers submit their due diligence through our online tool which allows for the instant monitoring of supplier due diligence for the entirety of their contracts. Through 2023 we continued to support grantees and subcontractors to develop and refine modern slavery policies and guidelines. As part of the due diligence assessment at the beginning of the supplier/contractor contracting process and during the contract term, we ask suppliers/contractors to confirm their compliance with the Act. We share a link to our policies as standard during the contracting process when suppliers are asked to accept compliance with our Business Partner Code of Conduct.
Alongside this we are also working closely with grantees on our projects to improve their awareness of modern slavery in their supply chains. One example of such collaboration is demonstrated on our UK PACT programme where, as of December 2023, 20 grantees have developed modern slavery policies with Palladium’s guidance and 35 grantees have used our modern slavery training to either develop their own training or use ours to train all project staff, including their consortium partners.
Ambition for 2023
1. Refreshing research to better understand the changing risk profile.
In 2024 we will continue to take a risk-based approach when reviewing our supply chain (based on the changing profile of our business) for potential intersections with modern slavery. We will refresh our desk-based research to understand where the highest risks may be in our supply chain and in such cases mandate a more rigorous due diligence which must include positive engagement with the supplier. This will help us to raise awareness of modern slavery across our supply chain.
2. Enhancing reorting mechanisms.
In 2022 we setup a new risk and issue registry (IRR) to standardise the way that risks and issues are managed across the Group. In 2023 we increased its functionality to allow for the anonymous reporting of safeguarding incidents including modern slavery, adding an additional reporting pathway for staff. The IRR is now used across the Group to proactively identify risks including those related to safeguarding and modern slavery.
In 2024, we are rebranding our Whistleblower hotline to our “Integrity and Protection Hotline” and transferring our case management system to Navex EthicsPoint. This increases the intake methods for reports, improves the language capabilities for reporting and also given the hotline will be staffed by a third party allowing true anonymity when making a report. Navex is the industry leader in this space, and we are very excited for this to go live around 1 April 2024.
3. Reviewing our purchasing practices.
We are confident that our employment practices protect staff against poor working conditions. We know that precarious work in low-paid, unregulated labour sectors can create conditions for labour abuses to develop, sometimes leading to extreme exploitation and forced labour. We know that these vulnerabilities were exacerbated by the impact of COVID-19 and the surrounding restrictions, and again with impending recession in many of our countries of operation. In 2024, we will review our purchasing practices, particularly in the purchase of electronics, where the risk of modern slavery in the supply chain is higher. When setting up a new supplier we will look at their modern slavery statements in detail and encourage them to provide us with a delivery chain risk map to help them identify any possible. We will also direct them to useful resources to help them improve their own understanding, identifying and preventing modern slavery, such as the Responsible Sourcing Tool (https://www.responsiblesourcingtool.org/)
4. Improving staff training and awareness.
We know that employees are better able to protect themselves against abuses such as poor working conditions and low pay when they are aware of their rights. Through our work in the field of international development, Palladium delivers job creation programming to educate communities about fair wages and employment rights internationally and in the UK. As part of our contracting with Tier 1 suppliers we confirm each organisation’s commitment to our Business Partner Code of Conduct. This includes our expectations for upholding and protecting the rights of employees.
In 2024 we will review and update our Modern Slavery training and guidelines to confirm they have the most up-to-date data. We will ensure that all staff and projects have access to this updated version through our SharePoint site and that they flow them down to suppliers and grantees, through their due diligence process, particularly to those who do not have their own training and policies in place, to help build their awareness and capacity.
We will continue to collect data and report against our corporate KPIs.
Key achievements to date
In 2018 we developed and published our Modern Slavery Guidelines. These Guidelines provide further information and guidance on the implementation of our Code of Conduct Policy with regards to the prevention of all forms of Modern Slavery and Human Trafficking. The Guidelines are applicable globally to all of Palladium’s operations, staff and all representatives of the company.
We strengthened our risk assessment policy to ensure that we assess the potential risk of modern slavery and human trafficking in our business development pipeline. Risk assessment is widely based – assessing country risk, industry or product risk as well as supply chain risk.
Palladium became a participant of the UN Global Compact on the 22nd January 2018. Palladium is committed to the UNGC initiative and its universal principles and we are building on this to embed these principles in our day-to-day operations and strategy for future growth.
We established reporting mechanisms outlined in Palladium’s Investigation SOPs and included the need to immediately report any suspected or alleged instances of Modern Slavery, Human Trafficking or Code of Conduct non- compliance using the Company Whistle-blower Hotline: Email: tellus@thepalladiumgroup.com. The whistle-blower hotline is advertised in all offices from which Palladium does business.
In our 2018 statement we committed to improving our due diligence practices to help us to gather greater information about our supply chain and to build the capacity of our supply chain in this area.
In 2019 we strengthened our due diligence process by moving to an online system for all of our UK government funded work (which forms the largest part of our business). This allows us to track data from suppliers, ensures that all due diligence for every supplier is updated on a 6-12 monthly basis and that suppliers cannot slip through the cracks. We are also committed to carrying out spot-checks and ‘deep dives’ to gather further information about a supplier and their supply chains. We committed to working with suppliers to develop modern slavery policies where none exist or to strengthen these policies where necessary. Where suppliers are not fully compliant, they are required to provide an action plan highlighting gaps in their process and corrective action they are taking. Gaps identified during the due diligence process are revisited after an agreed period of time (up to 6 months) and, where a supplier fails to fulfil an action plan, we will consider further measures including the termination of our relationship.
Palladium started implementing its first anti-slavery programme and is the implementing partner for the Foreign, Commonwealth and Development Office (FCDO) Stamping out Trafficking in Nigeria (SoTiN) programme. SoTiN closed after 15 months due to the UK government’s overseas development assistance (ODA) spending review. However, learning from SoTiN has and will continue to be shared across the organisation to strengthen and contextualise the understanding of modern slavery.
We strengthened our Code of Conduct policy and launched our Sustainable Business Approach. This approach shows how Palladium brings together Diversity and Inclusion, Safeguarding and Environmental policies which, although distinct fields, have shared goals and commitments.
In 2020 we set corporate KPIs to train staff and raise corporate awareness of modern slavery, improve internal reporting mechanisms of incidents of modern slavery and capacity build our supply chain to improve their modern slavery policies. We continue to monitor the data against these KPIs.
In 2021 we piloted our training with staff and project grantees and received feedback that the training was useful and increased staff awareness of the issues. We setup a Modern Slavery Working Group formed by 10 staff from across the EMEA region who have specialisations in modern slavery programming, due diligence and corporate initiatives. This group will work to test and pilot initiatives that will help strengthen our response to minimising modern slavery within our supply chains.
In 2023 we asked providers to disclose their hiring practices as part of the online due diligence questionnaire ensuring that final procurement decisions considered these responses, whilst ensuring that staff security remains central to all decision making.
This statement under the Modern Slavery Act 2015 was approved by the Board of Directors of Palladium International Limited on 21 March 2024.
Sinead Magill
Executive Officer
Palladium International Limited
Archived Statements:
Modern Slavery Statement 2023
Modern Slavery Statement 2022
Slavery and Human Trafficking Statement December 2020 - 2021
Slavery and Human Trafficking Statement December 2019 - 2020
Slavery and Human Trafficking Statement December 2018 - 2019