Modern Slavery Statement

This statement applies to Transport for Wales (TfW) and its subsidiaries and refers to our strategic approach to managing Modern Slavery.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and outlines the steps Transport for Wales (TfW) and its subsidiaries have taken to prevent modern slavery and human trafficking in our operations and supply chains. It reflects our commitment to ethical employment, fair work, and socially responsible procurement, aligned with the Well-being of Future Generations (Wales) Act, the Social Partnership and Public Procurement Act 2023 (SPPPA), and the Procurement Act 2023.

Transport for Wales is a not-for-profit company wholly owned by the Welsh Government. We are responsible for delivering a safe, integrated, accessible, and sustainable transport network across Wales and the Borders. Our operations span rail, bus, active travel, infrastructure development, and innovation services, delivered through subsidiaries including Transport for Wales Rail Ltd, TfW Innovation Services Ltd, Pullman Rail Ltd and TfW Ffeibr Ltd.

TfW’s registered office address is 3 Llys Cadwyn, Pontypridd, Rhondda Cynon Taf, CF37 4TH.

TfW considers that modern slavery encompasses:

• Human trafficking.
• Forced work, through mental or physical threat.
• Being owned or controlled by an employer through mental or physical abuse or the threat of abuse.
• Being de-humanised, treated as a commodity or being bought or sold as property.
• Being physically constrained or to have restrictions placed on freedom of movement.

TfW recognises modern slavery as a serious human rights violation and a significant business risk. We are committed to taking meaningful action to identify, prevent, and address modern slavery risks across our operations and supply chains. We uphold a zero-tolerance approach to exploitation and unethical employment practices and strive to embed ethical standards into our business as usual.

TfW doesn’t enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to TfW in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. TfW strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation and, in many cases, exceeds those minimums in relation to its employees.

Our Chief Commercial Officer holds overall accountability for modern slavery compliance.

The Commercial Contracts Director leads operational delivery.

The Head of Supply Chain acts as TfW’s Modern Slavery Compliance Officer, responsible for risk assessment, due diligence, and reporting.

A cross-functional Socially Responsible Working Group (SRWG) has been established to drive compliance, embed ethical standards, and align with relevant legislation.

TfW has in place or is developing policies on the following policies to support our modern slavery strategy:

• Whistleblowing
• Code of Conduct
• Recruitment & Selection
• Sustainable Procurement and Supply Chain Management
• Health, Safety & Well-being
• Equality, Diversity & Inclusion
• Anti-Money Laundering and Counter Fraud
• Grievance
• Ethical Employment

We are a Living Wage accredited employer and have signed up to the Welsh Government’s Code of Practice: Ethical Employment in Supply Chains and encourage our supply chain partners to sign up to this code and take action to eliminate the inappropriate use of zero-hours contracts. TfW is also committed to eliminating false self-employment practices, umbrella contracts and union blacklisting in accordance with the Code of Practice.

TfW’s supply chain includes direct and indirect suppliers across transport, infrastructure, facilities management, IT Equipment, material supply and textiles.

The main supply chains of TfW currently relate to the delivery of the rail service in Wales and the Borders and construction/engineering work to develop sustainable transport infrastructure. TfW’s first-tier suppliers are intermediary traders and therefore have further contractual relationships with lower-tier suppliers.  We recognise that lower-tier suppliers may present higher risks.

To help monitor adoption of the Code of Practice and to specifically address issues relating to modern slavery, TfW has appointed a Head of Supply Chain to help resolve disputes in the supply chain and identify any potential breaches of the Code of Practice.

We have undertaken a comprehensive gap analysis aligned to ISO 20400 and developed a 16-step Modern Slavery Compliance Plan which we are working through as part of our newly established Socially Responsible Working Group. Key actions include:

• Mapping our supply chain to identify high-risk sectors, regions, and suppliers.
• Embedding robust due diligence in our procurement process as Business as Usual.
• Embedding modern slavery clauses in contracts, including termination rights.
• Implementing grievance mechanisms for workers and suppliers.
• Developing a Supplier E-Learning Pathway and training for TfW staff.

TfW considers its main exposure to the risk of slavery and human trafficking to exist in lower-tier supply chains, such as facilities management services and products procured involving the provision of labour in a country where protection against breaches of human rights may be limited.

In general, TfW considers its exposure to slavery/human trafficking to be relatively limited. Nonetheless, it has taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods, works and/or services.  Our Head of Supply Chain will play a major role in assessing risk through heat mapping and prioritising actions.

TfW has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, TfW has taken the following steps to ensure that modern slavery is not taking place:

• Established a Socially Responsible Working Group to advise TfW on actions needed during the procurement of all TfW contracts, including the rail services and infrastructure contracts.
• Established a governance structure to ensure leadership and accountability.
• Communicated the policy and approach to sustainable and ethical procurement during the bidding process and at supplier events.
• The Code of Practice of Ethical Employment in the Supply Chain is included at ITT stage of the procurement process, and contracts, and the supply chain is encouraged to sign up.
• Built sustainable and ethical procurement requirements into procurement, contract management arrangements and associated documentation.
• Delivered training to Commercial and Procurement personnel to ensure due diligence is embedded in our activities.
• Actively participate in Welsh Government Anti-Slavery Wales Forum, collaborating with NGOs, trade unions and industry bodies to strengthen our approach and share best practices.
• We have taken proactive steps, such as awarding our uniform contract to a local Voluntary, Community, and Social Enterprise (VCSE), to improve transparency and resilience.
• Developed a 16 step Modern Slavery Compliance Plan.

TfW’s approach to sustainable and ethical procurement has mitigated the risks associated with the supply chain but cannot eliminate them.

Our Head of Supply Chain will work with our delivery partners to ensure that modern slavery does not take place in the supply chain. We continually review and update our processes to ensure that we adequately address the risk of modern slavery in our supply chain.

Modern Slavery Compliance Plan

TfW is developing key performance indicators, to measure its effectiveness in ensuring that modern slavery isn’t taking place in the organisation or its supply chains.

Day-to-day responsibility for implementing our modern slavery and human trafficking commitments sits with the Head of Supply Chain, who oversees supplier engagement, risk assessments, and due diligence processes across our supply chains.

The Commercial Contracts Director provides oversight and support to ensure these actions are effectively integrated into our commercial practices.

Overall accountability for modern slavery risk management rests with the Chief Commercial Officer, who reports to the Board on progress, performance, and compliance with the Modern Slavery Act.

Sarah Jane Waith

Head of Supply Chain & New Markets 

Fiona Lewins

Commercial Contracts Director

Alexia Course

Chief Commercial Officer