Modern Slavery Statement

Modern Slavery and Human Trafficking statement as required under S54 of the Modern Salvery Act

Introduction

Abellio East Midlands Railway Limited is registered in England and Wales, company number 0986048. Registered Office address, 2nd Floor St. Andrews House, 18-20, St Andrew's Street, London EC4A 3AG. Abellio East Midlands Railway Limited (Trading as “East Midlands Railway”) is a train operating company, running passenger services across the East Midlands. East Midlands Railway (EMR) employee over 2,490 people across a diverse range of roles from train driving, engineering, customer service and management. EMR is part of a wider transport group, Transport UK. Transport UK previously Abellio have been running the EMR franchise since August 2019, and in October 2022 the Department for Transport (DfT) agreed a new National Rail Contract (NRC) for East Midlands to operate services until 2026.

Commitment

East Midlands Railway Limited (“EMR”/ “us”/ “we”/ “our”) are committed to ensuring that all its business dealings are carried out in full compliance with relevant laws and, in doing so, we endorse the implementation and promotion of ethical business practices to protect workers from being abused and exploited both within EMR and its supply chains. EMR are committed to improving our practices to combat modern slavery and human trafficking and continue to take significant steps to promote and improve our ongoing commitment to eliminating abuse and exploitation in the workplace as detailed in this Statement. This Statement sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our business or supply chains.

This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and is reviewed on a regular basis.

Organisation Structure

EMR is divided into the following structure:

  • Commercial
  • Customer Services
  • Finance
  • Fleet
  • HR
  • Operations
  • Transition and Projects

EMR is part of the Abellio group, which consist of five UK purchasing departments, all work together to share knowledge and best practice to support each other.

Working Practices

EMR are fully compliant with UK Legislation and as a Real Living Wage accredited employer, all EMR colleagues are paid at least the Real Living Wage.

EMR have a suite of policies and procedures to ensure that all colleagues are treated with dignity and respect regardless of gender, race, religion, ethnicity, age, sexual orientation, national origin, disability or any other protected characteristic. Colleagues are employed into EMR on their ability to perform in their role and not based on their personal characteristics or beliefs.

EMR work very closely with the Trade Unions on several matters such as policies, pay, working conditions etc. and all colleagues have the right to join a Trade Union if they wish to do so. EMR recognise four Trade Unions; Associated Society of Locomotive Engineers and Firemen (ASLEF), The Rail, Maritime and Transport Workers Union (RMT), the Transport Salaried Staffs' Association (TSSA), Unite the Union (Unite). EMR complies with all UK laws pertaining to freedom of association and collective bargaining, and our people policies are agreed at our Company Council with Trade Union representatives.

Policies

All EMR colleagues have access to EMR’s whistleblowing policy which enables them to raise any concerns that they may have in a private and confidential manner.

We have clear and rigorous HR policies and procedures and high standards for employees that minimise the risk of any form of modern slavery existing within the organisation.

We have procedures and policies in place on all major employment issues - for example disciplinary, grievance, harassment and bullying, code of conduct, confidential reporting procedures, as well as other procedures and policies that support fair treatment of employees including attendance management and ill health capability, performance capability, colleague appraisals and recruitment and selection.

Recruitment

We have robust recruitment procedures in place for vetting new employees, which ensures they can confirm their identities, any appropriate qualifications and they are paid directly into an appropriate personal bank account, with employment references being sought. All prospective employees are asked to supply evidence of their eligibility to work in the UK as compliance with UK legislation.

Agency workers

Any agency staff used will have been sourced via verified agency’s ensuring their practices match our own including fair pay and working conditions.

Employee code of conduct

All employees, contractors, agency staff and volunteers must abide by our code of conduct, which makes it clear the actions and behaviours expected of them when representing EMR. Any breaches are investigated with the support of HR and may result in action against the individual.

Procurement

EMR has a supply chain of over 600 suppliers ranging across a wide variety of services such as manufacturing, train parts, catering, uniform, support services (such as cleaning of stations, vehicles and depots) and IT services. Most of the construction related suppliers are accredited via the RISQS (Railway Industry Supplier Qualification Scheme) scheme with NEC4 (New Engineering Contract 4)Terms and Conditions. EMR operate an in-house procurement team who primarily manage relationships with suppliers. The procurement team works within a Category Management structure with the following categories

  • Fleet
  • Indirect including Infrastructure
  • IT

EMR fully accept responsibility to work with the supply chain to ensure that expectations around modern slavery are fully met. These expectations are as follows:

  • Suppliers will set wages, working hours and working conditions in accordance with applicable legislation. This includes the requirement to pay staff at least the Real Living Wage.
  • Suppliers shall not use, or permit within their supply chain, any indentured or forced labour, slavery or servitude.
  • Suppliers shall treat all employees with dignity and respect and will not engage in any form of harassment.
  • Suppliers shall only employ staff who meet the minimum applicable age requirement. Under no circumstances should suppliers employ anyone under the age of 16 (with the exception of those employed on a registered Apprenticeship Scheme), even if local laws permit otherwise.
  • Suppliers shall select and employ workers only on the basis of their ability to do the job and not based on any personal characteristics or beliefs.

The procurement team ensure the following due diligence to reduce the risk of any Modern Slavery within our supply chain.

  • Staff whose primary job function is Procurement are either qualified Members of the Chartered Institute of Procurement and Supply (MCIPS) or are actively working towards the qualification. A code of ethics is in place, which requires all MCIPs professionals to foster awareness of human rights, fraud and corruption issues in the supply chain.
  • The assessment of supplier awareness and implementation of the Modern Slavery Act 2015, see below.

Modern Slavery Act 2015: Requirement under the Modern Slavery Act 2015 asks the following questions:

“Are you a relevant commercial organisation as defined by section 54 ("Transparency in supply chains etc.") of the Modern Slavery Act 2015 ("the Act")?” Response: Yes or N/A.

“If you have answered yes to Question 7.1 are you compliant with the annual reporting requirements contained within Section 54 of the Act 2015?” Response: Yes…..Please provide the relevant URL to view the Statement. Response: No……Please provide an explanation.

Note: All answers are scored on a PASS / FAIL basis.

The Supplier Selection Questions also include instructions to bidders regarding the applicability of response to consortium members or subcontractors as follows:

“If you are bidding on behalf of a group (consortium) or you intend to use sub-contractors,you should complete all of the selection questions on behalf of the consortium and / orany sub-contractors”

Training and future actions

  • Training will be implemented across the organisation on Modern Slavery and identifying the risks.
  • The procurement team will continue to work with suppliers on the importance of Modern Slavery through contract review meetings.
  • Terms and Conditions will make clear reference to Modern Slavery
  • Staff whose primary job function is Procurement will undertake continual professional development on Modern Slavery and Protecting Human Rights in the Supply Chain.