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Modern Slavery Act 2015 (“the Act”) Statement (“Statement”)

About us 

The Commonwealth War Graves Commission (“CWGC”) is a Royal Charter organisation which commemorates, in perpetuity, Commonwealth service personnel who fell in the First and Second World Wars. We have six member governments: Australia, Canada, India, New Zealand, South Africa, and the United Kingdom.

Applicability of the Modern Slavery Act

As at the date of this Statement, the Act contains criteria which, where satisfied, oblige an organisation to make a Statement. Whilst these criteria may not apply to the CWGC (and so may not oblige the CWGC to make a Statement), we unequivocally agree with the objectives which underpin the Act, and we therefore wish to make a Statement to set out the steps the CWGC is taking in relation to the detection and prevention of modern slavery and human trafficking.

Context for this Statement

This Statement was completed in December 2021 and relates to our financial year 2021/2022 (noting that our final year runs 1st April to 31st March in each year), with actions established for the financial year 2021/2022 and for the end of the calendar year 2022. We will publish an update to this Statement after the end of our 2022/2023 financial year (therefore after March 2023). In this Statement, we set out the initial steps that we have taken, which focus on an audit of our operations to understand where the potential for risk of modern slavery or human trafficking exists, as identified in the Risks below. We will, from time to time, update this Statement (and noting that the Modern Slavery Act contemplates annual updates at the end of each financial year, but, as we are posting this Statement toward the end of our financial year, we would anticipate providing an interim update in the summer of 2022), to show our progress, in accordance with the KPI’s below.

Our Commitment

We oppose slavery and human trafficking in all its forms, and we are committed to acting ethically and with integrity in all our relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking does not take place in our operations or supply chain. 

Organisational Structure and Supply Chain

Organisational Structure

Supply Chain

By way of broad overview of our operations and supply chain:


In support of this Statement, we will issue guidance and training as to the detection and prevention of slavery and human trafficking, to ensure that our commitment (as set out above) is broadly articulated, well understood by all who work for or with us and is integral to our operations.  This will include both a policy for employees and suppliers (as part of which, we will consider an Ethical Dealing policy/code of conduct for suppliers).  We have included the creation and implementation of this guidance/policies as a KPI (see below). 

Due Diligence

In preparing this statement, we have carried out initial due diligence on our operations and supply chain and have identified potential areas of risk (see Risks below), which will be the focus of our due diligence and action in the next financial year.   

Risk Assessment and Management

We recognise the potential for modern slavery and human trafficking exists in our operations and supply chain.  By way of overview:

Actions the organisation has taken to prevent slavery and human trafficking in our business or supply chain measured against performance indicators.

In conducting initial due diligence to support the provision of this Statement, and assessing where risk might exist, we have not detected any issues which would lead us to conclude that modern slavery or human trafficking is present in our operations or supply chain.   However, we recognise that the work beyond our initial diligence, as set out in the KPIs (below) is required to enable us to better understand risks and then be able to take such additional steps as are required to manage these risks.

Key performance indications ("KPIs")  


Measurement target - Financial Year End 21/22 (31 March 2022) or by Calendar Year End 2022 (31 December 2022)

Fully audit our operations on a risk-based prioritisation, beginning with Africa and Asia and addressing the procurement of labour services and the provision of accommodation in these continents (noting that audit beyond Africa and Asia will be undertaken subsequently).  

Africa and Asia by the end of Financial Year 2022

Review and where required enhance contracting standards (so that, for new suppliers, when we procure goods and services, our suppliers are always subject to a contractual obligation to comply with the Act) 

100% by the end of Financial Year 2022

Review on a priority basis existing contracts to ascertain if these contain appropriate wording re compliance with the Act

80% plus by the end of Year End 2022

Review procurement policy to ensure that it deals appropriate with the requirements of the Act

100% by the end of Financial Year 2022

Implement a policy for Modern Slavery Act compliance for our suppliers (potentially as part of an Ethics Policy), with publication of this policy on our website and distributed as part of the contracting process with new contracts (noting that auditing compliance against this policy will commence in a subsequent financial year)

100% by the end of Financial Year 2022

Implement a policy for Modern Slavery Act compliance for our staff (potentially included in Ethics Policy).  

100% by the end of the Financial Year 2022

Implement a training programme for our staff, to ensure that all staff are aware of the Act, and of our policy, and how it might impact on our operations and supply chain and how to spot and report potential issues

100% for implementation of training programme by the end of the year 2022, with 90% plus of staff trained within this period.  


As per the KPI above, to ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we will, over the course of the financial year 2021 to 2022, develop and implement a training programme, to raise awareness of the potential for modern slavery and to ensure that where risk has been identified, our employees who are closest to that risk are trained specifically (including to recognise the risk of modern slavery).   

Raising concerns and Whistleblowing

We have implemented, via third party supplier Safecall Limited, a global “hotline” which supports colleagues and others to raise concerns about our organisation and operations (Safecall Limited provide in-country telephone numbers).  We have also implemented a Whistleblowing Policy, which ensures colleagues and others know that the CWGC embraces a “speak out” culture.  We will ensure that this service and policy is available, and that colleagues and others have access to it so that there is certainty and confidence as to identifying and raising concerns (including as to modern slavery and human trafficking). 

This Statement is made in connection with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 31 March 2022. It has been approved by the CWGC’s Executive Management Team. 

Claire Horton CBE

Claire Horton CBE

Director General


Date: 10 December 2021

Statement updated 29 November 2022, to add that we will be publishing our updated Statement after the end of our financial year 2022/3, therefore after March 2023.