The National Gallery Company Limited Modern Slavery Statement - revised August 2020
This statement sets out the National Gallery Company’s (NGC) actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business, supply chains, contractors or licensed partnerships. This statement relates to actions and activities during the financial year 01 April 2020 to 31 March 2021.
We recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we are thoroughly committed to preventing slavery and human trafficking in all our business activities and to ensuring that our supply chains, contractors and licensed partners are free from slavery and human trafficking.
NGC is a commercial company which contributes financially to the National Gallery. It is owned by the National Gallery Trust, a charitable body which generates and manages additional charitable contributions to the National Gallery.
NGC’s business activities are broad ranging and include the following activities:
- Retail operations in the National Gallery
- The National Gallery online shop
- The National Gallery Picture Library
- Publishing books, developing and sourcing merchandise based on the National Gallery Collection and exhibitions
- Licensing the National Gallery spaces for commercial event hire or filming
- Developing global brand partnerships with licensees or other retailers
- Managing commercial contracts with specialist restaurant and café operators
NGC employs 64 people comprised of retail employees based in the National Gallery stores, with the remaining employees working from home and making occasional use of our central office location in Trafalgar Square as required. Our product supply base is manufactured across 21 countries, consisting of c.200 suppliers. We now have 50 licensed partners, working across the UK, Europe, the US, China, Hong King, Taiwan, South Korea, Turkey, Bangladesh, Tunisia, Brazil, Mexico, Chile, Japan and Australia. In addition, we manage significant contracts with concessionaires e.g. Sodexo
OUR VISION, MISSION AND VALUES
Our Vision is to be The Best Museum Trading Company in the World
NGC’s mission is to Get the Message Out, Get the People In and Make Money for the Gallery
Our values are to be Enterprising, Ambassadorial and Smart
OUR SUPPLY CHAIN
- Our own brand books and merchandise are sourced from 13 countries across the world. 40% of our suppliers are UK based, and the rest are sourced from suppliers with factories in Europe, the US, Switzerland, India, Sri Lanka, Hong Kong and China.
- In addition, we source unbranded product from suppliers for sale in our shops and online from the UK, Europe, Turkey, India, China, Taiwan, South Korea, Thailand, Indonesia and The Philippines.
- We work with our brand licensees to develop ranges which will be sold to customers in the UK, Europe and across the world. Many of them work with factories in the UK, Europe, Turkey, Tunisia, Brazil, Mexico, Bangladesh, Japan, South Korea, Taiwan and China.
- NGC contract specialist companies for public catering concessions in the National Gallery.
Our own business policies relating to Modern Slavery are:
- Green Policy
- Whistleblowing Policy and Procedure
- Health and Safety Policy
- Equal Opportunities Policy
- Safeguarding Policy
- Anti-bribery Policy
- Dignity at Work Policy
- Lone Working Policy and Procedure
- Agency Workers Policy and Procedure
Our policies are designed to help our people consistently live our values and encourage them to report any disconcerting activity. Our Executive Team champion this and we continue to explore where we can introduce new policies and update existing ones. This includes our commitment to training for our staff, our supply chain and our licensed partners about the Modern Slavery Act and our responsibilities.
Our Human Resources team are responsible for developing and putting in place the relevant policies. Our policies are reviewed regularly by the Managing Director and we will, as required, further develop and implement effective auditing processes and reporting, and introduce remediation programmes with respect to solving grievances if we find them.
DUE DILIGENCE AND RISK ASSESSMENT
Our approach to due diligence is proportionate and risk based, with a view to reducing our risk of the occurrence of modern slavery and human trafficking in our supply chains. We focus on significant sized contracts (worth more than £50k) with suppliers, licensed partners and contractors. This group is provided with a copy of NGC’s Modern Slavery and Human Trafficking Policy and Statement, and is asked to provide NGC with confirmation of their own commitment to ensure compliance with the Modern Slavery Act 2015 within their own organisations and to seek to reduce the risk of modern slavery in their own supply chains. The supply chain categories are as follows:
- Non-Product Suppliers
- Product Supply Chain
- Concession Contractors
- Licensed Partners
If we are unable to obtain confirmation from the supply chain, we will move to terminate the contractual arrangements (where it is legally permissible to do so) or will decline to renew until compliance is assured. Any new contracts issued will include the appropriate contractual wording, committing our supply chain (worth more than £50k) to comply with the Modern Slavery Act 2015 and to include similar provisions in its own direct supply chains and contractors.
We make sure that the following groups are aware of the Modern Slavery Act 2015 and its requirements:
- Our largest suppliers worth over £50k
- Our Senior Management Team and all staff working with supply chains
- Our Board of Directors