This statement is designed to satisfy the requirements of Section 54 of the Modern slavery Act 2015 (the “Act”), by setting out the approach of the British Council to modern slavery, human trafficking, forced labour and labour rights violations in its supply chains.
We continue to take our responsibility to prevent modern slavery and trafficking within our supply chain seriously.
1. Our status, operations, and supply chain
- The British Council is registered as a charity under registration numbers 209131 (England and Wales) and SC037733 (Scotland) and is incorporated by Royal Charter.
- We work in over 100 countries connecting millions of people with the United Kingdom through programmes and services in the English language, the arts and education.
- This statement relates to the British Council and its subsidiary entities.
- The British Council has a diverse and substantial supply chain, with sourcing carried out both centrally and within local markets across the globe and is guided by its corporate policies.
2. Current procurement policy and processes
2.1 The British Council follows UK public sector procurement legislation and ensures that all potential and incumbent suppliers are dealt with professionally, fairly and ethically and that we always uphold the principles of sustainable procurement. Our procedures also comply with law and address environmental management, health and safety, social value and equality legislation.
2.2 Suppliers are evaluated on criteria including their approach to risk; environmental sustainability; health and safety; social value; modern slavery and safeguarding.
2.3 We require our suppliers and their supply chains to maintain their standards while supplying us. We have a variety of channels both internal and external facing which facilitate the raising of concerns over supplier behaviour.
3. Due diligence process
3.1 We have implemented a risk-based modern slavery due diligence framework that assesses suppliers by both spend category and service delivery location, enabling enhanced scrutiny in sectors and regions where the risk of labour exploitation is highest.
3.2 Suppliers identified as higher risk are subject to enhanced due diligence through our Enhanced Modern Slavery Questionnaire, which assesses areas including governance, recruitment practices, workforce composition, subcontracting, grievance mechanisms, training, monitoring and remediation.
3.3 The approach is tailored to sector-specific risks, with targeted questions for categories such as construction, cleaning, security, accommodation, ICT hardware, catering and event management. It is designed to be proportionate and not create unnecessary barriers for SMEs, focusing instead on securing meaningful commitments to address modern slavery risks. Where appropriate, these commitments are incorporated into contractual obligations and monitored throughout the contract lifecycle through evidence-based reviews and audit activity.
3.4 We consider our principal modern slavery risks to arise within those supply chains that are labour-intensive and characterised by outsourced service delivery, subcontracting, and the use of temporary labour. Based on our assessment of spend and sector risk, the areas of greatest potential exposure are Soft FM services, including Cleaning, Security Services and Catering, and Temporary Labour. We also recognise the risks associated with global manufacturing and service supply chains, particularly within IT Hardware, Event Management, and travel-related categories.
4. Identifying and managing risks
4.1 The Modern Slavery Working Group has met on a weekly basis for the past year. The team has developed key governance documents and contributed to the development of the risk-based modern slavery due diligence framework.
4.2 The British Council’s modern slavery reporting channel now sits within its case management system. Individuals can raise concerns through multiple accessible reporting routes, including dedicated telephone helplines with local country numbers, an online reporting portal, and a digital reporting platform accessible via QR codes. These channels are designed to support confidential reporting and improve accessibility for workers, suppliers and other stakeholders who may wish to report suspected instances of modern slavery or labour exploitation.
4.3 The group’s work is supported by a governance pathways document. This governance document helps to form the basis of our pathways to remediation should an incident of modern slavery arise. Through defined escalation pathways, the Group ensures that modern slavery risks are assessed consistently, appropriate mitigation and remediation measures are implemented, and procurement decisions reflect our commitment to preventing modern slavery in our operations and supply chains.
4.4 Supplier non-compliance with commitments made during a procurement process is managed in line with our Modern Slavery Governance Pathway. Concerns are escalated to a Procurement Director, who works with the Modern Slavery Working Group to determine and implement the appropriate remediation plan. Where a case of suspected modern slavery is reported through the whistleblowing channel, it is treated as both a safeguarding and human rights issue. In accordance with the Governance Pathway, a cross-functional response team, comprising Procurement, Safeguarding, Legal and other specialist functions as required, will assess the risk, determine any immediate safeguarding actions, and coordinate a timely and effective response. The Modern Slavery Working Group reports to the Chief Procurement Officer, who has responsibility for overseeing escalations and ensuring appropriate action is taken in response to identified risks. Ultimate senior leadership accountability for the modern slavery programme sits with the Chief Operating Officer, who provides executive oversight of the programme and its effectiveness.
5. Training
5.1 The British Council launched a new eLearning course, Raising Awareness of Modern Slavery and Human Trafficking, to strengthen organisational capability in identifying and responding to modern slavery risks. The training equips staff to understand their responsibilities and recognise potential indicators of exploitation.
5.2 Procurement colleagues were required to further strengthen their capability by completing the UK Government Commercial College e-learning course, Key Skills for Tackling Modern Slavery in Public Supply Chains. Developed by the Home Office Modern Slavery Unit and the Joint Security and Resilience Centre, the programme provides practical guidance on identifying modern slavery risks, undertaking effective supplier due diligence, assessing supplier assurances, and implementing appropriate mitigation and remediation measures throughout the procurement lifecycle.
6. Key performance indicators (KPIs)
6.1 Since the launch of the e-learning course Raising Awareness of Modern Slavery and Human Trafficking, 95% of British Council colleagues have successfully completed the training. During the reporting year, 100% of procurement colleagues completed the UK Government Commercial College modern slavery course.
6.2 In this reporting year, October 2025 to September 2026, 74 strategic suppliers completed a modern slavery due diligence assessment. Responses were reviewed as part of our supplier assurance process and, where appropriate, follow-up discussions were undertaken to clarify responses and obtain additional assurance that suppliers' policies, risk management arrangements, and training provisions met the standards set out in the assessment. No significant concerns were identified through these reviews or subsequent discussions, and no suppliers were excluded from any procurement process as a result of the assessments undertaken during the reporting period. While this assessment has now been superseded by our Enhanced Modern Slavery Questionnaire, it will continue to be used where it complements the enhanced approach. Completion rates and outcomes will be monitored to support ongoing oversight of modern slavery risks.
6.3 In the next reporting year we will focus on a targeted communications campaign to promote our whistleblowing channel and ensure it is accessible to both our employees and those working within our supply chain. Engagement will be through either direct engagement with supplier employees or via British Council colleagues who have regular contact with those workers, and report progress through our modern slavery governance process. We also aim to strengthen collaboration with Internal Audit to support our Enhanced Modern Slavery Questionnaire. Through Internal Audit assurance processes, we will assess whether supplier commitments are being delivered throughout the contract lifecycle.
6.4 In terms of training for the next reporting year. Procurement colleagues will complete training on the Enhanced Modern Slavery Questionnaire. This training will equip procurement leads with the knowledge and tools to assess supplier responses effectively and develop proportionate remediation plans where risks or gaps are identified. It will also support our reporting framework, enabling the collection of robust data on the risks and the actions taken to mitigate them. To strengthen the work of the Modern Slavery Working Group, members will complete training on effective engagement with suppliers and their employees and then work to build capacity in this area across the organisation.
Next steps
The British Council is committed to continuous improvement in this area and will review and monitor and, where necessary, enhance our standards, policies and procedures, as well as improve the training and communications about The Act.