Slavery and Human Trafficking Statement

Slavery and Human Trafficking Statement

Financial Year December 2016 – November 2017


Under the UK’s Modern Slavery Act 2015 Mannion Daniels Limited (MannionDaniels) is required to publish a Slavery and Human Trafficking statement for each financial year. MannionDaniels is committed to enforcing anti-human trafficking and anti-slavery practices worldwide. We take a zero-tolerance approach to modern slavery and enforce effective systems and controls to ensure modern slavery and human trafficking is not taking place in our business or within our supply chain. MannionDaniels recognises that our success is very much dependent on the qualities and attributes of our employees, business partners (subcontractors, consultants, vendors, suppliers, grantees and clients) and our associates throughout our supply chain. We will only engage with business partners and associates who demonstrate a serious commitment to health and safety and operate in compliance with human rights laws. MannionDaniels is also now a signatory to the United Nations Global Compact. We support the ten principles of the UN Global Compact with respect to human rights, labour, environment and anti-corruption.

Our Organisation

MannionDaniels is a UK registered limited company. We work within the international development sector with a focus on public health, health systems and sustained poverty reduction in marginalised and vulnerable communities.  MannionDaniels supports governments, communities and other organisations by providing professional advice and services in policy, strategic planning, governance and programme management. Our teams work with many partners, consultants, stakeholders and civil society organisations across sub‐Saharan Africa and South Asia. For the financial year ending 2017, approximately 54 staff worked for MannionDaniels in our UK offices.

Our Polices in relation to Slavery and Human Trafficking

At MannionDaniels, we are committed to ensuring the highest standards of conduct in the delivery of our services. This is reinforced by our business code of ethics which outlines our steadfastness to upholding ethical values and practices. MannionDaniels’ directors have assessed our policies and procedures in relation to slavery and human trafficking, and our approach to managing our suppliers. Given the nature of our work with collaborators working across many difficult environments, we have revised our policies or developed new ones to promote ethical standards and to identify and mitigate risk, including modern slavery and human trafficking. The updated business code of ethics and complementary policies have been made available to all staff. All MannionDaniels staff are expected to review, understand and adhere to the policies and procedures.

The key policies and procedures that relate to mitigating risks of modern slavery and human trafficking in our business and supply chain include:

  • Business Code of Ethics – MannionDaniels has a business code of ethics to maintain a standard of conduct that is acceptable to the company. It applies to all employees, business partners, beneficiaries, associates and all stakeholders. We have now outlined our stance on anti-slavery and anti-human trafficking in the updated business code of ethics as well as our expectations and acceptable behaviours for all our stakeholders in relation to this
  • Modern Slavery Policy – We have developed a new modern slavery policy. The policy highlights that we do not condone use of forced labour and human trafficking and details measures, responsibilities and structures for identifying and mitigating risks of modern slavery in our business and supply chain. It also emphasises that we will not knowingly engage with business partners and associates who violate these laws
  • Due Diligence Procedure – We apply a structured and proportionate methodology to identify and assess risks in our supply chain. Our due diligence procedure requires assessment of policies for suppliers and mapping of our supply chain. We also establish baselines upon which to monitor suppliers and agree improvement plans for them, where needed
  • Procurement Policy – Our procurement policy sets a high level of expectations and acceptable practices for the procurement of goods and services on behalf of the company. We work collaboratively with and provide support to our internal teams and suppliers in their compliance with all our requirements and standards on human rights, discrimination and global labour standards
  • Whistleblowing Policy – MannionDaniels’ whistleblowing policy is publicised widely. It outlines our commitment to upholding ethical values and practices and promotes a business culture that enables staff, business partners and others to feel comfortable raising concerns without fear of retribution. The policy is supported by an anonymous, free-to-call and confidential service, which allows for the reporting of concerns including on modern slavery and human trafficking through a safe and secure mechanism


Training is fundamental to raising awareness of these slavery and human trafficking issues. We provide training on our business code of ethics and other policies. We are reviewing training which is intended to provide staff with an understanding of modern slavery and human trafficking as well as our obligations under the Act. Such training will be rolled out to staff and key stakeholders, who will be identified by our Operations and Compliance Team.

Effectiveness of our policies

We take seriously our obligation to monitor our effectiveness in this area. MannionDaniels investigates complaints about modern slavery and human trafficking relating to our programmes and business operations and takes prompt corrective action where warranted. We are also committed to continually measuring and improving our policies. We have dedicated teams that work closely with our supply chain to ensure transparency and to monitor compliance with our standards and policies. This includes adherence to the International Aid Transparency Initiative (IATI). We undertake internal reviews of our approach on a frequent basis and have key performance indicators in place for the provision of support and capacity building that we provide to our supply chain.

Matthew Wiltcher, Head of Operations

Matt Wiltcher