Modern Slavery & Human Trafficking Statement
The Royal NAAFI 2025/26 Modern Slavery & Human Trafficking Statement
Introduction
The UK Modern Slavery Act 2015 (the ‘Act’) requires businesses to state the actions they have taken during the financial year to ensure modern slavery is not taking place in their operations and supply chains. At The Royal NAAFI we are fully committed to playing our part in eradicating modern slavery and firmly believe that full transparency and collaboration with all our external partners is the key to eliminate the risks
Our Business, Structure and Supply Chains
NAAFI, now The Royal NAAFI, was incorporated in 1920 when the Expeditionary Force Canteens (EFC) and the Navy and Army Canteen Board (NACB) were combined to run the Armed Forces recreational establishments and to sell goods to members of our services and their families. The Royal NAAFI is a UK registered, not-for-profit company, with five subsidiary companies in Poland, Estonia, United Arab Emirates, and the USA. All our subsidiaries are subject to our standard policies and under the direct control of the Royal NAAFI Executive.
The Royal NAAFI operates in the United Kingdom, Germany, Gibraltar, Brunei, the South Atlantic Islands, Oman, Bahrain, UAE, Iraq, Estonia, Poland, Romania, and on board HM Ships. We provide convenience shops, pubs, coffee shops, as well as catering and cleaning services to the British Armed Forces and their dependants.
We also undertake contract management services for the MOD. Our unique position within the British military community results in our ‘posted’ colleagues being subject to UK and host nation law wherever they are based as well as MOD regulations.
Our supply chains are straightforward forward a majority are limited to dealing with companies incorporated and based in Western European countries; specifically; the United Kingdom, the Netherlands and Germany. A key purpose of our business is to provide our service personnel “a taste of home” wherever they are based in the world, which drives a prioritisation of reputable UK-sourced and branded products. Our scale limits our buying power and impacts on our ability to influence suppliers. Our procurement and supply chain position in the main is as a small customer of much larger organisations, with the majority of our product being sourced from reputable wholesalers.
All ordering and supplier liaison is conducted centrally, except for small-scale purchasing through local suppliers in remote locations, predominantly the South Atlantic and Royal Navy ships supply. We use the same suppliers as the MOD or ships chandlers who are all members of the International Ship Suppliers & Services Association (ISSA) in these areas.
Our Policies
The Royal NAAFI is fully committed to operating ethically and within the spirit and the letter of the law in every part of our business and this key commitment is embedded in our Corporate Responsibility Policy. Our employment policies are fully compliant with UK employment law and these standards are applied in all locations. All UK-sourced colleagues are paid the UK National Living Wage as a minimum, irrespective of the country where they work, and all locally employed nationals are also paid the local equivalent as a minimum.
In addition to having a transparent Grievance Policy, we have a robust Whistleblowing Policy. These policies provide safeguards for colleagues reporting issues, including illegal or unethical activity and are managed by chartered CIPD personnel in our Human Resources Management team who have independent access to the Board where necessary.
We are committed to ensuring that our recruitment policy and on-boarding practices in all locations are robust and eliminate opportunities for modern slavery to occur. All our policies are reviewed annually and updated as necessary to ensure that they are fit for purpose and continue to reflect current best practice.
Risks
The risks and associated controls of each of the below categories are different, however, all our colleagues are subject to stringent Right to Work, referencing and MOD security checks/clearance relevant to their work location. Our Colleagues are employed in three ways:
1. Direct Employment
Our HR team supports the internal recruitment of all these colleagues directly using reputable recruitment job boards and routes to recruitment. All recruitment follows a robust Interview process, supported by HR and followed by reference and write to work checks. We limit the use of external recruitment agencies to trusted third parties, and for high-level or specialist positions which have no risk of modern slavery or human trafficking.
All pay rates, incentives and rewards are subject to review by our Remuneration Committee. We review our pay and benefits across all locations annually to ensure that our pay rates remain appropriate. This includes annual negotiations with Unite, our Trade Union Partner.
All our colleagues are employed on clear and transparent written contracts with standard terms and conditions that comply with UK law or host nation legislation.
All our colleagues are over the age of eighteen and we have clear policies ensuring that vulnerable adults are treated fairly and supported. These are supported by Disclosure and Barring Service (DBS) checks where necessary.
2. Agency Workers/Sub-Contractors
We only use reputable and established sub-contractors and agencies, the majority of which we have long-established relationships with. We monitor agency performance and act if there is any indication or suspicion that acceptable ethical standards are not being met in their treatment of our colleagues.
3. Casual Colleagues
We limit the use of casual colleagues to our hospitality business in Germany and only for specific events. All casual colleagues are pre-registered with us, subject to detailed checks and recruited exclusively from the British Forces Community.
Due Diligence - Our Supply Chain
All suppliers are subject to a rigorous Supplier Risk Assessment process, and we are currently implementing full risk assessments across all existing suppliers. A full risk assessment process is conducted when engaging with new suppliers.
1. Risk Assessment
This robust Risk Assessment process is central to our response to the challenges of confronting Modern Slavery. Our risk assessment process considers the following factors:
- The geographical areas that a supplier operates in with reference to the legislative framework and human rights profile of that area.
- The type of economic activity a supplier undertakes, and the likelihood of that activity being involved in forced labour, child labour or any other manifestation of Modern Slavery.
- The supplier’s engagement with anti-modern slavery measures and organisations.
- Evidence that the supplier has effective due-diligence and the proper safeguarding policies in place.
2. Supplier Set-Up
Supplier setup has two stages.
- Stage 1 - Initial procurement/contract discussions.
- Stage 2 - Formal sign off by our Finance department, who have a separate reporting line to all other departments.
Risk assessments will be completed for all new suppliers where applicable, as a minimum provide a copy of their Modern Slavery policy.
KPIs
We are vigilant when setting up any supplier/supply chain KPIs to ensure that they do not drive inappropriate behaviours or inadvertently incentivise our suppliers to engage in activities which may breach the Modern Slavery Act. We are currently developing internal Modern Slavery specific KPIs which will be implemented to enhance transparency. These will include the number of:
- Supplier risk assessments completed.
- Personnel trained in identifying and reporting indications of Modern Slavery.
- Whistle-blowing incidents received in respect of Modern Slavery with commentary on outcomes and if appropriate, remedial action taken.
Performance against our KPIs will be included in all future statements.
Training
Our policies are available to all colleagues and are included in our induction process for new colleagues.
Training is provided to managers in the highest risk areas of our business, in particular those based outside of mainland Europe, involved in procuring new suppliers, and our Human Resources Managers.
Looking to the future
During our Financial year ending 31st March 2026, we will:
- Review our corporate policies to explicitly address Modern Slavery.
- Extend our training to cover all management involved in recruitment and sourcing of goods and services.
- Implement a measurable set of Modern Slavery specific KPIs to monitor compliance with our policies and provide a basis from which to continually evolve.
- Complete Risk Assessments for all current suppliers with an annual spend in excess of £100k or equivalent in local currency per annum.
This statement refers to the financial year ending 31st March 2025 and reflects our current activity and The Royal NAAFI board has approved this Statement.
