Modern Slavery & Human Trafficking Statement

The Royal NAAFI 2026/27 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 and is a self-sustaining public company limited by guarantee. The Royal NAAFI is a UK registered company and has, 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, the Middle East, USA, Estonia, Poland, Romania, Diego Garcia and on-board HM Ships. We provide convenience shops, pubs, coffee shops, as well as a wide range of hard and soft facilities management services to UK and NATO Forces and their dependants.

The Royal NAAFI undertake contract management services for the MOD wherever needed globally and our ‘posted’ colleagues are subject to UK and host nation laws wherever they are based as well as applicable MOD or local command regulations.

Our supply chains are straightforward; the majority are limited to dealing with companies within the United Kingdom and those incorporated and based in European countries; specifically; the Netherlands and Germany. A key purpose of our business is to provide service personnel with “a taste of home” wherever they are based in the world, which drives prioritisation of reputable UK-sourced and branded products. Our scale limits our buying power and impacts on our ability to influence suppliers and so we look for partners who understand and want to support what we do for service personnel and their families. Our procurement and supply chain position in the main is as a small customer of much larger organisations, with most of our products being sourced from these key reputable wholesalers etc.

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. Within these remote locations we focus on utilising the same suppliers as the MOD or ships chandlers of whom the majority are members of the International Ship Suppliers & Services Association (ISSA) in these areas.

Our Policies and contractual controls

In our Modern Slavery and Human trafficking statement we confirm that:

We will not tolerate any form of Modern Slavery.
The Royal NAAFI is fully committed to acting ethically and with integrity in all our business dealings and relationships.
We constantly review, update and improve our practises to ensure that Modern Slavery does not take place within our business and/or supply chains.
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.
We have a robust Whistleblowing Policy. This policy is widely available to all colleagues, who are asked to report issues, including illegal or unethical activities that extends to human rights violations, including Modern Slavery.
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.

1. Direct Employment

Our HR team supports the internal recruitment of all colleagues directly, using only reputable recruitment agencies job boards and routes to recruitment. All recruitment follows a robust Interview process that is followed by reference and right 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.

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. The remuneration committee review board determines executive pay and acts as an external governance for our internal pay rates.

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 Equality and Diversity policies that ensure all our colleagues including, minorities and vulnerable adults are treated fairly and supported.

Throughout 2025, we reviewed all our employment and recruitment practices. We introduced new policies, systems and workflows that will ensure we comply with Employment Rights Act 2025, including the changes that come into force in the UK within the latter half of 2026.

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.

Due Diligence - Supply Chain

All suppliers are subject to a rigorous Supplier checking process, and full risk assessments.

1. Risk Assessment

This robust Risk Assessment process is central to our response to the challenges of 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 up to date safeguarding and Modern Slavery policies in place.

2. Supplier Set-Up

Supplier setup has two stages.

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.

Our policies are available to all colleagues and are sign-posted in our induction process for new colleagues.

Training is provided to all management involved in procuring of new suppliers and the recruitment of our colleagues.

Looking to the future

During our Financial year ending 31st March 2027, we will:

Retrospectively risk assess all current suppliers and obtain copies of their Modern Slavery Policies.
Internally publish a set of Modern Slavery specific KPIs which will be implemented to enhance transparency and included in all future statements. These will include:
- Supplier risk assessments completed.
- Colleagues 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.
- Complete Risk Assessments in place for all suppliers with an annual spend that exceeds £100k or equivalent in local currency per annum.

This statement refers to the financial year ending 31st March 2027 and reflects our current activity, and The Royal NAAFI board has approved this Statement.