Modern Slavery Statement

1. ORGANISATIONS COVERED BY THIS STATEMENT

This Statement is prepared on behalf of the Northern Ireland Transport Holding Company (“NITHC”) and its private limited subsidiary companies, including (but not limited to) Ulsterbus Limited, Citybus Limited and Northern Ireland Railways Company Limited, collectively referred to as “Translink”.

Translink’s financial year end occurs on 31 March. This Statement covers the financial year 1 April 2023 – 31 March 2024. 

2. OBJECTIVE

Translink fully supports the aims of the Modern Slavery Act 2015 (the “Act”) and is committed to tackling slavery and human trafficking where it can. The objective of this Statement is to set out the actions Translink is taking to comply with the Act. 

3. ORGANISATION STRUCTURE, BUSINESS AND SUPPLY CHAINS

3.1. The Translink group consists of a Public Corporation, Northern Ireland Transport Holding Company (“NITHC”, established under the Transport Act (Northern Ireland) 1967), which owns and controls seven private limited subsidiary companies, some of which are covered by this Statement. Translink work with the Department for Infrastructure in the provision of public transport services.

3.2. Translink is Northern Ireland’s primary public transport provider. It provides integrated bus, coach, and rail services across Northern Ireland. Translink aims to make Northern Ireland Better Connected, striving to continually improve the quality and accessibility of our services to customers, leading the development of an integrated transport network linking communities, and accelerating action on climate change. Translink’s vision is to be the first choice for travel in Northern Ireland today, for tomorrow. 

3.3. 1.5 million passengers travel with Translink, across our network every week. We expect to return to pre-pandemic journey numbers this year and with the opening of our innovative new Transport Hub, “Belfast Grand Central Station” and other redevelopment projects such as the new York Street Station, we hope that the number of journeys increase. An increased supply chain has been in place during this important phase of infrastructure development, and we work to maintain best practices with our suppliers. 

Translink has a variety of suppliers, and our supply chains fall into a number of different departments, as follows: 

• Engineering and Fleet Maintenance 
• Corporate Services 
• Infrastructure, Capital Development and Estate Services 
• Fleet Procurement 

3.4. Translink is also a major employer in Northern Ireland with approximately 4,300 jobs provided across the region. Recognised as an industry leader, being the recipient of the Investor in People Silver mark, Translink continues to deliver strong performance despite challenging economic times. 

3.5. Should the Act apply to bidders, Translink requires those bidders to declare that their Policies and Procedures are fully compliant with the Act. 

4. POLICIES RELEVANT TO MODERN SLAVERY

4.1. As a Centre of Procurement Expertise, Translink is committed to ensuring that there is no modern slavery or human trafficking in its supply chains or in any part of its business. 

4.2. Translink’s commitment to conducting business ethically and responsibly, is reinforced through various company policies, including: 

• Whistleblowing Policy 
• Anti-Fraud, Theft and Bribery Policy 
• Fighting Bribery in Public Procurement Guidelines 
• Procurement Policy and Procedures (in line with NI Public Procurement Policy) 
• Employee Charter 
• Recruitment Procedures and Code of Practice 

Internal Translink policies are kept under review. Translink’s suppliers must also adhere to the Department of Finance Supplier Code of Conduct. 

5. RISK ASSESSMENT, PREVENTION AND MITIGATION

5.1 Translink has a zero-tolerance policy to slavery and human trafficking. To ensure all those in Translink’s supply chain comply with Translink’s values, Translink has in place a process to mitigate potential risk by ensuring that all suppliers sign up to Translink’s contract terms, which include Anti-Slavery conditions. 

5.2. Translink is committed to: 

• Identifying and assessing potential risk areas in Translink’s supply chains at the Procurement Strategy stage. 
• Mitigating the risk of slavery and human trafficking occurring in Translink’s supply chains by supplier assessment at the tendering stage. 
• Protecting whistleblowers. 
• Promoting anti Modern Slavery within our recruitment processes by ensuring compliance with relevant legislation. 
• Having policies and procedures in place to support employees such as Dignity at Work, Equal Opportunities.

5.3. Translink recognises the source countries and associated sector risks in its supply chains as follows: 

6. BUSINESS AND SUPPLY CHAIN DUE DILIGENCE

6.1. Considering common risk factors, Translink believes that the areas of its business with the potential for the greatest susceptibility to trafficked labour are roles where low skilled labour is required, in particular where agency staff or subcontractors are utilised. 

6.2. Regarding its own business, Translink complies with relevant employment laws applicable in Northern Ireland. 

6.3 Translink has strict recruitment processes in place, ensuring reference checks for all employees are carried out and proof of eligibility to work in the UK is confirmed prior to commencement of employment. Suitability checks to work with children, via Access NI, are also conducted for bus drivers and shunters prior to commencing work in this area. 

6.4 Suppliers wishing to be considered for Translink contracts, with total values of >£50k, must confirm the following as part of the tender pre-qualification process: 

• That none of the organisation’s Directors or Executive Officers have been in receipt of enforcement/remedial orders in relation to offences under the prevention of modern slavery legislation. 
• That the organisation has appropriate procedures and protocols in place to eliminate modern slavery and human rights abuses, unethical employment practices and blacklisting from its business activities. 
• That the organisation has appropriate procedures and protocols in place to support payment of the National Living Wage. 
• That, if requested to do so by Translink, these procedures and protocols will be provided for independent checks to be undertaken.

7. TRAINING AND COMMUNICATION 

7.1. Translink’s Procurement team undertakes CIPS Ethical Procurement training on an annual basis. 

7.2. This Statement is contained within Translink’s Corporate Records Centre. It is available to all employees via Translink’s intranet and will be communicated via employee briefings. Modern Slavery Statement for Financial Year 2023 – 2024 

8. FINANCIAL YEAR 2024/2025

In the coming year Translink intends to take several additional actions to pro-actively increase the precautions it takes in dealing with Modern Slavery. 

8.1. Translink proposes to introduce an awareness campaign to highlight and educate employees on the issues of Modern Slavery. 

8.2. Translink will provide training to relevant staff on new procurement rules and will develop a new eLearning training module on tackling modern slavery in government supply chains and embed learnings from it into future procurements and/or approaches. 

9. APPROVAL

This Statement has been approved by NITHC’s Board on 21st August 2024 and will be reviewed annually.

Signed:

Chris Conway, Group Chief Executive 

Date: 29th August 2024