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 2024 – 31 March 2025.

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. This is an additional 63,000 passengers per week compared to the previous year. Much of this increase is due to the opening of Belfast Grand Central Station and the opening of York Street Train Station, which have provided modern accessible passenger facilities.  An increased supply chain was 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 4,400 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 & Fraud and Theft Response Plan
• 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.

4.3. 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 >£65k, 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.  All Translink procurement staff are made aware of the NI Executive Procurement policy on Human Rights (PPN05/24) which identifies the potential for consequences on the human rights of people when employed to deliver goods and services through government contracts.

7.2. As part of the team’s engagement with the wider business when developing the tender strategy, consideration is given to the potential risk of human rights issues, including modern slavery, associated with the nature of the product or service to be procured

7.3. 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.

8. Financial Year 2025/2026

8.1. Translink will provide training to relevant staff on new procurement rules. Training will be sourced through the Cabinet Office, or other external providers such as the CIPS’ course on Ethical Procurement. 

8.2. In addition, Translink are undertaking a piece of work in relation to Capability in Centre of Procurement Expertise, which will identity existing training gaps and incorporate modules addressing modern slavery.   

9. Approval

This Statement has been approved by NITHC’s Board on 17th September 2025 and will be reviewed annually.

Signed:

Chris Conway, Group Chief Executive

Date: 2 October 2025