Modern Slavery Statement
1. Our Commitment
Bluechain Consulting Ltd is committed to conducting its business ethically, responsibly and with integrity, and to preventing modern slavery, human trafficking, forced labour and other forms of labour exploitation within its operations and supply chains.
We recognise that modern slavery is a global concern and that risks may exist in any country, industry or supply chain. We are committed to identifying, assessing and addressing these risks through proportionate due diligence, responsible procurement practices and engagement with our employees, consultants, contractors and suppliers.
Our approach is informed by the principles of the UK Modern Slavery Act 2015 and relevant international labour and human rights standards.
2. Our Business and Supply Chains
Bluechain Consulting is a UK-based specialist consultancy providing economic and financial analysis, development finance advisory, market development, policy analysis, research, evaluation and programme support, primarily in the water, sanitation, climate and environmental sectors.
We work with governments, multilateral organisations, UN agencies, NGOs, foundations and private sector organisations, including on assignments across Africa and Asia.
As a professional services consultancy, our activities are primarily knowledge-based, and our direct procurement of physical goods and materials is relatively limited.
Our supply chains principally comprise professional consultants and technical specialists, local research and project implementation partners, and providers of business support, travel, accommodation, transport, technology and other services.
We recognise that modern slavery risks may arise in both direct and indirect supply chains, particularly where services involve vulnerable workers, informal employment, recruitment intermediaries or subcontracting arrangements.
3. Risk Assessment and Management
Bluechain adopts a proportionate, risk-based approach to identifying and managing potential modern slavery risks.
Although our directly employed professional workforce generally presents a different risk profile from labour-intensive supply chains, we recognise that no employment arrangement or geographical location is inherently free from exploitation risks.
Areas requiring particular consideration include:
-
International subcontractors and local partners: Potential risks associated with recruitment practices, employment conditions, payment arrangements and further subcontracting.
-
Research and fieldwork: Potential risks involving temporary enumerators, field researchers, community mobilisers and other locally engaged personnel.
-
Travel and operational services: Potential labour exploitation within transport, hospitality, cleaning, facilities management and other supporting services.
-
Water and sanitation sector supply chains: Potential labour risks associated with construction, infrastructure development, sanitation services and informal service provision, where these activities fall within the scope of our work or procurement responsibilities.
In assessing risks, we consider relevant factors including geographical location, sector, workforce characteristics, recruitment arrangements, subcontracting practices and the nature of the goods or services being provided.
Where our advisory assignments involve reviewing or strengthening water and sanitation markets or supply chains, we seek to consider relevant labour and human rights risks where appropriate to the project's scope.
4. Supplier and Contractor Due Diligence
Bluechain is committed to maintaining responsible relationships with suppliers, contractors and project partners.
Our approach is to apply due diligence proportionate to the nature and level of risk identified.
Where appropriate, this may include:
-
Assessing modern slavery risks before engaging new suppliers or subcontractors.
-
Seeking information on employment practices, recruitment arrangements and the use of subcontractors.
-
Requiring suppliers and contractors to comply with applicable labour laws and relevant ethical business standards.
-
Seeking additional assurances from suppliers operating in higher-risk environments or providing labour-intensive services.
-
Reviewing concerns arising during the course of a contract or assignment.
-
Considering appropriate contractual safeguards for higher-risk engagements.
We expect suppliers and contractors to respect fundamental labour rights, including freedom from forced labour, human trafficking and unlawful child labour.
We also expect responsible recruitment practices, including no worker-paid recruitment fees or improper retention of identity documents, and compliance with applicable requirements relating to wages, working hours and employment conditions.
Where concerns are identified, Bluechain will assess the circumstances and determine appropriate actions. These may include seeking clarification, requiring corrective measures, enhanced monitoring, suspending further engagement or, where necessary and legally appropriate, terminating the relationship.
Our priority will be to address identified risks responsibly and avoid actions that could unintentionally increase harm to affected workers.
5. Reporting Concerns and Responding to Incidents
Bluechain encourages employees, associate consultants, contractors and other relevant stakeholders to raise concerns regarding suspected modern slavery or labour exploitation.
Concerns may be reported confidentially to a designated director or through the company's established reporting channels.
Reports will be taken seriously and assessed promptly, with appropriate consideration given to confidentiality, the safety of affected individuals and the protection of those raising concerns in good faith.
Where credible concerns arise, we will seek to establish the facts, take proportionate protective action and, where appropriate, engage with relevant partners, specialist organisations or competent authorities.
Any response will prioritise the safety, dignity and rights of potentially affected individuals.
6. Training and Awareness
Bluechain recognises that awareness is essential to identifying and preventing modern slavery risks.
We aim to ensure that personnel involved in procurement, recruitment, subcontractor engagement and international project delivery have access to appropriate information and guidance on recognising potential indicators of modern slavery.
Relevant guidance and resources are made available to staff, with further briefing or training considered where assignments or supplier relationships present increased risks.
We encourage personnel to remain alert to warning signs of exploitation and to raise concerns through appropriate channels.
7. Monitoring, Effectiveness and Continuous Improvement
Bluechain is committed to reviewing and improving its approach to modern slavery risk management as its activities, partnerships and operating environments evolve.
We will consider the effectiveness of our arrangements through proportionate measures, which may include:
-
The identification and assessment of higher-risk supplier or contractor relationships.
-
Completion of relevant supplier due diligence checks.
-
Staff awareness and access to appropriate guidance.
-
The identification, escalation and resolution of any modern slavery concerns.
-
Implementation of corrective actions and lessons learned.
Our priorities include strengthening risk-based supplier assessments, reinforcing expectations for local subcontractors and project partners, and improving documentation and internal awareness where appropriate.
8. Review and Governance
Responsibility for oversight of this statement rests with the Directors of Bluechain Consulting Ltd. The statement will be reviewed at least annually, taking account of changes in the company's activities, relevant legislation, operational risks and recognised good practice. Where this statement is used to report under section 54 of the Modern Slavery Act 2015, it will describe the steps actually taken during the relevant financial year.
9. Approval
This statement has been approved by the Board of Directors of Bluechain Consulting Ltd.
