Modern slavery and human trafficking statement

The Royal Academy of Arts (RA) is committed to combatting slavery and human trafficking. This statement sets out the steps that the RA is taking to ensure modern slavery is not taking place in our business or supply chains and is made pursuant to Section 54 of the Modern Slavery Act 2015. This statement is applicable for the financial year which ended 31 August 2020. The statement applies to the RA as a whole, which includes the following entities:

- The Royal Academy of Arts (‘RA’) (company no. 6298947) – an independent charity led by eminent artists and architects to promote the Arts of Design through exhibitions and education;

- R. A. Enterprises Ltd (company no. 1666333) – a wholly-owned subsidiary of the RA that operates the RA’s shops and e-commerce, restaurants and cafés, publications, art sales and commercial learning;

- Burlington House Ltd (company no. 2216104) – a wholly-owned subsidiary of the RA that conducts fundraising, through ticketed events, from the corporate sector and individuals;

- RA (Arts) Ltd (company no. 2836364) – a wholly-owned subsidiary of the RA that operates entertainment and community services for the corporate sector;

- The Friends of the Royal Academy (company no. 1291535) – a separate charity with its own trustees, it supports the work of the Royal Academy and promotes the creation and appreciation of the arts; :

- The Royal Academy Trust (charity no. 1067270) – a separately registered charity, whose object is the maintenance, development, advancement and preservation of the Royal Academy.

You can read more about our activities in our latest annual report, here.

Our Performance

Set out below is what we said we would do in our previous statement, and what we have done in the latest financial year.

Supply Chain & Contractual

As explained in our previous statement (for the year ended 31 August 2019), we have developed our understanding of the actual modern slavery risks inherent in our supply chain, establishing the highest risk categories based on level of spend and nature of activities. This year, we have expanded the list from six to seven categories, to include retail. These categories are:

1. Building Works;

2. Art Transport;

3. IT;

4. Print;

5. Facilities Management;

6. Catering;

7. Retail.

What we said we would do: “Asking suppliers specific questions on modern slavery as part of relevant selection processes”

“New Suppliers: For the categories of suppliers identified as posing the highest risk to us (as set out above), we will carry out particular due diligence to understand what measures they are taking and what mitigation they have in place to prevent Modern Slavery before we enter into a contract with them. This will consist of detailed questions at procurement stage where relevant.”

What we have done: As part of our procurement processes we ask questions of potential suppliers regarding their compliance with the Modern Slavery Act, where the service falls within our main risk categories and anticipated spend is above £25,000. We have reviewed responses from suppliers, together with their own Modern Slavery policies, and raised further queries where appropriate.

What we said we would do: “Existing Suppliers: For existing suppliers identified as posing the highest risk to us, we will carry out annual checks to understand their commitment and progress, and work with suppliers to ensure that they can commit to our standards and contractual obligations.”

What we have done: We have yet to undertake this work, which we plan to do before the end of 2021.

What we said we would do: “Obtaining where appropriate contractual warranties that slavery is not taking place in the supplier’s business or in any element of its supply chain and that all necessary policies and procedures have been put in place to prevent such practices”

“Updating our agreements and terms and conditions relating to sponsorship, venue hire and corporate membership, to include requirements for these third parties to comply with the Modern Slavery Act 2015 and/or the RA’s policy on Modern Slavery and Human Trafficking.”

What we have done: The RA’s standard terms and conditions relating to sponsorship, venue hire and corporate membership have been updated a number of times in this period, and since. These agreements, together with other terms and conditions the RA proposes to suppliers and other contractual partners, each contain explicit provisions requiring compliance with the Modern Slavery Act 2015 and/or the RA’s policy, entitling the RA to terminate the contract where this is not adhered to.

The RA is accredited as a London Living Wage employer, requiring larger value contractors and suppliers to pay their staff the London Living Wage. We have introduced these requirements into additional major contracts, for example with a catering partner.

Policies

What we said we would do: “Developing and implementing the RA’s policy on Modern Slavery and Human Trafficking”

What we have done: This has been implemented and was updated on 4 February 2020 and 2 March 2021.

 What we said we would do: “Updating our Whistleblowing Policy to encourage staff to report concerns about modern slavery and child or forced labour.”

What we have done: The RA’s Whistleblowing Policy refers to ‘belief or suspicion of modern slavery’ as an example of a concern which might fall under the Policy. The Policy is due to be reviewed and updated in 2021.

Training

What we said we would do: “In 2019/20 we will focus on training staff, to improve understanding of modern slavery and human trafficking, and the effectiveness of our processes.”

What we have done: We did not undertake specific staff training in 2019/20. The Royal Academy has significantly restructured its operations in response to the Covid-19 pandemic. We will consider what training may be appropriate in the context of our new structure and activities.

Recruitment and Employment

What we said we would do: “Updating our recruitment processes to include due diligence checks and information for new staff” :

What we have done: We have not made changes to our recruitment processes or staff induction information specific to modern slavery. During the Covid-19 pandemic, our levels of recruitment have been limited. As with training, we will consider this in the context of our new structure and activities, and future level of recruitment.

If you have any queries regarding this statement, please contact:

- Michael Casartelli (Head of Procurement) (michael.casartelli@royalacademy.org.uk); or

- Benedict Anstey (General Counsel) (benedict.anstey@royalacademy.org.uk).

Approved by the Council of the Royal Academy of Arts on 2 March 2021

Rebecca Salter, President – The Royal Academy of Arts