Modern Slavery and Human Trafficking Statement

Financial Year 2025-26

Introduction

This statement sets out NS&I’s approach to ensuring that slavery and trafficking is not taking place in any part of our own business, or in our supply chain, for the 2025-26 Financial Year.

Section 54(1) of the Modern Slavery Act 2015 requires businesses with a turnover above £36m to publish an annual modern slavery and human trafficking statement. In 2020, the UK Government published its first Modern Slavery Statement, and Ministerial Departments have been required to publish their own statements since 2021. At NS&I, we hold ourselves to the same standard of transparency that is asked of our suppliers in regard to assessing modern slavery risks in our supply chain. As such, for several years we have published our own statement, as a matter of good practice, as well as contributing to HM Treasury’s departmental statement which covers all of its agencies.

Modern slavery is a crime and violation of fundamental human rights, and NS&I has a zero-tolerance attitude to any of the forms of abuse described in the Act, including slavery, servitude, forced or compulsory labour, human trafficking and exploitation. NS&I is committed to acting ethically and with integrity in all business dealings and relationships, and to ensuring our supply chain is held accountable to the same ethical standards.  

As an executive agency of the Chancellor of the Exchequer, NS&I is responsible for providing cost-effective financing to the government by issuing and selling retail savings and investment products to the public. NS&I directly employs around 275 people all of whom are based in the UK.

Our review has concluded that the services NS&I provides are at low risk of being affected by slavery or human trafficking. However, NS&I is committed to maintaining effective systems and controls to ensure modern slavery is not taking place anywhere in our own business, or in our supply chains.

As a central government organisation, NS&I has a preference for using central government framework agreements to source supplies and services, where they meet our needs . The majority of these are procured on our behalf by the Government Commercial Agency (GCA), formerly known as Crown Commercial Service, the government’s central purchasing body. NS&I is then responsible for selecting from appropriate framework suppliers appointed by GCA, usually via a competitive process. The nature of this arrangement means that some general reliance is placed on the government-procured supply chain, and on GCA’s ability to take the lead in providing assurance that their selected contractors comply with the Act. Notwithstanding this, the review of supplier compliance with Modern Slavery Act transparency requirements, described below, includes all GCA framework suppliers currently providing services to NS&I.

Being a Living Wage employer

NS&I has been a Living Wage employer, certified by the Living Wage Foundation, since 2019. This commits the business not only to maintain fair rates of pay for its own workforce, but also to promote and embed this principle with key suppliers. NS&I’s key suppliers pay all UK staff the real Living Wage or above, and the majority of them are certified by the Living Wage Foundation. This provides a useful synergy with our efforts to ensure modern slavery is eliminated, by fostering ongoing dialogues with suppliers about their own employment practices. NS&I once again renewed its Living Wage employer certification in November 2025 and will maintain this for 2026-27.

Staff training and guidance

NS&I staff in the Commercial team have received training on the principles of the Modern Slavery Act and how to understand the level of modern slavery and trafficking risk posed by different activities outsourced to third parties. This training is refreshed at least annually, and ensures the team are appropriately equipped to assess and investigate this area of supply chain risk, as well as being able to advise suppliers on how to verify and demonstrate their own compliance, especially during the annual supply chain review described in this statement. In addition, during 2025, following the entering into force of the Procurement Act 2023, NS&I Commercial reviewed its training and guidance to follow the latest best practice as issued by Cabinet Office under Procurement Policy Note 009 “Tackling modern slavery in government supply chains”. This approach shows that NS&I holds itself to the same high standards that it rightly expects from suppliers.

NS&I’s outsourced business partners

For the period covered by this statement, the majority of NS&I’s customer-facing and back-office services were delivered by key outsourcing partners. Atos IT Services UK Ltd provides core banking services, runs NS&I’s prize draw system, and provides a range of other customer services, some of which are in the process of transition to other suppliers as part of a multi-supplier model. During 2022 and 2023 new strategic contracts were awarded to IBM United Kingdom Limited, providing digital integration, digital experience and digital enablement through web and app services, and Sopra Steria Limited, to provide our customer contact centre and related operations. In addition, Capgemini was awarded a contract in 2025 to act as a Systems Integrator.

Atos , IBM, Sopra Steria and CapGemini have all been assessed to ensure they have robust internal ethics and training throughout the business and, specifically in terms of modern slavery risk in the supply chain, detailed training an systems in place to ensure they are able to assess and mitigate supply chain risks associated with slavery and trafficking. We have assessed all four key suppliers as providing a strong level of assurance. These suppliers have recently been subject to further review as part of the exercise detailed below. 

NS&I’s wider supply chain

In addition to Atos, IBM, Sopra Steria, and Capgemini, NS&I has a directly managed supply chain of around 100 suppliers at any one time. As noted above this includes suppliers selected and assured by GCA, although NS&I also undertakes its own procurement exercises on a regular basis.

Between February and March 2026, NS&I’s Commercial team conducted an in-depth audit of 83 suppliers (excluding a small number whose contracts were imminently due to expire and would not be renewed). Of these, 45 had a turnover of more than £36m (including those whose parent company revenue exceeded £36m) and were therefore required to comply with the supply chain transparency obligations in Section 54 of the Act.  These included Atos, IBM, Sopra Steria, and Capgemini, as noted above.  

For the 45 in-scope suppliers, a detailed review was undertaken, examining their modern slavery statement, where published, and the supplier’s associated policies, procedures, and training plans.

For each, we considered a number of features, based on Home Office best practice recommendations, including:

• Was the statement up to date?
• Was it published on the Company website and easy to find?
• Was it signed off by a Director or equivalent senior leader, and was it clearly endorsed by the board and senior leadership of the organisation?
• Did it meet all of the statutory requirements set out in the Modern Slavery Act?
• Was it supported by staff training plans, appropriate compliance procedures, and any other relevant evidence?

Suppliers were evaluated on the level of assurance their transparency publications offered, using the following methodology, which is based on Home Office guidance:

• Strong – The statement is up to date, and with supporting evidence, demonstrates that the supplier has undertaken a thorough review of their own business, and their supply chain, to identify areas of risk with regard to modern slavery. The supplier has appropriate training in place for staff, and robust procedures for ensuring their supply chain is compliant. The senior leadership of the business takes modern slavery reporting seriously. The effectiveness of these procedures is regularly audited, and there is reliable assurance that action will be taken against supply chain partners who may be non-compliant.
• Adequate – The statement is up to date and shows that the supplier has undertaken a review of their own business, and their key supply chain partners. The senior leadership of the business has endorsed the statement. There may be some evidence of staff training and / or active monitoring of supply chain partners, but this could be further developed.
• Inadequate – There is no statement, or the statement is out of date. Or, despite publishing a statement and acknowledging the need to combat modern slavery, the supplier’s procedures for addressing it contain significant gaps, and / or there is a lack of evidence that they are effectively monitored or acted upon, and / or there is no indication of support or buy-in from the senior leadership of the business.

The same evaluation was also conducted on the key subcontractors of our Gold-tier business partners, Atos, IBM, Sopra Steria, and Capgemini

Assessment

In our assessment, all four key strategic suppliers have published an up-to-date Moden Slavery statement, supported by evidence and re-occurring staff training, demonstrating strong compliance with their obligations. In addition to the strategic suppliers, two other in-scope suppliers, NatWest and Dun & Bradstreet, had a modern slavery statement, supported by good evidence, which demonstrated a particularly strong level of assurance that modern slavery was not present in their operations or their supply chain. A further 37 in-scope suppliers were deemed to provide an adequate level of assurance.

Two in-scope suppliers had an inadequate Modern Slavery Statement. In both cases, this was because the statement was out of date. These suppliers were contacted by NS&I’s Commercial Team and have since published new, up-to-date statements that are of an adequate quality. 

Assessment of key sub-contractors: Atos

Atos currently has five key subcontractors. Out of the five, three are out of scope as they are based outside of the UK jurisdiction. However one of these, Sopra Banking Software (SBS) is a particularly important part of NS&I’s supplier ecosystem as they provide the software for NS&I’s Core Banking Engine, and their compliance was therefore reviewed. SBS published a Modern Slavery and Human Trafficking statement last year, and the main responsible entity, 74Software Group, based in France, has in place an up to date Code of Ethics in line with the requirements of French corporate law.

Of the remaining two suppliers, Worldline IT Services has a strong, up-to-date Modern Slavery statement with a well-detailed risk assessment, and Paragon Customer Communications published an adequate, up-to-date statement. It is worth noting that though the three out of scope suppliers are not required to publish a modern slavery statement under the Act, they have each published a human rights statement and are compliant with appropriate Environmental, Social and Governance obligations in their countries of origin.

Assessment of key sub-contractors: IBM

IBM has three key sub-contractors, and all three are within scope. Amazon Web Services and ServiceNow UK Ltd both have a published a strong statement. Though Adobe did have a strong statement in general, their statement lacked express board level approval. This was raised with IBM, and Adobe has since confirmed in writing that their statement is approved by the Board as a part of their overall corporate governance reporting. 

Assessment of key sub-contractors: Sopra Steria Limited (SSL)

SSL have 21 key third-party suppliers. Out of those, six of them are out of scope. The rest of the 15 in-scope suppliers have published a statement. Of these, four had strong statements, and eight suppliers had an adequate level modern slavery statement in place.

However, two suppliers’ statements were out of date at the point of review. They were:

•    Bytes Software Services Limited; and 
•    Hyland Software UK Ltd

Furthermore, it was deemed that ASM Technologies Limited’s statement was weak, particularly around assessing the risk of Modern Slavery in the business and the supply chain.

SSL were made aware of these issues and raised them with their respective subcontractors. In response SSL has confirmed the following:

• Hyland: SSL’s legal team has confirmed that Modern Slavery and Human Trafficking Statements are published using previous fiscals. Therefore, the Modern Slavery and Human Trafficking Statement for Fiscal Year 2025 will be published this year, by end of June 2026.
• Bytes Software Services Limited: At the time this report was drafted SSL has not received a response from the supplier. NS&I must conclude that this subcontractor does not meet the reporting requirements of the Modern Slavery Act. This was being further escalated with SSL at the point of publication.
• ASM Technologies Limited: SSL has confirmed that they are currently reviewing the statement and their associated due diligence processes, with a focus on strengthening how modern slavery risks within our supply chain are assessed, managed, and evidenced. This work will also feed into future statements. NS&I will monitor this to ensure that their next statement is fully compliant.

Assessment of key sub-contractors: Capgemini

Capgemini has only one key sub-contractor, Actica Consulting Limited. They have a strong, up-to-date modern slavery and human trafficking statement, with good evidence and details. 

Resolutions

The actions taken by Atos, IBM, and Sopra Steria to ensure their key sub-contractors make any updates or improvements required to their statements, will be actively monitored by NS&I during Q2 of the financial year 2026-27.  

Finally, our review also found that nine smaller NS&I suppliers, despite being under no legal obligation to publish a modern slavery and human trafficking statement, had voluntarily done so, and that these were generally to a reasonable standard. As in previous years, NS&I sent a note of thanks to these suppliers to commend their positive attitude to this serious issue. 

Conclusions

Compared to the previous year’s review, the level of general compliance with the reporting provisions of the Act has increased. The majority of in-scope suppliers understand their obligations and are proactive in complying with them.

All statements from suppliers which NS&I directly contracts with have been updated and are compliant with the Modern Slavery Act. IBM, Sopra Steria, Capgemini and Atos IT Services UK have worked constructively with NS&I throughout this process and have helped address issues within their supply chains.

This statement, and the procedures NS&I has in place to tackle modern slavery, will be fully reviewed next year and an updated statement published in line with our 2026-27 Annual Report.

Approved on behalf of the NS&I Board by:

Sir Jim Harra KCB
Interim Chief Executive and Accounting Officer
National Savings and Investments
24 June 2026