Anti-slavery policy and statement

The Board of Trustees of the Royal Botanic Gardens Kew (“RBG Kew”) 
Slavery and Human Trafficking Statement 2024-2025

This statement sets out the steps that the Royal Botanic Gardens, Kew (‘RBG Kew’) has taken during the financial year ending 31 March 2025 to ensure, as far as possible, that modern slavery is not taking place within its business or its supply chains. RBG Kew has a zero-tolerance approach to modern slavery and is committed to acting ethically, transparently and with integrity in all our business dealings and relationships. There have been no detected instances of modern slavery during 2024/25.

Our structure and business

We are a world-leading botanical garden, a UNESCO World Heritage Site, and one of the most biodiverse places on Earth. RBG Kew is incorporated as a non-departmental public body with exempt charitable status, established under the National Heritage Act 1983. RBG Kew makes this statement for and on behalf of itself and its wholly owned trading subsidiary RBG Kew Enterprises Limited[1] which provides commercial services such as retail, publishing, licensing, venue hire, visitor programming, and marketing and digital services. RBG Kew Enterprises Limited donates its profits under Gift Aid to RBG Kew, thereby assisting the funding of our non-commercial, charitable activities.

RBG Kew’s structure and business is set out in greater detail in its annual report and accounts. Our expenditure for 2024/25 was £118 million. We are over 1,500 staff and 800 volunteers.

Supply chain

The overall risk of modern slavery in our supply chain remains low. The majority of our procurement is conducted through established framework agreements, such as those provided by the Crown Commercial Service and the London Universities Purchasing Consortium, which incorporate robust contract compliance, supplier due diligence, and performance monitoring mechanisms aligned with national standards, including ethical procurement and human rights safeguards.

In line with our obligations under the new Procurement Act 2023 and the National Procurement Policy Statement, which came into force in February 2025, we continue to embed ethical and sustainable procurement practices across our organisation. We take active steps to identify and mitigate any potential risks of labour exploitation or unethical practices in our procurement activities, particularly when working with direct suppliers or subcontractors outside of framework agreements.

Our retail and trading activities continue to present a low risk of modern slavery, as we do not typically engage in high-risk sectors or source goods from jurisdictions with weak labour protections. Nevertheless, we require all suppliers to self-certify annually against a comprehensive set of ethical trading standards, including explicit confirmation of compliance with the Modern Slavery Act 2015. Suppliers must provide supporting evidence or certifications (e.g., Sedex, ETI Base Code, SA8000) on request.

As part of our commitment to continuous improvement and transparency, we will strengthen contract and supplier management processes in line with new national guidance and integrate supplier risk assessments into our contract award and monitoring activities, particularly for high-value or high-risk procurement categories. 

In April 2023 our Executive Board approved our 2023 to 2028 Procurement Strategy which sets out the strategic approach to procurement for both RBG Kew and Kew Enterprises. We will ensure that our direct suppliers, and where possible their sub-contractors, are absolutely committed to preventing slavery within their own activities and through their supply chain which includes manufacturers and producers.

Recruitment and our people

We have a variety of policies and procedures in place to ensure compliance with UK employment law, and periodic internal audit reviews provide assurance on the operation of these policies. Our Human Resources team manage recruitment activities with recruiting managers and only use reputable employment agencies and job boards to source candidates. We carry out appropriate background checks including Right to Work and Disclosure and Barring Service checks for all fixed term and permanent appointments.

Regular meetings between management and union representatives provide structured opportunities to discuss issues affecting staff. Members of staff are also encouraged to provide feedback through an annual Staff Survey, the results of which feed into operational planning and decision-making.

Policies

RBG Kew maintains a suite of established formal policies including Anti-Slavery, Safeguarding, Ethical and Environmental Trading, Third Party Engagement, Procurement, Recruitment and Whistleblowing. Policies are regularly reviewed and approved by our Executive Board/Trustees as applicable. The policies are communicated to all staff to inform them of the standards to which both RBG Kew staff and suppliers must adhere, and the mechanisms available to staff and suppliers to report issues/concerns. These mechanisms include the provision of a confidential, independent whistleblowing hotline, and a dedicated safeguarding email inbox.

We updated our Anti-Slavery Policy in June 2024 to reference related policies and include details of our independent Whistleblowing Hotline and charities who can provide advice.

Our Safeguarding Policy (2025) includes a Practical Application to our work in Madagascar and a new appendix on the Protection from Sexual Exploitation, Abuse and Harassment (PSEAH). The policy is available in seven languages and publicly on our website. The next mandatory training period for Safeguarding and PSEAH awareness, which includes elements of modern slavery, is autumn 2025, with a previous completion rate of 99.7% achieved in 2023.

Our Third-party Engagement Policy (2025) and processes provide a frame of reference for how we assess and manage third party relationships to ensure regard for our ethics and values, which includes anti-slavery. 

Work outside of the UK

RBG Kew adheres to local laws in the countries we work in. We run a research and conservation centre in Madagascar. Acknowledging this as an area of potential risk (given the different regulatory and legal environment in the country) we commissioned an advisory review of Finance and HR controls in operation at the site in 2021/22 and a review of legal compliance in 2023. We have used the findings from these reviews to further refine our human resources practices, and to help embed effective working structures between the UK and Madagascar offices.

Safeguarding input has continued across Kew Madagascar both in the form of raising awareness across the workforce and within local communities. Partner capability building has also continued via in-country support and monthly safeguarding focal point meetings, chaired by Kew’s Head of Safeguarding. Formal learning via the Safeguarding and PSEAH webinar (available in Malagasy, French and English) is required on an annual basis. Kew Madagascar has active membership of the UN’s PSEAH Madagascar taskforce.

In-house international safeguarding training, featuring elements of modern slavery, is available for all Kew staff, students and volunteers who travel overseas as part of their work. Contextualised safeguarding assessments and risk mapping work is ongoing in Kew’s strategic countries. 

Our future plans

RBG Kew is committed to continuous improvement of our systems and processes. Planned activity for 2025/26 which will contribute towards our anti-slavery commitments includes:

• continued focus on safeguarding awareness, including mandatory safeguarding training for all staff and further refinement of our international safeguarding framework to mitigate risk both internally within RBG Kew and in our work with partner agencies.
• a new Responsible Procurement Policy to replace our ‘Sustainable Procurement Guidelines’. This policy will be aligned to the new Procurement Act and accompanying regulatory framework. It will recommend the adoption of the Government Buying Standards where appropriate and will provide links to guidance and training on successful adoption. The new policy will rely upon the Social Value Model, which includes vulnerability to modern slavery threats as a consideration in relation to contract delivery.
• continued participation in Defra’s Modern Slavery Steering Group to share best practice.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2025. It was approved by RBG Kew’s Executive Board on 21 May 2025 and Board of Trustees on 26 June 2025 and signed on their behalf by:

Richard Deverell                              
Director, Royal Botanic Gardens, Kew         
26 June 2025     

Dame Amelia Fawcett
Chair, Royal Botanic Gardens, Kew
26 June 2025

*RBG Kew Enterprises Limited does not meet the financial threshold which would require its own statement.