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Procurement Strategy 2020-2025

Last Updated 18/12/2020 9:00am

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Strategy Foreword

Strategic Procurement Themes

By Councillor Barry Parsons

Councillor Barry Parsons I am delighted the Council’s Procurement Service is part of my portfolio. It fits naturally within my area of work and is vital to supporting our public services across the Council’s activities.

Procurement is a wide-ranging discipline. It considers how we all work together to promote quality, performance and value for money through the Council’s activities, as well as support innovative, sustainable, efficient services.

Today’s changing world requires us to continually consider our priorities; balancing a strategic approach with the ability to respond swiftly to opportunities and challenges. The Council’s procurement approach promotes sustainable solutions. This benefits all Council duties in line with our strategic objectives and daily operations. We work collaboratively to drive value for money and promote sustainable services to support Devon’s communities and our wider public service.

I see first-hand how procurement skills are applied across our services to support the Council’s priorities. I value the progress towards our wider objectives and am proud to oversee our achievements along the way.

Procurement considerations are so wide ranging that the themes cannot all be covered in one place, however this document outlines current procurement priorities as a guide to Devon’s approach. This strategy works in tandem with the National Procurement strategy for Local Government in England and provides a local interpretation of key themes from a procurement perspective.

Here at Devon County Council our procurement approach is based on practicalities, sound principles and handling sometimes complex tasks successfully. I wish to endorse the themes identified within this strategy and look forward to how it will support our wider objectives.

Introduction

Welcome to Devon County Council’s Procurement Strategy for 2020 and beyond. The Strategy builds on recent achievements, complements the Local Government Association National Procurement Strategy and highlights a range of priorities for the Council’s procurement approach.

Devon’s Strategic Procurement Service forms part of the Council’s Digital Transformation and Business Support service; a natural fit as a corporate service which contributes to all aspects of the Council’s activity, as a full system approach. Procurement is about outcomes and at Devon County Council we do everything we can to promote an enabling procurement environment.

Procurement enables objectives to be drawn into a practical approach. This Strategy has been developed to support all areas of the Council’s activity in a joined-up way, bringing added value to Devon’s residents and communities.

Our procurement approach supports the organisation’s core purpose and continual evolution. The procurement function is about far more than just competition and compliance; it is an expansive, value-adding system which supports alignment of purpose and overall public value.

This Procurement Strategy links with the LGA National Procurement Strategy and brings together key considerations locally across Devon. It links with the Council’s wider objectives, many of which are highlighted within. Naturally, as our landscape alters, the strategy will be updated periodically to reflect these changing times.

Justin Bennetts

Justin Bennetts MCIPS Strategic Procurement Manager Devon County Council

Daniela Pleiss

Daniela Pleiss MCIPS Senior Procurement Officer Devon County Council

01392 383000
procure@devon.gov.uk

Local Government Association National Procurement Strategy

The Local Government Association (LGA) has published the National Procurement Strategy for Local Government in England. The Strategy outlines three Priority Themes and four ‘Enablers’ for Local Government procurement in coming years.

The LGA National Strategy highlights these themes and invites councils to develop their own approach linked to them. The Strategy themes are illustrated below and are available at local.gov.uk.

National Procurement Strategy for Local Government in England

National Procurement Strategy for Local Government in England

The Devon County Council context

The Council proudly serves over 740,000 citizens across Devon, covering 2,500 square miles and as the largest authority in South West England, is responsible for a wide array of public services.

The local and national landscape requires a whole system approach that works innovatively for re-design and improved integration, drives value for money, balances difficult decisions and promotes community outcomes and citizen wellbeing. Continually evolving the service offer in parallel with managing daily operations, is essential in our purpose of helping Devon’s communities flourish and thrive.

The Council has a budget of around £1,390m for 2020-21 across its capital and revenue workstreams, varying through each annual budget, with a proportionate mix of service areas as follows:

The Council applies many different service delivery models across its operations, using a ‘right model for the right service’ approach. This includes single/multiple provider frameworks and contracts, use of small Lots, local, regional and pan-regional frameworks, joint ventures and many partnership operations. For the Council’s full strategic plan please visit devon.gov.uk.

We keep up to date with ever-changing practice guidance to identify new opportunities to improve and develop service delivery.

Council Tax Graphic

Procurement at Devon County Council

Procurement is a facilitator that brings many diverse considerations together for a common purpose. Strategic procurement is an integral part of the corporate services offer and supports the Council’s strategic objectives and operational needs.

Devon’s procurement approach is informed by many complementary influences such as the Council’s strategic plan, service objectives and commissioning strategies, local economy considerations and reinvestment, the wider supply market, the national procurement strategy and legislative framework.

The Council’s diverse operations require a breadth of procurement expertise which enables the procurement service to build a wide knowledge base. The Council’s strategic procurement function is entitled ‘Devon Procurement Services’, a leading operator in South West public procurement.

The team brings a positive service culture, a solutions-based approach, an inclination towards collaborative working and view to the bigger picture.

Devon Procurement Services is configured into market-facing teams, using a Category Management approach which aligns to the Council’s service areas and their priorities. The team is a founding member of the Devon and Cornwall Procurement Partnership (DCPP) and the South West Procurement Board, with many collaborative arrangements.

Further information around the Council’s procurement operations is available here.

Our culture

The priorities within this strategy are based on doing the right things very well, balancing priorities and thinking holistically about our work. As many of these considerations are interconnected, the skill is carefully balancing these many perspectives.

To assist we have developed our vision and mission, to complement the service and learning culture fostered over many years.

Vision and mission

Vision statement

We will make the difference, inspire the future and help make lives better.

Mission statement

Procurement will take a lifecycle approach, champion innovation and develop practical, sustainable solutions which promote value for citizens.

Using innovative and practical procurement practice, we will work with stakeholders to support the Council’s strategic priorities.

Strategic procurement themes

Here are some of our top procurement themes. They interrelate as a balance of considerations, are not in order of priority nor are they exhaustive. The approach works in line with organisational objectives and the National Procurement Strategy, and will develop over time.

These themes will be promoted across services through the procurement approach and performance will be monitored for continuous improvement.

Support organisational objectives

Procurement is an enabler which supports the Council’s objectives.

Our priorities include:

Procurement awareness

  • Maintain excellent links with procurement portfolio holder and Member group including:
    • Members Masterclass events and focus sessions
    • Excellent links with the Council’s Leadership teams

Support future service design

  • Early procurement involvement in service planning
  • Promote community and service user input to support effective service design
  • Consult service providers to build supply market skills into service design
  • Support Service Delivery model decision making and strategy into action

Support daily activities

  • Daily operations across the Council’s business
  • Promote procurement support for public sector partnerships and income generation/cost recovery to support partners as appropriate

Continuous learning

  • Identify continuous learning opportunities and share knowledge widely
  • Undertake support and challenge role to support effective decisions

Promote equality and diversity objectives

Work with services to ensure equality and diversity considerations are central to the procurement approach, helping build a society where everybody can thrive.

Key message

Attuned to organisational strategy with an enabling procurement environment.

  1. Promote procurement as an enabler to support the organisation’s strategic objectives and daily operations.

  2. Ensure Equality Impact statements are undertaken and actively contribute to the procurement approach and monitored through contract duration.

Global climate emergency

Devon Climate Declaration

Devon’s Climate Declaration had been published and a Devon Climate Emergency Response Group established. Procurement considerations are part of the Council’s Environmental Performance Board which is working in response to the climate emergency.

This includes working with service providers to reduce carbon footprint in line with developing commitments. This will include measurement and reduction of carbon emissions towards Devon’s net-zero ambition. It will carefully consider specifications and standards and a total lifecycle approach to consider long term impact.

Procurement activity will underpin the Council’s climate emergency activities by supporting carbon emission data, renewable energy, waste management strategies and climate enhancement initiatives. We will work with services, communities, external partners and supply markets to show leadership, improve standards and enable investments which support environmental sustainability priorities and play our part in tackling the global climate emergency.

We will promote local service delivery, reduce road miles, help de-carbonise the supply chain and support opportunities for local supply in our procurement approach.

Key message

Our procurement approach will underpin the Council’s Climate Change Action Plan

  1. We will prioritise procurement support for climate emergency activity.

  2. Work across the Council to reduce Devon’s carbon footprint including supply chain carbon reductions.

  3. Lead the improvement of environmental quality standards and specifications, invest in lifecycle planning and prioritise environmental wellbeing.

Prioritise local economic development and SMEs

Devon’s organisational strategy emphasises local economic wellbeing. The Council’s Procurement Strategy aims to prioritise opportunities for local suppliers, (small and medium-sized enterprises (SMEs) and voluntary community and social enterprise (VCSE)) when planning the procurement approach and that applying to do business with the Council is as streamlined as possible.

We recognise that engaging local SMEs and VCSEs is a powerful means to support the local economy. The ‘Devon pound’ brings a multiplier effect through which local service providers can upscale, create and sustain local jobs, invest in personnel, generate local economic wellbeing support, social stability, be agile and support innovation.

Service providers working within their localities bring an unrivalled appreciation of local considerations. Their contribution is tireless and they are able to direct their operations in line with fast-changing local priorities. We are mutually reliant on their success.

We recognise VCSEs can play a critical role in the health and social care sector and far beyond and look to build suitable opportunities into our approach when planning procurements.

Devon’s approach includes:

  • Applying an SME/VCSE engagement strategy for specific contracts, designing services at an appropriate scale to support engagement and local ‘Meet the Buyer’ events.
  • Approaching the competitive process in a practical way, with procedures and templates proportionate to each procurement – with early market engagement, appropriate routes to market and small lots.
  • Promoting the ‘Multiplier effect’ of the ‘Devon pound’, whereby £1 spent locally is multiplied many times over through the local economy. As organisations gain turnover, they can upscale and invest, gain resilience and support sustainable services and communities
  • Considering innovative models of service delivery such as the ‘Preston’ and ‘Wigan’ models of community participation and partnership
  • SME/VCSE use of e-procurement systems including a common system across SW procurers
  • Using Light Touch Regimes and Dynamic Purchasing Systems to support SME engagement
  • Social value frameworking, informing procurement approach and measure SME/VCSE engagement
  • Utilising VCSE sector for insights into local community requirements and support service design, with community engagement in service development
  • Building in Social Value when planning all our procurements: consider breaking down opportunities into smaller lots, ensuring SMEs and VCSEs have good opportunities to bid.
  • Encouraging partnership building between SME/VCSE sector and support smaller service providers to link with primary contractors to access supply chain opportunities
  • Ensuring fair payment and other positive practices flow through the supply chain
  • Setting annual targets for local SME/VCSE contract spend, monitoring performance and local supply
  • Considering how ‘Tail spend’ is managed and ensure it is not just the high profile spend areas which attract due attention
  • Recognise how local supply chains contribute to the Local Economic Multiplier effect

Key message

Local supply is key for sustainable services and economic wellbeing. We will promote opportunities for local community and partnership engagement.

  1. Ensure wherever possible we create opportunities for small to medium  enterprises  and  the voluntary / community sector.

  2. Promote and prioritise local economic development across our procurement engagement and delivery.

  3. Ensure we are easy to do business with and take a proportionate approach at all times.

  4. Promote supply chain opportunities between service providers and ensure good practices such as fair payment flows throughout the system.

Social value

“Social value drives everything”

Unlocking social value promotes the improvement of economic, social and environmental wellbeing, and our work must prioritise the things that bring value. Our approach includes:

  • Considering opportunities in line with the Social Value Act 2012
  • Implementing a social value matrix to maximise social value opportunities when planning procurement activity
  • Ensuring social value considerations are proportionate with the size, scope and nature of procurement activity.
  • Working in line with good practice approaches such as the national social value framework. Measuring, reporting and improving social value in financial and qualitative terms.
  • Ensuring social value is considered upfront in all procurement approaches as appropriate (e.g. quality criteria, specifications, design of route to market and contract evolution through its lifecycle).
  • Social value championing ensuring wide engagement
  • Supporting local social value creation events
  • Promoting social value across all our collaborative procurement forums and collaborating in developing a shared social value framework with other local/regional authorities.

Key message

Social value drives everything

  1. Our approach will prioritise the value ahead of the cost.

  2. We will ensure social value considerations are built centrally into the planning of all procurement activity.

Digital transformation

The Council’s strategic procurement system is closely aligned with the digital agenda, working across all our markets to seek opportunities through digital access, innovation and facilitate change.

Procurement is a facilitator of change. It links to the Council’s digital strategy and ICT roadmap, to identify opportunities for digital change and harness opportunities from specialist and innovative service providers.

We will support digital transformation and modernisation opportunities across the Council, partners, stakeholders and service users to improve quality outcomes, promote wellbeing and efficiency. We will improve citizen experiences, support fitness for the future and transformational change. Digital opportunities through the procurement approach include:

  • Supporting service re-design
  • Enabling agile working and flexibility
  • Increasing efficiency through use of better devices, hardware and software systems
  • Cloud commissioning/remote hosting approach
  • Supporting better IT infrastructure
  • Using data and business intelligence
  • Maximising benefit created through technology such as Devon’s Digital Platform
  • Innovating
  • Working to modern e-government standards including cyber security and information governance

Key message

We will support digital transformation throughout services, reduce waste, automate, digitalise, innovate, transform, simplify, streamline. Ensuring the citizen and efficiency is at the heart of what we do.

  1. We will seek opportunities for digital transformation across all service areas to improve all areas of our overall public service.

  2. Be at the forefront of utilising new innovative technology to improve our user experience.

Contract management and performance regime

Contract management is vital to service performance. It supports overall service quality, value for money, promotes continual innovation, agility and flexibility, supports early intervention and encourages collaborative service development.

As we increasingly work with external partners through a commissioned approach, the importance of contract management grows. This requires clear objectives and measurement of what’s important to people. We take a proportionate approach to contract management ensuring considerations of strategic, political and citizen importance are within the performance regime.

Contract management focuses service delivery towards quality performance, making efficiencies and achieving cost reductions, increasing social value opportunities, decreasing environmental footprint, mitigating risks, increasing resilience and harnessing continuous innovation and change.

Our priorities for contract management include:

  1. Working with strategic suppliers at regional level via supplier relationship management.
  2. Collaborative framework management and focus sessions.
  3. Leading nominated SW region supply focussed initiatives – such as the SW Procurement Portal, property construction and maintenance.
  4. Promoting supply chain opportunities through ‘Meet the Buyer’ events.
  5. Performance monitoring of suppliers and supply chain. Measures include financial resilience, service quality and continuity, supply chain unlocking partner opportunities, monitoring prompt payment, modern slavery, carbon footprint and road miles, market dominance, early problem resolution. Ensuring all parties are held mutually to account.
  6. Sharing supply side intelligence with partners to support joined-up public service.
  7. Updating the Leadership Team around performance of cost, time and quality.
  8. Ensuring governance and control over provider performance through good measurement and reporting. Ongoing performance reviews and meetings.
  9. Observing visibility of potential risks and ability to mitigate these to avoid underperformance / disaster with early intervention (for example, inclusion of ‘Termination on Insolvency, Change of Control, and Breach of Warranties’ clauses).
  10. Understanding market development opportunities, innovation and value creation; ensure contract agility and continual development.
  11. Post contract review meetings and lessons learned sessions including exit strategy.
  12. Maintaining contracts register including risk and opportunities registers.

Key message

We need to measure what’s important to people.

  1. Support services to develop contractual arrangements that facilitate effective contractual relations.

  2. Maximise the benefits realised through purchaser to provider relationship management.

Value for money and benefits realisation

Our services prioritise value for money and our supply competitions include specific criteria which identify the critical success factors for each opportunity. We optimise the performance of our contracts and prioritise value for the people of Devon. We promote service quality and lifecycle value with performance, sustainability and longevity in mind.

Procurement activity requires the highest standards of probity, transparency and fair competition. This includes adherence to the Council’s Code of Business Conduct and strategic procurement good practice and operating procedures.

Further details can be found in the procurement documents we publish for each competitive process and the wider considerations outlined in this strategy.

Commercialisation and working efficiently

As government funding changes, we increasingly bring sustainable models which promote service outcomes in the best possible way. This includes the following approaches:

  • Income-generating/cost recovery through procurement services for other public bodies.
  • Developing ideas for further cost reductions and revenue generation opportunities.
  • Maximising commercial attractiveness by aggregating requirements if appropriate.
  • Bringing innovative ideas for service delivery (for example, creation of trading services).
  • Utilising frameworks and dynamic purchasing systems for operational efficiency.
  • Engaging and researching the market for up-to-date intelligence.
  • Developing procurement strategy and documentation for each competition to ensure opportunities are attractive for the market and include innovation and value creation.

Key message

Value is at the centre of everything we do.

  1. We will seek income generation/cost recovery opportunities with a good organisational fit which enables us to support partners, promote joined up public services and reinvest in our skills.
  2. Investing in our team will enable us to support our own financial sustainability, continuously develop our skills base and maintain our strategic procurement offer.

Risk appetite and risk management

“We just need to be brave enough”

Being responsible for sometimes complex services for which innovation and transformation come as standard, but also requires risk appetite to pursue our objectives. This demands a balance between the benefits of innovation and the appropriate awareness of risks this can carry.

Risk management is important to our activities and is part of good governance.

Risks are identified and made transparent, with mitigations considered and implemented within the contract management approach.

This also requires that risks are appropriately apportioned through our contracts and sit with whichever risk owners are best placed to manage them.

This ensures service providers do not take on inappropriate risk and then build risk allocations into their proposals; we can then provide better assurance and reduce costs in the system.

Our approach includes the following:

  • Procurement and Services collaboratively designing contract specifications to include risk identification and mitigation – for example supplier resilience and business continuity.
  • Identifying risk ownership and mitigation assurance.
  • Reporting and monitoring of suppliers’ input and responsibilities.
  • Developing and applying suitable terms and conditions for contracts.
  • An appetite for innovation.
  • External environment monitoring and identifying risk implication and mitigation in relation to strategic contracts (for example, Brexit, financial resilience, monitoring service outcome deliverables).

Key message

We need to be brave enough. We will maintain a responsible approach to risk appraisal and oversight.

  1. Procurement will support risk appraisal areas and help identify appropriate ownership and mitigation of risk amongst stakeholders

  2. We will create an environment of opportunity and promote innovation.

Working with partners

We believe partnership should be a principle of how public service is organised. Our procurement philosophy is a ‘one team’ approach working with networks to ensure resources are applied efficiently, needs are understood, knowledge is shared, and innovative solutions are implemented.

We prioritise early stakeholder involvement and recognise the value in service co-design, consultation and working together. We promote early engagement, collaboration, collective intellect and partnership, and recognise that competition can in some cases risk driving out co-operation in service design.

We engage with local public partners (examples the Devon and Cornwall Procurement Partnership, district councils, clinical commissioning groups, the National Health Service, the police service, fire service, education sector partnerships, SW Procurement Board, and other regional councils) to uncover benefits which can be derived through collaboration.

We also look to community groups, service providers and reference groups to build in intelligence and local service knowledge into the planned approach.

We see advantages of a collaborative approach including:

  • the avoidance of duplication of effort/ resources and working in silos/ the fostering of cooperation across internal departments and with external partners
  • joint planning and budgeting processes
  • strong cross-organisational governance structures
  • a cross-functional project management approach and shared support/resources
  • greater economies of scale and cost savings

Key message

We promote collaborations and partnerships which are greater than the sum of the parts.

  • While recognising the value of competition, we recognise it can drive out collaboration; we will look to the big picture in supporting relationships.

Client of choice

It is important our approach enables us to be the client of choice. Service providers have choices around which clients to prioritise, and to secure the best outcomes for the people of Devon we should be a client of choice.

In practice this includes being easy to do business with, practical and consistent in our approach, transparent and diligent, communicating well and seeing things from a supply-side perspective. This requires early planning, market communications, risk allocation, meeting our commitments and holding to our principles.

We plan procurements to accommodate SMEs and VCSEs, use small Lots as appropriate and build contracts of sensible scale. Supporting measures include prompt payment, avoiding onerous contract terms, meeting our timescales, good implementation planning and quality relationship management.

Adversarial contractor-provider relations should stay in the past. We believe the best way to achieve great outcomes is working constructively together in a full systems approach. We aspire for Devon to be a client of choice and this will help bring about the very best outcomes for the people of Devon.

Workforce skills development

We rely on the skills of our people and all those we work with for their professionalism, diligence, knowledge, open-mindedness and leadership.

We are committed to lifelong learning and continual professional development. Our procurement team are professionals who bring unique skillsets, expertise, technical knowledge and offer peer challenge and support.

We aim for high-quality procurement support at all times. This requires continuous development of skills and competencies, diversity, broad exposure to experience and learning, and cross functional working with services and market areas for knowledge development.

This brings team mentoring,formal professional development and links to industry forums, partnerships and learning events.

We invest in skills development to evolve our service, improve resilience and link back to our purpose of supporting Devon’s communities by providing high quality public service.

We value and embrace diversity and equality at the heart of what we do.

This includes:

  • linking with HR strategy to encourage workforce development and diverse experiences
  • identifying leadership development opportunities
  • seeking career development opportunities
  • promoting a management and mentoring approach
  • cross matrix working and working across disciplines
  • applying apprenticeship programme and wider staff development
  • workforce development strategy

The team has achieved milestones along the way including regional and national recognition:

Shortlisted nationally:

  • Chartered Institute of ‘Purchasing and Supply: ‘Most Improved Purchasing Operation’
  • CIPS Best Cross Functional Teamwork Project
  • Constructing Excellence awards – Value award

SW regional winners (jointly with our partners at Hampshire County Council):

  • Constructing Excellence SouthWest – Value award
  • Local Government Commercial Awards Public Private Partnership Award
  • Chartered Institute of Building South West Built Environment Awards – Integration and Collaborative working

Key message

We invest in our team for continual learning, embrace autonomy and shared purpose.

  1. Workforce strategy which supports and enables professionals to continually develop their knowledge and make ever greater contributions. Ensure personal accountability and continual learning help.

  2. Continuous review of internal and external forces, developments and opportunities to help our services be more efficient, effective and smart. Glean quality information to measure and inform performance.

Ease of doing business

Procurement can sometimes feel complex due to many competing priorities. We work hard to stay structured, methodical and easy to do business with. We take a proportionate approach and work transparently. This requires balancing many alternative perspectives, as we think widely about our procurement approach from a range of alternative perspectives.

As being a pioneer South West authority to implement e-tendering, for the SW regional Procurement Board we have supported the regional uptake of a common e-tendering platform for many years. This ensures our suppliers have a common system to embrace opportunities to work with SW public bodies, as a joined-up supply-side experience which promotes ease of doing business.

Transparency

Devon Procurement Services works transparently. We ensure our operations are well structured, logical and predictable, and that our procurement procedures are transparent, practical and easy to engage with.

The service supports the transparency regime; the Council publishes details of all spending over £500.

The team links with Information Governance and supports information enquiries from the public, many of which link to DCC’s contractual arrangements. Previous freedom of information responses can be found here.

Key message

We will be a client of choice. In meeting our obligations, we prioritise purpose over process.

  • Openness, transparency, fairness, sustainability, resilience, equity and democracy.

We apply the legal framework in an enabling manner which allows us to work fairly, transparently and consistently. Considerations include:

  • common appreciation of legal considerations Council-wide including highly integrated working with Devon’s Legal Service
  • staying continuously up to date with the developing public sector legal framework
  • embedding service-specific legislation such as Care Quality Commission, OFSTED requirements and building controls
  • modern slavery measures and compliance checks – collaboration with the Policy Team
  • innovation and consistent approach
  • information governance and GDPR measures and compliance checks – collaboration with the Information Governance Team
  • assisting internal stakeholders and external partners in procurement compliance
  • ensuring ethical trading standards are supported by the supply chain
  • working with the Council’s Equality and Diversity Policy
  • considering opportunities available through legislative change such as Brexit
  • counter fraud measures and awareness of procurement fraud risk

Key message

We apply the legal framework in an enabling manner and maximise opportunities from legislative change.

  1. We will apply the legal framework to ensure our operations are consistent, practical and innovative and legally compliant.

  2. Ensure our procurement practises are compliant with all relevant legislation and reflect the latest best practise resulting from case law.

United against modern slavery

We are united against Modern Slavery and Devon County Council’s modern slavery statement is available here.

As part of the SW Procurement Board, we have a joint approach in which all its members stand united in our commitment to positively contribute to both influencing and supporting the National Procurement agenda across the public sector.

We aim to do this by providing a strategic voice with links into national policy, best practice and emerging changes to commissioning, procurement and supplier relationship management.

We can all make a difference.

Key message

We are united against all aspects of modern slavery and will take a unified approach with regional partners.

  1. Work across the Council and the SW Procurement Board to raise the profile and bring attention to this area.

  2. Undertake supply market assessments and focus reviews to uncover and eliminate slavery from our supply chains and all areas of activity.

You can download and print a PDF version of the Strategy here.

Please note that this document was designed for printing purposes only and with that in mind will not be fully accessible to someone using assistive technology such as a screen reader.