21st October 2022
Our Ref: NNL CEO/UN/L1069

To our stakeholders:

I am pleased to confirm that the National Nuclear Laboratory Ltd reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Yours sincerely

Dr Paul Howarth FREng
Chief Executive Officer

NNL has an Anti-Slavery & Human Trafficking Policy in place with the intention to ensure the protection of all persons working for the company, or on its behalf, in any capacity.x

The NNL policy applies to all persons working for the Company or on its behalf in any capacity.

The policy:

Ensures the Company acts ethically and with integrity in all its business dealings and relationships and that it implements and enforces effective systems and controls to ensure modern slavery is not present in or through our business.

Ensures there is transparency in the business and in the approach to tackling modern slavery throughout the company's supply chains, consistent with the disclosure obligations under the Act.

Any violation would be escalated to the senior leadership/executive team. Day-to-day responsibility is held by the Head of Procurement.

Our internal policies form part of our integrated management system (IMS) and are underpinned by policy implementation matrices. The management system audit function and compliance team provide second-line assurance of these, with oversight from the independent assurance function.

NNL is committed to applying the highest of standards in relation to worker rights and protections and this is applicable to workers directly and indirectly, through our supply chain.

We have developed a raft of policies which support the standards set by the UN Principles. These are as follows:

1. Safeguarding Policy - in place - Commitment to protect children, young and vulnerable adults from harm. Purpose: To protect people, particularly children, at-risk adults and beneficiaries of assistance, from any harm that may be caused due to their coming into contact with our organisation.
2. Dignity at Work Policy - In place - Overarching Company policy - currently under review. Purpose: To ensure that every employee, customer or supplier is treated with dignity and respect and that the Company is free from discrimination, bullying, harassment or victimisation of any kind.
3. Collective bargaining arrangements - In place - Recognition of Trade Unions and formal TU collaboration. Purpose: Ensures all employees know that they have the legal right to belong or not to belong to any trade union and which unions the Company has recognised for consultative and collective bargaining purposes. To state that the Company regards consultation and collective bargaining with its recognised unions as a positive aid to the effective conduct of its business and the application of its employment policies. To confirm the arrangements by which the Company and unions consult and negotiate.
4. Whistleblowing Policy - in place - Anonymous reporting of concerns through an independent body, reviewed annually by the board. Purpose: To provide a safe and confidential environment which protects individual(s) who wish to disclose information about irregular practices at work which are a cause for serious concern and/or could place the Company in a vulnerable position. To ensure the rapid escalation of major concerns to the Board and protect the individual who has raised the concern.
5. Security Vetting process - In place - ID, Right to work checks. Purpose: To underpin the Security policy with regard to the Vetting of Personnel. Ensure that all staff, agency-supplied workers and contractors are vetted and issued with appropriate clearances in order to have access/information with the company.
6. Bullying and Harassment policy & procedure - In place - Standalone Policy currently in development. Purpose: To clarify the standards and behaviours the Company expects all employees to uphold to ensure it sustains a work environment where everyone treats each other with mutual respect, and conducts themselves in a professional manner that does not violate the dignity of others. To outline what constitutes bullying, harassment, and victimisation and what to do where employees feel standards and behaviours fall below the expected standard - Complements the Company's Dignity at Work policy.
7. Disciplinary policy & procedure - In place - currently under review. Purpose: To provide a consistent, fair, and systematic approach to help and encourage employees to achieve and maintain the Company's required standards of conduct and behaviour.
8. Grievance policy & procedure - In place - currently under review. Purpose: To provide employees with a clearly defined process for resolving any grievances (concerns, problems, or complaints) about work, the working environment or working relationships.
9. Gender pay reporting - In place - Published annually. Purpose: To comply with The Equality Act 2010 (Gender Pay Gap Information Regulations 2017). To outline the activities that have been undertaken to improve equality in the business. To eliminate any gap in gender pay.
10. Family Focused policy and procedures - In place - enhanced benefits supporting families, maternity protection rights. Purpose: This suite of policies explains employee rights and entitlements, leave, and pay procedures for all types of family leave to help them consider their options. This policy covers maternity, paternity, shared parental, parental, adoption, foster care, neo-natal and parental bereavement.
11. Working Time Directive Regulations recognised - In place - Working hours of employees monitored - currently under review. Purpose: To restrict excessive working hours which may adversely affect the well-being of employees.
12. Health & well-being Initiatives - In place - Annual medicals for staff working in hazardous areas - ad hoc initiatives. Purpose: To ensure that all employees ​​feel supported, safe and secure at work. To help the Company's line leader community support employees in their day-to-day lives both at work and at home. To assist managers in supporting their teams from a well-being perspective.
13. Equality, Diversity and Inclusion initiatives and strategy - In place. Purpose: To support the Company in achieving its aspirations of equality and diversity. To improve the Company's attraction, recruitment, and promotion processes so that they are transparent, fair and people-centric.To support the Company in achieving its aspiration of inclusivity. To ensure that leaders, managers and employees champion everyone regardless of their particular combination of protected characteristics or their life circumstances.
14. Occupational Health - In place - access to occupational health services. Purpose: To provide a service that promotes and preserves both the physical and mental well-being of all staff by ensuring that the work environment is safe and that a person's health is not adversely affected by their work activities. To assist in sign-posting line managers and provide awareness to staff to relevant occupational health information and guidance and to allow them to adequately manage occupational health issues.
15. Job Evaluation - In place - job evaluation based upon the Hay methodology. Purpose: To enable a fair and transparent process for the grading of roles. To ensure that the company in complies with legal requirements in relation to equality and best practice by providing a non-discriminatory scheme in which employees performing work of equal value receive equal pay, regardless of gender, race and disability.
16. Progression and promotion - In place - Pay pod scheme in place to progress through the pay bands. Purpose: To give opportunity for all employees to progress in terms of monetary reward for competent and enhanced performance and contribution.
17. Annual Leave provisions - In place - Enhanced provisions in place (above statutory). Purpose: Ensure employees understand the annual leave allowances, and the arrangements to anticipate or carry over leave.
18. Training and Education concessions - In place - Access formal training courses and qualifications. Purpose: To enable the development of employees in order to increase the skills and capabilities of the workforce as a whole and to support individuals in reaching their potential. To ensure that funding is protected and that it continues to be available and accessible to all staff.
19. Recruitment and selection training In place - Licence to recruit training (including unconscious bias). Purpose: To ensure that recruiting managers are trained in the use of the company recruitment and selection procedures. To ensure that the company operated a fair and equal process.
20. Mandatory training on ED&I - In place - all employees to complete. Purpose: To ensure employees are aware of the policies and procedures that are in place that ensure that the Company achieves its aspirations of equality, inclusion and diversity, To improve the Company's attraction, recruitment, and promotion processes so that they are transparent, fair and people-centric. To support the Company achieve its aspiration of inclusivity. To ensure that leaders, managers and employees champion everyone regardless of their particular combination of protected characteristics or their life circumstances.

Please see the above and below

All policies and programmes are regularly reviewed and anomalies are flagged to the NNL Executive, via the CHRO

Our internal policies form part of our integrated management system (IMS) and are underpinned by policy implementation matrices. The management system audit function and compliance team provide second-line assurance of these, with oversight from the independent assurance function

Measures relating to specific policies/programmes are as follows:

Safeguarding Policy - Number of cases + any trends in cases
Dignity at Work Policy - Number of employees who have completed the training, Number of related cases, Any trends in cases
Collective bargaining arrangements - No measure is in place
Whistleblowing Policy - Number of concerns raised
Security Vetting Process - Records that all staff have the appropriate clearances
Bullying and Harassment Policy & Procedure - Number of cases
Disciplinary Policy & Procedure - Number of cases, Any trends in cases
Grievance Policy & Procedure - Number of cases, Any trends in cases
Gender Pay Reporting - Comparison of the mean pay and bonus pay for men and women. Comparison of the median for basic pay and bonus, for men and women. Comparison of basic pay by salary quartile and business areas. Number of part-time workers and full-time workers
Working Time Directive Regulations - Number of employees working more hours than the maximum average weekly working time. Number of employees not having the required rest periods
Health & Wellbeing Initiatives - Absence from work levels. Level of absence by cause of sickness (as specified by the HSE and IOM). Number of people who use the Company Employee Assistance Programme and for what reason
Equality, Diversity and Inclusion initiatives and strategy - Demographics of employees broken down by diversity factors (e.g. ethnicity, gender etc)
Occupational Health - Number of OH referrals in relation to employee health and well-being or absence
Progression and Promotion - Number of employees who go through pay progression
Annual Leave Provisions - Percentage of leave planned and taken
Training and Education concessions - Number of applications for training and higher education. Training spend per employee
Recruitment and selection training - Number of hiring managers to have completed the training
Mandatory training on ED&I - Numbers of employees who have undertaken the mandatory training

NNL is committed to applying the highest standards of environmental stewardship and protection.NNL maintains ISO 14001:2015 Environmental and ISO 50001:2018 – Energy Management accreditation

NNL maintains ISO 14001:2012 Environmental and ISO 50001:2018 Energy Management accreditations

NNL is a named Organisational Partner of BEIS, actively delivering Net Zero, via the UK Government Greening Commitments(GGCs).

Additionally, NNL is currently working with a consultancy to develop a net zero transition plan for Scopes 1 & 2 (2030 target) and to assess Scope 3 baselines and pathway to net zero

NNL’s integrated management system comprises the arrangements for environmental management (EMS), energy management (EnMS), occupational health and safety (OH&SMS), security and information security management (ISMS) and quality management (QMS), and is fundamental in terms of governance for the organisation.

The arrangements defined apply to all NNL personnel, staff or agency-supplied workers. A summary of the activities undertaken by NNL is as follows:

Technology development and support services to projects and operational plants (mainly but not exclusively for nuclear facilities) including conceptual design studies, provision of technical, engineering, analytical, safety, and environmental services and the provision of required supporting infrastructure and facilities. Design, manufacture, installation and commissioning of test rigs. Modification of existing rigs and facilities. Design of facilities to support optioneering studies. The provision of nuclear-related training to clients.

The Integrated Management System (IMS) scope covers all aspects of the above by interpretation of the law, regulations, nuclear site licence requirements and customer requirements, through this context document, the ISO 9001, ISO 14001, ISO 50001, ISO 27001 and ISO 45001 standards, policies, management reviews, objective setting, risk criteria, procedures, instructions and guidance.

• Environmental Management System (EMS)

The EMS provides the framework used by NNL to assure and demonstrate compliance with environmental legislative and regulatory requirements, and to measure, monitor control and where possible reduce environmental impact from its operations and activities.

Both the EMS relates directly and specifically to the full scope of NNL’s activities (see above).

Aligned with the QMS and EMS, NNL sets its quality and environmental & energy management strategies, together with associated objectives, via long-term strategy documents. These strategies are underpinned by quality and environmental & energy management improvement plans.

EHSS&Q (plus Energy mgt) objectives and key performance indicators are communicated and monitored via the company-wide EHSS&Q performance monitoring and improvement processes.

• Energy Management System (EnMS)

The EnMS is used by NNL to plan for optimised energy usage in the delivery of its commitments to customers and to identify opportunities for energy saving and reduction and introduce improvements where possible and practical. This relates specifically to Energy management related to the offices (excl Welsh Office), all laboratories and processing sites of the National Nuclear Laboratory and incorporates the office-based activities undertaken by NNL Holdings plc at the NNL Risley office location.

Aligned with the EnMS, NNL’s energy management strategy and objectives are included in the environmental & energy management strategy and associated environmental & energy management improvement plan. The energy management objectives and key performance indicators are communicated and monitored via the company-wide EHSS&Q performance monitoring and improvement processes.

As such, NNL’s EnMS is wholly applicable to the needs of those stakeholders that we deal with. NNL’s aim is to continually improve its EnMS through maintenance, review and modification of processes while taking into account any new energy consumption demands relating to new operations, services, facilities or changes in workforce numbers (headcount as they arise).

The EMS provides the framework used by NNL to assure and demonstrate compliance with environmental legislative and regulatory requirements, and to measure, monitor control and where possible reduce environmental impact from its operations and activities.

Our internal policies form part of our integrated management system (IMS) and are underpinned by policy implementation matrices. The management system audit function and compliance team provide second-line assurance of these, with oversight from the independent assurance function.

NNL is committed to applying the highest standards of ethical conduct and having robust controls in place to prevent bribery. NNL takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships wherever it operates and implementing and enforcing effective systems to counter bribery and corruption.

NNL carries out thorough due diligence on both its customers and suppliers which involves contracting on terms which ensure that the parties (and any sub-contractors appointed by them) commit to not breaching the Bribery Act 2010.

NNL’s zero-tolerance approach to bribery and corruption is set out in further detail within the Anti-Bribery and Corruption Policy (currently in review with our Trade Union), and across a range of other policies and procedural documentation. This applies to all staff and non-executives, together with contractors and agents working or acting on behalf of NNL. NNL requires all its personnel at all times to act in an honest and ethical manner.

All NNL employees are responsible for gaining an understanding of the requirements, the standard of conduct expected of them and ensuring that they comply at all times with the Anti-Bribery and Corruption Policy. This includes those in relation to procurement, hospitality and the acceptance of gifts.

Any act of bribery undertaken by an employee of NNL will result in appropriate legal and/or disciplinary action being taken by NNL.

The success of NNL’s anti-bribery measures depends on all employees, and those acting for NNL, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on the behalf of NNL are encouraged to report any suspected bribery in accordance with the procedures set out in either the Reporting Concerns at Work or the Anti-Corruption and Bribery Policy.

NNL ensures that appropriate training on the Antibribery and Corruption policy is mandated for all employees to attend.

Our internal policies form part of our integrated management system (IMS) and are underpinned by policy implementation matrices. The management system audit function and compliance team provide second-line assurance of these, with oversight from the independent assurance function.