National Gas Transmission Modern Slavery and Human Trafficking Statement 2022/23

This statement has been published in accordance with the Modern Slavery Act 2015. It sets out the steps that National Gas Transmission and National Gas Metering has and will be taking in respect of preventing both modern slavery and human trafficking within our business and supply chains for the Financial Year 2022/23 period.


We are committed to demonstrating our progress over time.  In this first statement we set out the foundational steps we will take as a standalone business to build upon the National Grid framework to embed modern slavery risk assessment and due diligence in a way that is tailored and proportionate to our business and supply chain.

National Gas Transmission

Our business operates as a regulated monopoly. We have one economic regulator for our business, Office of Gas and Electricity Markets (Ofgem). The regulator puts in place an incentive regime that ensures our interests are aligned with those of customers and society.

As both the transmission owner (TO) and system operator (SO), we own, build, and operate the high-pressure gas national transmission system, with day-to-day responsibility for balancing supply and demand in real time and we facilitate the connection of assets to the transmission system.

We play a pivotal role in connecting millions of people safely, reliably and efficiently to the energy they use. Our network comprises approximately 7,630 kilometres of high-pressure pipe, 23 compressor stations connecting to 8 distribution networks and also other third-party independent systems.


National Gas Metering

National Gas Metering is one of the largest gas meter equipment managers in the UK providing installation and maintenance services to energy suppliers within the regulated market. National Gas Metering is the asset manager assigned to manage the meters on behalf of National Gas Transmission.

National Gas Metering activities broadly cover asset procurement and logistics management; meter installation, maintenance, exchange and removal; and customer service provision.

The asset base that National Gas Metering manages is around 7 million domestic and commercial meters in March 2022, down from 8.4 million in March 2021.


Our progress summarised

In National Grid’s last statement, we said we would:


This is what we in National Gas Transmission and National Gas Metering have delivered this year, against the commitments made as part of National Grid:


Embed the process for the background checking of suppliers



This has been included in the contractual Terms and Conditions for any new tenders and onsite assurance processes.  We have developed guidance to support this requirement.


Refresh our supplier modern slavery risk assessment tool to align with Supply Chain Sustainability School (SCSS) guidance and recommendations from the Utilities Against Slavery Working Group, facilitated by Slave Free Alliance 


We have updated our risk assessment tool and supplier engagement framework to align with these recommendations and have provided these to Achilles UVDB (who provide our vendor registration system) at an industry level to support more robust questions as part of the tendering process.


Develop a Responsible Procurement Strategy to align with the Responsible Business Charter, formalising the reporting and strengthening the governance and ownership of the Statement. 


The Procurement function’s strategic focuses are Commerciality and Innovation aligned to our Environment, Social and Governance (ESG) strategy.  Procurement plays a key role in managing risk and ensuring our ESG commitments are embedded into all supply chain considerations.


Review the Operation Fort report produced by the Independent Anti-Slavery Commissioner, consider the learnings and any action points, and share these through our supply chain. 

A review of this report has been carried out and the key takeaways have been shared with the relevant departments and within our supply chain. An example of this is the use of Ethical Trade Platforms to help manage risks associated with modern slavery.


Our people

We recognise the value of our people and employ a diverse workforce consisting of 1,528 direct employees. Within National Gas Transmission and National Gas Metering we operate policies and procedures to ensure the highest standards of ethical conduct. Equality and fairness are very important to us. As a responsible business we pride ourselves on treating all employees fairly, ensuring that they are provided with a respectful, safe and secure environment.


1528 employees


41 years is the average age of our (direct) employees

26.9% of our direct workforce are female


15.4% of our direct workforce are from ‘minority’ racial or ethnic heritage


Our recruitment processes are designed to ensure equal opportunities, compliance with local legislation and that all our people have the appropriate right to work in the UK. We use employment agency partners for attracting temporary workers who are contracted to uphold the same standards of employment that we offer our direct employees.

Where we procure resource from an external source, Contract Managers actively manage our employment agency partners, to monitor that they are meeting our employment requirements, including carrying out any relevant screening, paying the Real Living Wage and adopting the “employer pays” principle. This means that no employee of National Gas Transmission and National Gas Metering should ever have to pay to obtain access to temporary or permanent work within our organisation or supply chain.

We carefully monitor this area and believe that the policies and processes we have in place mean that the risk of forced or trafficked labour being employed directly by National Gas Transmission and National Gas Metering and its employment agencies is very low.

We are committed to paying our employees, trainees and contractors working on our behalf, at least the Real Living Wage, as set by the Living Wage Foundation.


Diversity, Equity, and Inclusion

As we progress towards the completion of our sale process, we are developing our own Diversity, Equity, and Inclusion strategy appropriate for our standalone business.  Diversity, Equity, and Inclusion continues to be a priority for our business, ensuring that we have an inclusive culture where our employees can thrive and that we can continue to attract and retain talent from across a diverse spectrum of backgrounds.

Our policies

Summarised below are our policies, which collectively set the standards we require, encompassing the prevention of modern slavery in the workplace and in our supply chains.



Relevance to modern slavery

Code of Ethics

This is our company code of conduct that is applicable to employees and sets out our values and how we expect employees to behave whilst working for National Gas Transmission and National Gas Metering.

It includes sections on discrimination, harassment, bullying and human rights and sets out National Gas Transmission and National Gas Metering commitment to zero tolerance to all forms of corruption as well as the avenues available for raising concerns and how we will protect those who “speak up” about a concern.

Supplier Code of Conduct

This is reviewed, updated, and sent to all our suppliers on an annual basis and sets out the standards we expect our suppliers to work to and which they should extend into their own supply chain, whilst working for National Gas Transmission and National Gas Metering.

It includes reference to the key international labour standards including the Ethical Trade Initiative base code and the UK real living wage requirement.

We encourage all suppliers to publish a modern slavery statement regardless of legal obligation.



Our recruitment policies ensure that employees have equal opportunities, the relevant rights to work and are employed in line with all local legislative requirements.

There are stringent background checks in place for the onboarding of direct hire employees to safeguard human rights, minimising the risk of directly recruiting someone who is being forced to work or is being trafficked.

Inclusion and Diversity

This policy sets out National Gas Transmission and National Gas Metering commitments to providing an inclusive, equal, and fair working environment for all.

It recognises and respects the importance of an inclusive and diverse workforce.

Disciplinary (internal)

This policy sets out what actions will be taken where employees deliberately break the requirements set out in the Code of Ethics.

All employees know what is expected of them and the consequences for misconduct.

Anti-Financial Crimes Policy

This policy sets out our commitment to prevent financial crime and corruption. It applies to all employees and those who work on our behalf.

References modern slavery and sets out the duty of all employees to be vigilant in guarding against and reporting unusual activity or payments.

Contracted Service provider Background Checking Policy                 

This policy sets out the requirements for the background checking of contractors working for or on behalf of National Gas Transmission and National Gas Metering.

These requirements ensure that our contractors have the relevant rights to work and identification documents which include address history and previous employment checks.


Supply Chain and Due diligence

We work with around 3,500 suppliers across our National Gas Transmission and National Gas Metering organisation and spend over £600m with them. We spend approximately 60% of our annual spend with 20 organisations. Most but not all of our Tier 1 suppliers are based out of the UK and Europe.

The standards we expect, relating to working conditions, pay and workers’ rights for those working in our supply chain, are mandated into our contracts through our supplier code of conduct.

We continue to collaborate across the industry and work with our suppliers to improve approaches to identify and mitigate potential risks of exploitation.

We pre-qualify most of our UK procurement activities using a vendor registration system operated by Achilles called the Utilities Vendor Database (UVDB). During the previous financial year we worked with the ‘Utilities Against Slavery’ Working Group, to propose improvements to the Achilles UVDB questions asked in relation to modern slavery, so that they go beyond basic compliance. Through the Achilles UVDB consultation process these questions have now been finalised and will be included in the updated pre-qualification and supplier onboarding question set.

We continually review external media and use a screening service to check for adverse media, reports, fines, or sanctions against our direct suppliers and have a process in place to act on anything that is highlighted, in a timely and appropriate way.

Risk Management

We have embedded our sustainability assessment tool to consider potential risks at the initial stages of sourcing activity and to embed human rights considerations into our strategic sourcing process alongside other sustainability criteria. The tool maps to the relevant Achilles Utilities Vendor Database (UVDB) questions and requires a positive response against the key questions identified. The majority of the questions are mandatory at the pre-qualification stage of our sourcing process.

This approach is referenced in our strategic sourcing process training and has been integrated into sourcing events.

In the instance where a supplier is either unwilling or unable to provide the relevant evidence, this could result in a formal process to review the contract and influence the allocation of any future project work over the framework period.

Awareness and Training

We continually promote openness and transparency and provide avenues available to all employees and those working on our behalf to raise concerns. We have confidential helplines available, operating 24/7. Details of these helplines are available on our website, in our Code of Ethics and Supplier Code of Conduct.

We take all allegations of any type of unethical or illegal behaviour very seriously and we have dedicated ethics and business conduct teams who are trained to deal with all reported concerns sensitively and thoroughly. We carry out independent investigations and take any relevant action. Any outcomes and findings from investigations are reviewed. Senior leaders within our organisation are made aware of the investigation findings. Each year we track supporting metrics through our employee engagement survey.

Our workforce know they can safely raise an ethical or compliance concern using our helplines.

Our induction programme provides training and awareness of our company values and our Code of Ethics to all new starters. In addition, we have ongoing mandatory training for all employees on topics related to our Code and understanding the process for raising concerns.  

National Gas Transmission and National Gas Metering procurement professionals have access to additional training on human rights and modern slavery awareness. We are also encouraging our suppliers to utilise the free training and resources that are available through the Supply Chain Sustainability School (SCSS). We are promoting the use of modern slavery learning pathways available in the school and are working with other partners of the school to agree how this could be delivered at an industry level.

We have also raised awareness of our Supplier Code of Conduct within our contract management community and aspire to providing additional training to help them understand the processes that are in place and how to frame conversations with their suppliers around the human rights agenda, including modern slavery as part of ongoing contract management.

Focus areas for the remaining Financial Year 2022/23

We fully support the need to demonstrate continual improvement and commitment to tackling the risk of modern slavery and each year we will review our approach and set our commitments for the next 12 months.

With the current level of change across our organisation and transition to a standalone business, we recognise the need to keep our commitments realistic and achievable. We therefore commit to:

  • Ensure that standalone processes, policies, and procedures are in place to build upon National Grid process and allow us to formulate our Modern Slavery Statement
  • Embed and test the controls for National Gas Transmission and National Gas Metering
  • Implement a structured process for including modern slavery checks into existing site visits, assessments, and contract management practices.

This statement applies to National Gas Transmission and National Gas Metering and has been approved by the respective Boards.


Jon Butterworth

President National Gas Transmission

National Gas Transmission

Warwick Technology Park

Gallows Hill


CV34 6DA