Modern Slavery Act Statement

This statement has been published in accordance with the Modern Slavery Act (2015). It details the steps that GTS Rail Operations Limited (trading as GTS) has taken to prevent and identify risks of modern slavery within our direct operations and supply chain during the 2025/26 financial year.

It also covers the measures which we have in place to monitor the effectiveness of our actions and continuous improvements in this area.

Introduction by the Managing Director

Slavery and human trafficking, in all its forms, is an abuse on individual freedom and human rights. As a business, we recognise the importance of the Modern Slavery Act and are fully committed to doing all we can to ensure our operations and our supply chain are free from instances of modern slavery. We are proud of the steps we have taken, and that we continue to take, to ensure we can identify and remove any unacceptable practices from our operations and supply chain.

Our Business

GTS Rail Operations Limited is the concession operator of the Elizabeth line, London’s newest high-capacity railway. The Elizabeth line stretches over 100 km, connecting 41 accessible stations from Reading and Heathrow in the west to Shenfield and Abbey Wood in the east, including ten central London stations. At peak times, the line operates up to 24 trains per hour through its central section, offering direct, frequent journeys across the capital.

Our Structure and Supply Chains

GTS currently has 1,297 employees and97% of our employees are employed full time. We conduct comprehensive checks on all prospective employees throughout the interview process. These checks include but are not limited to right to work checks,  are carried out and verified by a third party.

Our supply chain covers the provision of services that support us in the delivery of the railway. We also work with third party suppliers for the provision of indirect goods and service requirements such as staff uniforms and the delivery of station upgrade and enhancement works.

London Living Wage

GTS is committed to paying its own staff and suppliers the London Living Wage. We also require our suppliers and subcontractors to pay their employees an hourly wage (or equivalent hourly wage) equal to or greater than the London Living Wage, as adjusted annually.

This obligation applies to all suppliers’ employees, both directly and indirectly employed, who perform duties in relation to the railway:

  • Within the Greater London Authority Area;
  • Outside of the Greater London Authority Area where the person is engaged at an GTS station or facility; or
  • Outside of the Greater London Authority Area where the person is engaged at other premises (including the supplier’s own premises) within the control of the boroughs of the Greater London Authority and proximate to the Elizabeth line route.
Our Sourcing Approach and Due Diligence

Our standard terms of business include clauses covering Modern Slavery Act compliance by suppliers. These terms raise awareness of the Modern Slavery Act and our supplier’s individual obligations. The terms require a supplier to notify GTS if it becomes aware of any instances of modern slavery within its operation or supply chain and detailed action being taken to address the issue.

All prospective new suppliers to GTS are required to complete our Supplier Questionnaire (SQ). This is mandatory for all prospective and new suppliers. The supplier responses are assessed against quality, financial, sustainability and ethical trading criteria.

Within the SQ, suppliers are required to confirm their Modern Slavery Act reporting requirements and to provide details of their statement and the actions they are taking to reduce the risk of modern slavery in their operations and supply chain. Where suppliers fail to meet our requirements, improvement plans are agreed. If issues are not resolved within a specified timeframe, the supplier will not be on-boarded or granted approved supplier status.  Approved suppliers are required to keep this information up-to-date to ensure that there is regular monitoring.

Risk Analysis and Monitoring

We undertake an annual risk analysis exercise of our tier one suppliers. This takes into consideration the level of risk exposure driven by the location of the supplier, the industry type and labour employed in the delivery of the goods/services. A risk profile is then assigned to individual suppliers.

Based on the risk level assigned to a supplier, we develop annual monitoring plans with individual suppliers, if required. Example actions include developing and monitoring corrective action plans. 

We recognise the complexity of modern slavery and the many different forms it can take. Through the risk assessment exercises that we undertake, we are able to identify the categories of products/services associated with the delivery of the railway that bring an elevated level of risk. As a result, we gain a greater understanding of our supply chain network as a whole in order to bring it under closer management, review trends within our supplier risk environment, and monitor our progress in managing these risks year on year.

The categories that we have identified as presenting a higher level of risk are contracts involving labour e.g. station retail cleaning, selected types of products and solar panels. 

As a business, we have implemented a robust approach to due diligence in the area of managing and monitoring supply chain risks and general supplier management. To support this we have implemented a procurement processes to manage interactions with our supply base. These, coupled with the due diligence process and the risk assessment, gives us the required visibility to monitor our suppliers and tools that allow us to work collaboratively with them to address issues.

Building on this we have implemented a structured framework for managing supplier relationships, allowing information on supply chain performance to be monitored and updated regularly. This covers performance against contractual requirements, sustainability and supply chain performance and monitoring. Our management of these elements of supplier performance allows for the information to be captured and updated by suppliers efficiently and regularly. 

In addition, we encourage suppliers to register with Sedex where they can maintain data on labour practices at the factories and facilities they use, and make this data available to GTS to drive and demonstrate monitoring and improvements in the supply chain. 

Awareness Across the Business

The direct management of our supply chains is undertaken by a small number of people in our business; however, we recognise that it is everyone’s responsibility to ensure that working practices are in line with our company purpose and objectives. 

Many of our business policies contribute to ensuring we are working to prevent the existence of modern slavery within our business and supply chains. These policies are:

  • Equality & Diversity Policy
  • Procurement and Tendering Policies and Procedures
  • Qualification and Supplier Management Procedure
  • Whistle-blowing Policy
  • Safety Management System Procedures
  • Anti-Bribery & Corruption Policy
  • Anti-Slavery and Human Trafficking Policy

The Anti-Slavery and Human Trafficking Policy covers the measures that the business has in place to prevent instances of modern slavery from occurring, individual responsibilities and issue reporting.

The organisation ensures training on the Modern Slavery Act and how to identify and manage risks within the supply chain is provided to necessary staff. This is undertaken via our e-learning platform by those responsible for managing our tier one suppliers thus increasing awareness of risks and reporting. Training on ethical sourcing is delivered to all other colleagues responsible for working with third party suppliers.

Monitoring the Effectiveness of our Actions

To ensure that we are able to effectively track our progress in the key areas outlined in this statement we have implemented the following key performance indicators (KPIs) to monitor our progress:

  1. Number of suppliers on-boarded through the supplier due diligence process (Approved Supplier Questionnaire, ASQ), for both new and existing suppliers;
  2. Number of suppliers identified as high risk engaged with through the creation of action plans;
  3. Number of suppliers being monitored;
  4. Number of employees who have completed the Modern Slavery Act training on ethical sourcing training.

This constitutes our company’s Modern Slavery Act statement. The statement has been approved by the Executive.

Chris Fowler 

Managing Director, GTS

May 2025