Modern Slavery Policy at Scottish Water

Scottish Water is strongly opposed to modern slavery in all its forms and has a zero tolerance approach to inaction and coverup of any issues.  We also have a responsibility to understand the risks within our own business and supply chain, and to ensure ongoing management of those risks.

As part of this commitment, we have a number of policies and practices in place to ensure we engage our employees and procure goods and services in a responsible and sustainable way. 

The latest Modern Slavery Statement is Scottish Water’s 8th, responding to the requirements of the Modern Slavery Act 2015. Our Modern Slavery Statement is published on our website to clearly and openly state our position on responsible working practices.  

Since it published its first Modern Slavery Statement in 2016, Scottish Water has aimed to be increasingly transparent about its approach to modern slavery whilst also ensuring this approach continues to develop. 

What is Modern Slavery

The definition of modern slavery is broad and includes forced labour, servitude, slavery, human trafficking, debt bondage, forced or servile marriage, descent-based slavery and child labour

Modern Slavery Policy

Access our lastest Modern Slavery Policy below


Watch Video

CEO Alex Plant and Procurement Category Lead Lesley McIntosh explain Scottish Water's stance on Modern Slavery.<strong><p style="margin-bottom: 0cm; text-align: justify;"><br></p></strong>

Scottish Water actively encourages feedback on the content of this Modern Slavery Statement from its stakeholders. Please get in touch by EmailThis statement was approved by the Scottish Water Board of Directors on 31st August 2023. 

Supply Chain Integrity

Scottish Water is committed to an ethical supply chain. We want to work with suppliers who ‘do the right thing’ – who take issues of sustainability, human rights, and ethical practices seriously.

In practice, this means that we expect every link in our supply chain, from those we deal with directly right through to those who supply the raw materials for our goods, to not only comply with the Ethical Trading Initiative Base Code and the legal requirements of all countries they do business in but to also go beyond this. 

That means, taking a stand for workers’ rights and safety, promoting and encouraging diversity and inclusion, considering the sustainability of sourcing practices and requirements, and ensuring business is conducted in a fair, transparent, and honest manner.

Fair Work First

Scottish Water is a proponent of the Scottish Government’s ‘Fair Work First’ principle. 

This is an initiative that aims to raise employee standards within Scotland.

infographic showing elements for fair work and Modern Slavery


It means commitments on:

  • Appropriate channels for effective voice
  • Investment in workforce
  • Zero hours contracts
  • Gender pay gap and diversity
  • Real Living Wage
  • Flexible and family-friendly working practices
  • Fire and rehire practices

More information on the Fair Work First principle can be found here


Supply Chain Concern: Polysilicon

As part of our wider work to ensure supply chain integrity, some months ago, Scottish Water, led by its Board of Directors, began a deep dive analysis on the origin of a key part of our supply chain – specifically, a component material of some solar panels called polysilicon. 

Publicity since 2021 has shown that many supplies of solar-grade polysilicon across the world have been found to have links to forced labour and other human rights violations in the Xinjiang province of China.  As a result, global supply chains for solar panels have begun shifting away from a heavy reliance on products from this part of China. 

This obviously represents a clear conflict with modern slavery policy for supply chains using solar panels sourced from that region, including at Scottish Water.  

As of early 2023, Scottish Water has been doing everything it can to urgently source a new supply of solar panels that is ethically sound.  This will allow us to meet our large demand for these products as we move Scottish Water towards a low carbon future on the ambitious trajectory we’ve set out in our Net Zero emissions routemap.

Many months of work have gone in, with leadership on this issue being provided by the Scottish Water Board, and taken forward by our executive teams, alongside our leads on procurement and within Scottish Water Horizons, to investigate the issue of polysilicon sourcing in our indirect supply chain.  

There are a number of projects that require solar panel installation already underway across the company which make up an important element of our Net Zero ambitions.  We have followed UK Government guidance on these matters, and we are working with others, such as Utilities Against Slavery to influence the future supply chain in a positive way. We will therefore build out projects already under way, and then move to an ethical supply chain which means our solar panel production lines will come from new sources that have no links to modern slavery. 

We will not develop any further projects, or install photo voltaic panels in other equipment until we are assured that an ethically safe supply chain is available. 

This is a complex area, we are confident that the decision we have taken is a big step in the right direction as we focus our energies on sourcing supplies of solar panels that have no links to forced labour.  That said, we are being open and transparent that we cannot yet guarantee solar panel sources will be completely free from elements that come from the Xinjiang region and the evidence of forced labour in that area.  

Unfortunately, as things stand, no company in a similar position to us can be 100% certain of ethical origin.  Our commitment is to do all we can, working with others, to open up a solar panel supply chain that is free from forced labour as soon as possible.

The Scottish Water Board takes this issue really seriously and we are leading the way in trying to find a solution that will help us to achieve our Net Zero targets whilst also protecting human rights.

Supply Chain Ethical Oversight

The ethical integrity of the Scottish Water supply chain is the responsibility of everyone involved in procuring goods and services for our company.  But we also have a dedicated team embedded into our procurement function to make sure we are holding ourselves and our suppliers to account in this critical area of commitment.

Our leads in this area are Joe Rowan who is Scottish Water’s Modern Slavery Compliance Officer and Lesley McIntosh who is our Supply Chain Ethics and Risk Lead.  Please reach out to them if you have any questions at all regarding the ethical integrity of Scottish Water’s supply chain, our modern slavery commitments, or indeed our plans for future years in this area.