Modern Slavery and Human Trafficking Statement
Section 54 of the Modern Slavery Act 2015 requires some organisations to produce and publish an annual modern slavery and human trafficking statement. Although the Trust does not meet the relevant criteria to be legally required to produce and publish such a statement, it is committed to the protection of vulnerable people and does not tolerate modern slavery in any of its forms: slavery, servitude, forced or compulsory labour or human trafficking (collectively, Modern Slavery).
This statement sets out the actions the Trust has taken during the financial year to ensure that Modern Slavery is not taking place within its organisation or in any of its supply chains.
Organisational structure and supply chains
As an NHS Foundation Trust, the Trust provides an extensive range of acute hospital and community-based services for people living in and around City and Hackney.
The Trust procures goods and services from a range of suppliers and its contracts range from small, one-off purchases to large, long-term service contracts.
When choosing a supplier of goods or services, the Trust, as an NHS body, is obliged to follow strict procurement processes and to contract using NHS standard terms and conditions as well as ensuring compliance with its internal policies and procedures (see below), all of which go towards ensuring that the Trust’s activities are free from ethical and labour standards abuses.
For example, during the selection of a supplier of goods or services, the following steps are followed:
- Procurement stage: Identification and management of risks in new procurement activity (and existing contracts) by following the Cabinet Office Procurement Policy Note 02/23: ‘Tackling Modern Slavery in Government Supply Chains’.
- Selection stage: Consider the mandatory and discretionary exclusion grounds as set out in the Standard Selection Questionnaire, and if these can be supplemented with additional questions for medium / high risk contracts, whilst not creating barriers to participation by SMEs/VCSEs.
- Award stage: Apply the standard criteria in the Social Value Model, ensuring these sufficiently take account of the risk of Modern Slavery and any specification requirements, whilst taking a proportionate approach.
From a contractual perspective:
- Contractual terms and conditions: Apply NHS Standard Terms and Conditions for supplier contracts which require suppliers to comply with relevant legislation.
- Contract management: Following contract award, continually work in collaboration with suppliers to monitor and address Modern Slavery risks, including a clear process for reporting and responding to suspected incidents of Modern Slavery. The safeguarding teams for children and adults oversee all new contract agreements to ensure that the safeguarding requirements as per the NHS Standard Contract are met.
With regard to staff that are not employed by the Trust (collectively, Agency Staff):
- Bank workers are recruited under the same requirements as Trust employees following safer recruitment processes.
- Agency staff are only recruited from agencies that are on approved NHSE frameworks.
2. Organisational policies in relation to Modern Slavery
The Trust has internal policies and procedures in place that assess, identify and respond to any concerns in relation to the potential for Modern Slavery.
The Trust’s safeguarding policies include information on Modern Slavery with clear guidance for Trust employees on how to identify and respond to any concerns they may have in that respect.
All Trust employees have access to the Trust’s Safeguarding Service for support and guidance in the event they have any concerns about Modern Slavery.
The Trust’s Incident Reporting Policy states that Trust employees should report incidents of any and all kinds of incidents, including concerns regarding Modern Slavery. By using the Trust’s risk management system, appropriate teams such as the Safeguarding team and Freedom to Speak Up team are made aware of any concerns raised by Trust employees.
The Trust has appointed a Freedom to Speak Up Guardian and also Freedom to Speak up Champions. Guidance has been produced as to how Trust employees can raise any concerns confidentially. The Freedom to Speak Up Guardian or one of the Champions, will provide support to the individual raising a concern. Trust employees are provided with this information as part of their induction training.
Any identified concerns regarding Modern Slavery are escalated as part of the organisational safeguarding processes. All Trust employees have a personal responsibility for the successful prevention of Modern Slavery and are made aware of such responsibility as part of their induction, and annual refresher, training.
All Agency Staff must also comply with our policies, safeguarding processes and mandatory training requirements as if they were Trust employees.
3. Risk assessment and management
To identify and mitigate the risks of Modern Slavery in it the Trust’s organisation and supply chain:
- The Trust adheres to the National NHS Employment Checks / Standards (this includes employees UK address, right to work in the UK and suitable references).
- The Trust has systems to encourage the reporting of concerns and the protection of whistle-blowers.
- The Trust purchases a significant number of goods and services through NHS Supply Chain and the Crown Commercial Service, and the contractual documentation ‘Supplier Codes of Conduct’ includes express provisions prohibiting Modern Slavery.
- Other contracts are governed by standard NHS Terms & Conditions in which suppliers warrant that there is no Modern Slavery in their supply chains and they must notify the Trust if they become aware of any actual or suspected incidents of Modern Slavery in its supply chains.
- The Trust requests all suppliers to comply with the provisions of the Modern Slavery Act 2015, through agreement of our ‘Supplier Code of Conduct’, purchase orders and tender specifications. All of which will set out our commitment to confirming there is no Modern Slavery related to the Trust’s service provision.
- The Trust upholds professional codes of conduct and practice relating to procurement and all Trust employees that procure goods and services on behalf of the Trust are required to be members of the Chartered Institute of Purchasing and Supply (CIPS) and be qualified as a Member of the Chartered Institute of Procurement and Supply
Safeguarding training is provided for all our Trust employees and Agency Staff at the appropriate level which includes awareness of Modern Slavery. All Trust employees and Agency Staff are mandated to complete Level 1 safeguarding training, with clinical-based Trust employees and Agency Staff required to complete Level 2 safeguarding training and, where considered necessary, Level 3 safeguarding training.
We ensure that all Trust employees and Agency Staff have access to training, provided on how to identify those who are victims of Modern Slavery. The training materials are updated regularly and includes the latest information and will help Trust employees and Agency Staff develop the skills to support individuals who come use the Trust’s services. All Trust employees and Agency Staff are provided with annual refresher safeguarding training.
The Trust will continue to ensure all of its employees and Agency Staff are aware of the Modern Slavery Act 2015 and their safeguarding duty to protect and prevent any further harm and abuse when it is identified or suspected that the individual may be or is at risk of Modern Slavery. It will also continue to monitor compliance and completion of mandatory training requirements and adherence to policies and identify any applicable trends in complaints and Freedom to Speak Up cases.
The Trust will continue to ensure its employment standards, training, remuneration and policies reflect its commitment to be a high quality employer, conscious of safeguarding. The Trust will continue to ensure the safeguarding procedures document includes up to date information on Modern Slavery.
The Trust plans to research and review other ways in which it could further enhance the due diligence of its supply chain and ensure all of the safeguards against Modern Slavery are taking place and are effective.
Chief Executive Officer