Modern slavery
Section 54 of the Modern Slavery Act 2015 requires large employers to produce a modern slavery statement each financial year. This statement relates to actions and activities during the financial year 1 April 2024 to 31 March 2025.
This statement sets out our actions to:
- understand all potential modern slavery risks related to our business
- put in place steps aimed at ensuring there is no slavery or human trafficking in our own business and supply chains.
The initiatives we have put in place include:
- training for staff
- due diligence of suppliers.
We have a robust policy review programme which has input from many stakeholders. The programme is key in the Human Resource service work plan. It ensures that our policies and procedures remain compliant and fit for purpose.
The following policies and procedures are key in meeting the requirements of the Modern Slavery Act.
Employee code of conduct
Our employee code of conduct makes clear the actions and behaviours expected of staff when representing us. We try to maintain the highest standards of employee conduct and ethical behaviour. Any breaches are investigated.
Recruitment
Our recruitment processes are transparent and include procedures for vetting new employees. It ensures they can confirm their identity and qualifications. It also makes sure that people are paid directly into an appropriate, personal bank account.
Agency workers
We have a managed service contract in place for the provision of temporary agency staff with an umbrella Agency. Where staff are required from different agencies, we will verify the agency practices before accepting workers. If the agency worker is being procured through the procurement team, this would happen as standard as part of the procurement process. If the agency appointment is below the threshold where a formal procurement process is required, the service area must make sure that this is checked in line with policy.
Pay
We have evaluated our roles, and through Human Resource policies, we ensure that all employees are paid fairly.
Whistleblowing
We operate a whistleblowing policy. This encourages and enables staff, volunteers and contractors working on our behalf to speak up. They can come forward and make disclosures, without fear of reprisal or victimisation. This complies with the Public Interest Disclosure Act 1998.
Corporate complaints policy
We operate a complaints policy to deal with complaints about our services. This can be used to report:
- community concerns such as overcrowding
- issues which might reveal slavery or trafficking and which merit investigation
- reporting to a partner agency.
Safeguarding
We understand our responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and vulnerable adults and protect them from harm.
We have a comprehensive policy which all staff and councillors are expected to read and work within. We work within multi-agency partnerships to protect and safeguard people. On our intranet and website are the following safeguarding documents:
- Safeguarding children policy – internal only policy
Partnership working
We work in partnership with a wide range of agencies with the aim of preventing abuse from taking place. Where it is detected, we will report the instances of neglect and abuse through approved channels and to support victims.
Training staff on anti-slavery measures
We require some groups of staff to undertake training on modern slavery. In particular, those working with supply chains.
Awareness-raising programmes
As well as formal requirements for training, we also raise awareness of modern slavery issues among the wider work force. This is done through corporate communication channels and on the internal intranet site.
We also link to the Home Office guidance on Modern Slavery.
Due diligence of our Suppliers
The Council has a collective responsibility in preventing, detecting, and reporting modern slavery within any part of our business or supply chains.
When letting and managing contracts, proportional consideration is given around potential risks related to particular contracts, where necessary specific considerations are put in place for any high risk contracts whilst ensuring that we do not impose unnecessary burdens on those assessed as lower risk which could otherwise deter suppliers from competing for our contracts.
Whether we openly tendering for our contracts on Find a Tender or through a contract awarded through a compliant public sector framework, a range of due diligence on supplier credibility is undertaken including where appropriate assessing them against the Government’s Procurement Suitability Questionnaire (PSQ).
For any appointed suppliers who are required to under the Modern Slavery Act 2015 (e.g. all suppliers with a turnover of over £36 m) we expect them to confirm their compliance with the Act by publishing statements detailing the measures they are taking to prevent modern slavery in their supply chains.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015.
Claire Shand
Director of Corporate Services