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 2020 to 31 March 2021.

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.


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.


We have evaluated our roles, and through Human Resource policies, we ensure that all employees are paid fairly.


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.


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:

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 suppliers

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those who work for us.

It is important we consider modern slavery when letting and managing our contracts. The mitigation of modern slavery risks will be considered throughout the procurement process.

We will be proportionate in our approach. We will not impose any unnecessary burdens that would deter suppliers from competing for our contracts. On this basis, we have not adopted a blanket approach to managing modern slavery risks. The approach will be proportionate based on the type of contract being procured and the risks identified.

We have criteria built into our procurement documents where suppliers can be excluded from our process. This is where they have committed offences under section one, two or four of the Modern Slavery Act 2015.

We also ask all suppliers with a turnover of over £36 million to confirm that they are meeting their obligations. They must publish statements about what they are doing to prevent modern slavery in their supply chains.

If the potential supplier is proposing to sub-contract any of the work required as a part of the contract, they must prove their method and track record of delivering and managing a supply chain.

Some contracts will carry a higher risk in terms of where modern slavery can present itself. Additional evaluation and contract monitoring criteria can be built into the procurement process. This enables a proper and thorough assessment of suppliers. This ensures they are compliant with the Act and that they are monitoring their supply chains as well.

For existing suppliers, contract monitoring and management is done within each service area. There will be a contractual obligation on the suppliers to notify us if their circumstances change from their initial declaration. We will continue with the process of rolling out a contract monitoring system which will result in a consistent approach to a core set of contract monitoring measures. This will make provision to prompt an annual declaration from the supplier to confirm they still meet the minimum due diligence criteria for their contract.

This statement is made pursuant to Section 54 of the Modern Slavery Act 2015

Claire Shand

Director of Corporate Services