We are continuing to raise the profile of modern slavery and human trafficking across all services. We contribute to the NHS Safeguarding Modern Slavery and Human Trafficking (MSHT) network and work in collaboration with our partners including the police.
The Modern Slavery Act 2015 is designed to consolidate various offences relating to human trafficking and slavery. The provisions in the Act create a requirement for an annual statement to be prepared that demonstrates transparency in supply chains. In line with all businesses with a turnover greater than £36million per annum, the NHS is obliged to comply with the Act.
The legislation addresses slavery, servitude, forced or compulsory labour and human trafficking and links to the transparency of supply chains.
Section 54 of the Act specifically addresses the point about transparency in the supply chains. It states that a commercial organisation (defined as a supplier of goods or services with a total turnover of not less than £36million per year) shall prepare a written slavery and human trafficking statement for the financial year. The statement should include the steps an organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any part of the supply chain or its business. The statement must be approved by the Board of Directors.
The aim of the statement is to encourage transparency within organisations, although it is possible to comply with the provision by simply stating that no steps have been taken during the financial year to ensure that the business and supply chain is modern slavery free. It is worth noting that although this may be an acceptable approach for this year’s statement, there is an expectation that further work will be undertaken to provide these assurance s in years to come.
There are potential consequences for those organisations that do not appear to make progress in this area; especially for those that are funded wholly, or in part, by public money.
The Trust will be required to review and/or prepare a similar statement on an annual basis. To support the production of the statement, assurance mechanisms will be put in place, including the use of Internal Audit. Internal Audit’s work would include a review of the systems in use by the Trust that seek appropriate assurance form other organisations. These assurances will be included in Internal Audit reports that will be discussed at the Audit Committee.
Modern Slavery and Human Trafficking Act 2015 Annual Statement
Section 54 of the Modern Slavery Act 2015 requires all organisations to set out the steps it has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.
The aim of this statement is to demonstrate that the Trust follows good practice and all reasonable steps are taken to prevent slavery and human trafficking.
All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility lead for overall compliance.
We have zero tolerance of slavery and human trafficking and are committed to maintaining and improving systems, processes and policies to avoid complicity in human rights violation and to prevent slavery and human trafficking in our supply chain.
The Trust policies, procedures, governance and legal arrangements are robust, ensuring that proper checks and due diligence are applied in employment procedures to ensure compliance with this legislation. We also conform to the NHS employment check standards within our workforce recruitment and selection practices, including through our managed service provider contract arrangements. This strategic approach incorporates analysis of the Trust’s supply chains and its partners to assess risk exposure and management on modern slavery.