Modern Slavery Statement 2018/19
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.
Airedale NHS Foundation Trust provides services from its main hospital site, Airedale Hospital, and a range of community services from community hospitals, as well as health centres and general practices (GPs). The Trust’s annual turnover from continuing activities for 2017/18 over £165million. The Trust employs over 2,700 permanent and fixed term contract staff.
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.
To ensure all those in our supply chain and our contractors comply with our values, we use the Ethical Trading Initiative Base Code as our organisational standard on labour and we ensure that our suppliers adhere to this via our sourcing process.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our procurement staff. The procurement department’s senior team are all Chartered Institute of Purchasing and Supply (CIPS) qualified and abide by the CIPs code of professional conduct. Over the next year, specific training will be provided for the Trust’s internal supply chain management related to slavery and human trafficking.
In addition, the Trust is meeting its supply chain commitments on slavery and human trafficking by undertaking the following steps during the year:
For all Terms and Conditions, including specific clauses that reflect our obligations under the Modern Slavery Act 2015
Including relevant pass/fail criteria for all Procurement led tender processes and new vendor requests
Up-skilling the Procurement and Supplies Team on the implications of the Act in order that they can support the wider organisation on its implementation
Communicating to all high risk suppliers providing an overview of the legislation, stating our intent and future expectations
For those contracts deemed to be of high risk, including the specific Right to Audit against the obligations of the Modern Slavery Act 2015
The Trust employs solely within the UK and how we treat our employees is managed consistently across the Trust by the Human Resources Directorate. The Trust pays above the national living wage i.e. the minimum wage set by the Government.
Risks to Airedale NHS Foundation Trust associated with this Act are managed in accordance with the Trust’s Risk Management Policy.