Modern slavery
INTRODUCTION
This Statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Airedale NHS Foundation Trust (the Trust) has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Trust has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to put effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.
AIM OF THIS STATEMENT
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 the lead responsibility for compliance in the supply chain.
ABOUT THE ORGANISATION
The Trust is an integrated NHS hospital and community services Trust employing over 3,500 staff, providing high quality, personalised, acute, elective, specialist, and community care for a population of over 200,000 people from a widespread area covering West and North Yorkshire and East Lancashire Services are provided from the main hospital site, Airedale Hospital, and from community hospitals, as well as health centres and general practices. Its health services are commissioned by West Yorkshire Integrated Care Board along with Lancashire and South Cumbria Integrated Care Board, as well as regional specialist commissioners and NHS England. The Trust also includes three joint ventures – Immedicare LLP, Integrated Laboratory Solutions LLP and Integrated Pathology Solutions LLP, and a wholly-owned subsidiary, AGH Solutions Ltd.
OUR POLICIES ON SLAVERY AND HUMAN TRAFFICKING
The Trust is aware of its responsibilities towards patients, service users, employees, and the local community and expects all suppliers to the Trust to adhere to the same ethical principles. The Trust is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships.
Currently all awarded suppliers sign up to our terms and conditions of contract which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with the Trust’s anti-slavery policy.
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. This strategic approach incorporates analysis of the Trust’s supply chains and its partners to assess risk exposure and management on modern slavery.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include the following:
Recruitment and Selection policy and procedure: We operate a robust recruitment policy including conducting eligibility to work in UK checks for all directly employed staff. Other checks include checks of identity, evidence of qualifications, health clearance, employment history, and Disclosure Barring Service criminal records check for roles that meet the requirements. External agencies are sourced through the NHS Improvement nationally approved frameworks and are audited to provide assurance that pre-employment clearance has been obtained for agency staff to safeguard against human trafficking or individuals being forced to work against their will.
Equal Opportunities: We have a range of controls to protect staff from poor treatment and/or exploitation which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities.
Safeguarding Policies: We adhere to the principles inherent within both our Safeguarding Children and Adults policies and procedures. These provide clear guidance so that our employees are aware as to how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain.
Freedom to Speak Up Policy: We operate a Speak Up policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.
Standards of Business Conduct (within Standing Orders): This policy explains the way we behave as an organisation and how we expect our employees and suppliers to act.
Sustainable Procurement and Innovation Policy: this shared West Yorkshire Policy further supports the work the West Yorkshire Provider Procurement Collaborative complete regarding ethical standards in Procurement.
WORKING WITH SUPPLIERS
The Procurement Team ensures that due diligence is undertaken for all new and ongoing suppliers of goods and services to the organisation and their associated Supply Chains by sourcing through the following compliant routes:
- Competitive Processes through – Procurement Act 2023 / or Public Contract Regulations 2015 procurements tendered in compliance with UK guidance which require suppliers to confirm they comply with the Modern Slavery Act. To support their response bidders are also required to state:
a) the organisation’s structure, its business, and its supply chains
b) its policies in relation to slavery and human trafficking
c) its due diligence processes in relation to slavery and human trafficking in its business and supply chains
d) the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk
e) its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate
f) the training and capacity building about slavery and human trafficking available to its staff.
2. Procurement through compliant national government frameworks. The Trust purchases large amounts of products from third party distributors such as NHS Supply Chain and utilises framework agreements from national framework providers such as Crown Commercial Services (CCS) which include specific questions around the Modern Slavery in their procurement documentation and any breaches of labour laws which result in disqualification of unsuitable organisations.
3. All contracts and associated purchase orders are raised on the NHS Standard Terms and Conditions which suppliers are mandated to comply with. These conditions state:
10.1.28 it shall: (i) comply with all relevant Law and Guidance and shall use Good Industry Practice to ensure that there is no slavery or human trafficking in its supply chains; and (ii) notify the Authority immediately if it becomes aware of any actual or suspected incidents of slavery or human trafficking in its supply chains
10.1.29 it shall at all times conduct its business in a manner that is consistent with any anti-slavery Policy of the Authority and shall provide to the Authority any reports or other information that the Authority may request as evidence of the Supplier’s compliance with this Clause 10.1.29 and/or as may be requested or otherwise required by the Authority in accordance with its anti-slavery Policy.
4. Adherence with all current Procurement Policy Notes (PPN’s) such as PPN009/24: Tackling modern slavery in government supply chains, which came into effect in early 2024 and any superseding PPNs that may follow.
TRAINING
Advice and training about Modern Slavery and human trafficking is available to staff through our mandatory Safeguarding Children and Adults training programmes, our Safeguarding policies, and procedures, and our Safeguarding Leads. It is also discussed at our compulsory staff induction training.
Awareness is also raised through information sharing on the Trust intranet and our public website.
Advice and training about Modern Slavery and human trafficking is available to staff through our Safeguarding Children and Adults training programme. The Trust is committed to and follow the Airedale NHS Foundation Trust Safeguarding Adults Policy and Procedures.
OUR PERFORMANCE INDICATORS
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
BOARD OF DIRECTORS’ APPROVAL
The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation. This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our organisation’s modern slavery and human trafficking statement for the current financial year.
Signed on behalf of the Board of Directors:
Sarah Jones ‘Foluke Ajayi
Chair Chief Executive Officer
6 May 2026
