Modern Slavery Statement
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 now obliged to comply with the Act.
The condition of being forced by threats or violence to work for little or no pay and of having no power to control what work you do or where you do it. Modern Slavery includes domestic slavery, forced sex work and forced participation in crime as cannabis production.
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 £36 million 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 from 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.
East of England Ambulance Service NHS Trust (EEAST) provides Ambulance Services across East of England. The Trust serves around six million people in Bedfordshire, Hertfordshire, Essex, Norfolk, Suffolk and Cambridgeshire. Like the other ambulance NHS trusts in England, EEAST provides a range of services, but are best known for the 999-emergency service. The Trust’s annual turnover from continuing activities for 2018/19 was over £262 million. The Trust employs more than 4,000 staff and have about 1,500 volunteers working with us.
From a safeguarding perspective, included in our training packages and updates are Modern Slavery & Human Trafficking. We alert crews/volunteers on the signs to spot. We have referral pathways through our single point of contact (SPOC) for any patients that we may come into contact with who may be victims. We would also report such cases to the Police.
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.
What we have done;
- EEAST adopted the Standard Selection Questionnaire (SSQ) in its procurements in 2015. The SSQ uses the Modern Slavery Act and other levers in relation to EU social and Labour law and other collective agreements and standards as mandatory and discretionary exclusion grounds. Suppliers are asked to confirm whether they have breached their obligations in the field of EU and UK Social and Labour law and other collective agreements and standards.
- EEAST has asked all suppliers submitting tenders since Feb 2018 to sign up to the EEAST ‘’Supplier Sustainability Agreement’’ which includes a requirement as follows; ‘’Suppliers will adhere to the principles of the Modern Slavery Act 2015, the united nations Global Compact, UN declaration of Human Rights as well as the 1998 International Labour Organisations ‘’declaration on Fundamental Principles and Rights at Work’’. This is a pass or fail question within the SSQ, so any supplier that does not sign the agreement is removed from the tender process.
- The Sustainability Agreement seeks to provide assurance on a number of connected issues; Modern Slavery, Health and Safety, Environment, Ethics and System management which together help provide assurance that not only are workers not being subject to Slavery, but that they also work in acceptable conditions that protects and supports their health and the health of the environment.
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 but will include all 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 East of England Ambulance Service NHS Trust associated with this Act are managed in accordance with the Trust’s Risk Management Policy.
What we plan to do:
- EEAST will issue a TISC Statement and ensure this is on the Trust intranet and more visible to all suppliers, staff and the public by December 2020.
- Start requesting MSAT Assessments from at risk Suppliers from March 2021 in line with the TISC Statement due to be agreed later this year.
- Include a disclaimer below, which will go into all our HR Policies:
East of England Ambulance Service recognises our obligation of supporting the requirements of the Modern Slavery Act 2015 and any future legislations. EEAST prime objective is to eradicate modern slavery and human trafficking and recognises the significant part EEAST must play in both combatting it and supporting victims. EEAST is also committed to ensuring that its supply chains and business activities are free from any ethical and labour standards abuse.
The Board of Directors will consider 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 slavery and human trafficking statement for the financial year ended 31 March 2021.