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 for all businesses with a turnover of over £36m that demonstrates actions taken to ensure transparency in supply chains. In support of the Act, Public Procurement Notice (PPN) 02/23 confirms a requirement to use the guidance ‘Tackling Modern Slavery in Government Supply Chains’ to identify and manage risks in both new procurement activity and existing contracts.
Modern slavery is the recruitment, movement, harboring or receiving of children, women, or men through the use of force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting. Traffickers and slavers use whatever means they have at their disposal to coerce, deceive, and force individuals into a life of abuse, servitude, and inhumane treatment.
Modern Slavery is a world and UK problem. Since the year ending March 2016, there has been an increase in the number of modern slavery offences recorded by the UK police, from 909 to 5,144 offences in the year ending March 2019. A high profile UK case in 2019 saw five men and three women jailed for between 3 and 11 years for enslaving up to 400 people.
The aim of the statement is to encourage transparency within organizations, raise awareness of the issues and to help fight and eradicate Modern Slavery in the UK by ensuring Modern Slavery is not hidden within the goods and services we purchase or the services we provide.
1. Organisation structure and supply chains
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 2022/23 was over £400 million. The Trust employs more than 5,000 staff and has about 1,200 volunteers working with us.
As an organisation and in compliance with the Act we are committed to;
- Updating the Modern Slavery Statement each year.
- Publishing the Statement on our website.
- Demonstrating that we have met the requirement through seeking Board of Directors approval of the statement.
- Having a Director sign the statement to demonstrate our firm intent of meeting the requirements of the Act.
2. Policies in relation to slavery and human trafficking
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.
We are committed to acting ethically and with integrity and transparency in all our business dealings and to putting effective systems and controls in place to protect our staff and the public against any form of modern slavery. Through the implementation of robust recruitment policies and procedures EEAST ensure that comprehensive checks and balances are in place to negate the likelihood of individuals being employed by EEAST who have been trafficked illegally or who are the victims of Modern Slavery.
These checks include but are not limited to:
- Undertaking appropriate references
- Occupational health screening
- DBS and immigration status checks
- Identity checks
By adopting the NHS national pay, terms and conditions of service, the service has the assurance that all staff will be treated fairly in respect of pay and will comply with the latest legislation. The service has appropriate policies and procedures in place designed to provide guidance and advice to staff, managers, and volunteers. These policies are available on the staff intranet and via the EEAST public web site. An Equality Impact Assessment is completed on each policy to assess the impact from an equality and diversity perspective and to ensure EEAST is conducting business in an ethical and transparent manner and each Policy is reviewed and approved by our Compliance and Risk Group (CRG).
These policies include but are not limited to.
- Agency Workers Policy
- Annual Leave Policy
- Breast Feeding Policy
- Collective Grievance Policy
- Dignity at Work Policy
- Disability Policy
- Employment Break Policy
- Flexible Working Policy
- Fit and Proper Person Policy
- Freedom to Speak Up Raising Concerns Policy
- Home Working Policy
- Maternity Leave and Paternity Leave Policies
- Recruitment and Selection Policy
- Special Leave Policy
EEAST adopted the Standard Selection Questionnaire (SSQ) in its procurements in 2015. The SSQ uses the Modern Slavery Act as mandatory and discretionary exclusion grounds.
Suppliers are asked to confirm whether they have breached their obligations in the field of 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 several 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.
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 encounter who may be victims. We would also report such cases to the police.
3. Risk assessment and management
We have adopted central government’s Social Value Model (Procurement Policy Note 06/20), which requires a minimum 10% weighting in all procurements dedicated to Net Zero and Social Value, including the elimination of Modern Slavery. As of 1st April 2022, all NHS organisations are required to adopt PPN06/20 and specific guidance on how to apply the Social Value Model to healthcare settings is provided.
We are in the process of employing a Contract Manager and Social Value lead to provide greater assurance regarding delivery of the Social Value and Modern Slavery commitments made by suppliers during the tender process.
4. Key performance indicators to measure effectiveness of steps being taken
What progress we have already made.
- First issued a TISC Statement and ensured this was visible on the Trust intranet and thus more visible to all suppliers, staff, and the public from December 2020.
- Started requesting MSAT Assessments from high risk clothing suppliers in June 2021 in line with the TISC Statement and expanded that to Private Ambulance Providers in 2022.
- Included a disclaimer below in 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.
- Provided training to the Procurement and Supplies Team on the implications of the Act in order that they can support the assurance that Modern Slavery is not within our supply chain.
- For all Terms and Conditions, included specific clauses that reflect our obligations under the Modern Slavery Act 2015.
- Included relevant pass/fail criteria for all Procurement led tender processes and used Section 7 of the SSQ to ensure suppliers adhere to the Modern Slavery Act.
- Communicated to all high-risk suppliers providing an overview of the legislation, stating our intent and future expectations.
- Ensured that the risk of Modern Slavery being within our Supply Chains and compliance with the Act is included within the Trust risk register.
- For those contracts deemed to be of high risk, including the specific Right to Audit against the obligations of the Modern Slavery Act 2015.
We are committed to the following actions to further improve our effectiveness for the coming year:
- Complete further procurement training on PPN 02/23 encompassing the new requirements within Tacking Modern Slavery in Government Supply Chains.
- Employ a Contracts Manager and Social Value lead able to track, chase and monitor supply chain compliance through completion of the Modern Slavery Assessment Tool and compliance with the Supplier Sustainability Agreement more effectively.
- Rolling out the MSAT assessments and thus supply chain mapping to all new and existing suppliers to ensure full compliance with PPN 02/23.
- Assessing our statement against the Ethical Trade Initiative (ETI) Modern Slavery Statement Framework.
5. Training on modern slavery and trafficking
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have already provided 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.
All current members of the procurement team have completed training via the Government Commercial College in relation to Modern Slavery and human trafficking awareness. EEAST staff and volunteers may attend to patients who are modern day slaves. EEAST recognises that the Modern Slavery Act 2015 highlights the importance of identifying and responding to victims of Modern Slavery. EEAST regularly conducts training and awareness sessions for all frontline responders to ensure they recognise and understand the signs of modern slavery and know what to do if they suspect that it is taking place. Equality and Human Rights Commission Values and Behaviours eLearning, Safeguarding and Preventing Radicalization are core mandatory courses within EEAST.
The Board of Directors will consider this statement and will continue to support the requirements of the legislation.
Signed by Marika Stephenson, Director of People Services 30/06/2023
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 2023.