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. PPN 02/23 sets out four key areas of activity for buyers to prevent modern slavery in supply chains: identifying and managing risks in new procurements; assessing existing contracts; taking action when victims of modern slavery are identified; and training.
Modern slavery is the recruitment, movement, harbouring 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. In 2023 17,004 potential victims of modern slavery were referred to the Home Office, similar to the preceding year (16,921) but nonetheless the highest annual number since the National Referral Mechanism (NRM) began in 2009.
Collecting legal evidence for modern slavery offences can be difficult, and the cases are among the most challenging and complex to prosecute. For example:
- There were 205 suspects of modern slavery flagged cases referred from the police to the Crown Prosecution Service (CPS) for a charging decision in England and Wales in the year ending 2019.
- Over two-thirds (68%) of modern slavery related CPS prosecutions in England and Wales resulted in a conviction in the year ending March 2019.
The aim of the statement is to encourage transparency within organisations, 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 2024/25 was over £400 million. The Trust employs more than 6,000 staff and has approximately 1,000 volunteers collaborating 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 February 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.
The Procurement Act 2023 has amended procurement regulations to include Modern Slavery offences such as child labour and human trafficking as grounds for mandatory exclusion from public procurements.
From a safeguarding perspective, included in our training packages and updates are Modern Slavery and 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 01 April 2022, all NHS organisations have been required to adopt PPN06/20 and specific guidance on how to apply the Social Value Model to healthcare settings has been provided and implemented.
We engaged a partner in February 2024 to support the delivery and ongoing measurement of social value delivered through our contract activity using the National Themes, Measures and Outcomes (TOMS) system that align to the Social Value Model and are in the process of developing a Social Value Plan.
The National TOM’s NT43 will allow suppliers to support social value outcomes through the reporting of:
- Initiatives taken throughout the local and global supply chain to strengthen the identification, monitoring and reduction of risks of modern slavery and unethical work practices occurring in relation to the contract (i.e. supply chain mapping, staff training, contract management.
4. Key performance indicators to measure effectiveness of steps being taken
What progress we have already made:
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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.
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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.
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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.
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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.
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For all Terms and Conditions, included specific clauses that reflect our obligations under the Modern Slavery Act 2015.
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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.
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Communicated to all high-risk suppliers providing an overview of the legislation, stating our intent and future expectations.
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Ensured that the risk of Modern Slavery being within our Supply Chains and compliance with the Act is included within the Trust risk register.
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For those contracts deemed to be of high risk, including the specific Right to Audit against the obligations of the Modern Slavery Act 2015.
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Completed further procurement training on PPN 02/23 encompassing the new requirements within Tacking Modern Slavery in Government Supply Chains through the Government Commercial College (GCC)
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Contracted a partner to support the delivery of social value within our contracts that includes actions our suppliers are doing to eradicate Modern Slavery within their own supply chains.
We are committed to the following actions to further improve our effectiveness for the coming year:
- Complete the Assessment of 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 procurement staff have completed the 10 Modules of training related to the implementation of the Procurement Act 2023.
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 Radicalisation are core mandatory courses within EEAST.
The Board of Directors will consider this statement and will continue to support the requirements of the legislation.
Marika Stephenson, Chief People Officer - 9 July 2025
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 2025.