Modern Slavery Act Statement 2015
Leicester City CCG, West Leicestershire CCG and East Leicestershire and Rutland CCG (LLR CCGs) are committed to implementing the requirements of the Modern Slavery Act 2015 and this statement sets out the steps that the LLR CCGs are taking to ensure that the organisations are free from Modern Slavery.
The Act sets out that organisations with a turnover of £36 million or more must report annually on the steps that they have taken during the financial year to ensure that slavery and human trafficking are not taking place in their own business or in their supply chains.
Section 54 of the Act requires those organisations to prepare and publish a statement setting out the steps that they have taken during that financial year to ensure that slavery and human trafficking are not taking place:
What is modern slavery?
The offence of modern slavery includes subjecting someone to slavery or servitude, forced or compulsory labour, including child labour, and human trafficking, often breaching human rights law, employment law and health and safety regulations, harsh and inhumane treatment, and exploitatively low pay and long hours.
Someone is in slavery if they are:
• Forced to work either through coercion, mental or physical threat
• owned or controlled by an ’employer’ through mental or physical abuse, or the threat of abuse
• dehumanised by being treated as a commodity or bought and sold as ‘property’
• physically constrained or have unlawful restrictions placed on their freedom of Policies and Procedures
As both a local leader in commissioning health care services for the population of Leicester, Leicestershire and Rutland and as an employer, the LLR CCGs provided the following statement in respect of its commitment to, and efforts in, preventing slavery and human trafficking practices in the supply chain and employment practices.
Preventing Modern Slavery through our employment practices
LLR CCGs have in place robust risk assessment processes which provide assurance about their approach in tackling any matters related to Modern Slavery. LLR CCG policies such as the Bullying and Harassment policy, Grievance policy and Whistleblowing policy provide an additional platform for their employees to raise concerns about poor working practices or any matters related to Modern Slavery.
The LLR CCGs will continue to ensure their recruitment processes are robust by ensuring that there are practices in place that adhere to safe recruitment principles. This includes strict requirements in respect of identity checks, work permits and criminal records.
Their commitment to contribute to the eradication of modern slavery is reflected in their safeguarding policies and procedures including the Adult Safeguarding and Safeguarding Children policies, which have been developed in accordance with national and local safeguarding legislation and guidance. It includes guidance on recognising suspected human trafficking victim. Their safeguarding training includes information on modern slavery awareness.
Preventing Modern Slavery in our Procurement and our Supply Chain
Contracting with providers is a core function of the LLR CCGs. Their procurement approach follows the Crown Commercial Service standard. When procuring goods and services, they apply NHS Terms and Conditions (for nonclinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.
The Modern Slavery Act and its explanatory notes are available at http://www.legislation.gov.uk/
Review of effectiveness
To identify and mitigate the risks of modern slavery and human trafficking in their own organisations and their supply chain they will continue to carry out the following;
• Complete pre-employment checks on staff they employ, confirming their identities and right to work in the United Kingdom. They will also ensure agencies are on approved frameworks.
• Follow NHS Agenda for Change Terms and Conditions to ensure that staff receive fair pay rates and contractual terms.
• Consult with Trade Unions on any proposed changes to employment terms and conditions.
• Support their staff to understand and respond to modern slavery and human trafficking, and the impact of modern slavery on individuals. Each and every individual working in the NHS can have in keeping present and potential future victims of modern slavery and human trafficking safe.
• They will ensure that all NHS staff have access to training on how to identify those who are victims of modern slavery and human trafficking. This training will include the latest information and will help staff develop the skills to support individuals who encounter health care services.
• Work with their partner organisations and other NHS funded organisations to ensure modern slavery and human trafficking are taken seriously and features prominently in safeguarding work plans.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes their slavery and human trafficking statement for the financial year ending 31st March 2020.