The Modern Slavery Act

The Act was introduced in 2015 to provide victims of modern slavery with greater protections and police with greater powers.

Modern Slavery encompasses:

  • slavery
  • servitude
  • forces and compulsory labour
  • and human trafficking

There is no typical victim of slavery – victims can be men, women, or children of all ages and nationalities.

Our commitment

We are committed to opposing Modern Slavery and recognise the role we must play as a public sector organisation in its identification and disruption. As such, we have a zero-tolerance approach to any form of Modern Slavery and are committed to acting ethically, with integrity and transparency in all that we do, whether alongside our internal workforce or externally with partners and suppliers.

Modern Slavery transparency statement

Our Modern Slavery Transparency Statement sets out our commitment, policies, and procedures in relation to identifying and mitigating the risk of Modern Slavery.

This is in accordance with the Transparency in Supply Chains Provision (TISC) section 54 of the Modern Slavery Act (MSA) which requires commercial entities with an annual turnover of £36m or more to publish annually a Modern Slavery transparency statement.

Tackling Modern Slavery in supply chains

In February 2023 the Government published Procurement Policy Note (PPN) 02/23: Tackling Modern Slavery in Government Supply Chains. This outlines how Government departments and public sector organisations must take action to ensure modern slavery risks are identified and managed within supply chains.

Although councils don’t fall into scope of the PPN, it is still relevant. We are taking action to apply this approach to mitigate the risk of modern slavery in our supply chains. The PPN sets out four key areas of activity:

  • identifying and managing risks in procurement
  • assessing existing contracts
  • taking action when victims of modern slavery are identified
  • training

Working with our supply chains

In applying the PPN 02/23, as a supplier you may find that our procurement processes and contract management, and those of other public sector organisations, may ask you for more information about managing modern slavery in your supply chains.

There are 4 key areas of activity under PPN 02/23 that you may wish to consider adopting into your own practices.

Identifying and managing risks in new procurements/supply chains

  • review and amend operating procedures, processes and any related document in line with the Government’s publication
  • assess modern slavery risks in new procurements/supply chains
  • Design new procurements / supply chains in line with the associated risk level including consideration to social value
  • Review and amend contract management processes and any related documentation 

Assess existing contracts

  • carry out a risk assessment on existing contracts
  • conduct supply chain mapping exercise(s)
  • invite suppliers to complete the Modern Slavery Assessment Tool (if appropriate)
  • apply strengthened contract management to manage risks, working with suppliers to progressively improve

Taking action when victims of modern slavery are identified

  • work openly and proactively with suppliers to resolve issues and change working practices
  • consider terminating a contract only as a last resort

Training

  • raise awareness of modern slavery and human rights abuses amongst your staff, and offer and deliver appropriate training