Modern Slavery Act Statement
Slavery is a violation of a person’s human rights. It can take the form of human trafficking, forced labour, bonded labour, forced or servile marriage, descent-based slavery and domestic slavery. A person is considered to be in modern slavery if they are;
- Forced to work through mental or physical threat
- Owned or controlled by an “employer”, usually through mental or physical abuse
- Dehumanised, treated as a commodity or sold or bought as “property”
- Physically constrained or has restrictions placed on their freedom of movement
The use of slavery in the production of goods and services
Typically, the products bought nowadays have passed through a long chain of producers, manufacturers, distributors and retailers who have all participated in its production, delivery and sale. It can therefore be very difficult to certify that a product has or has not been produced using slavery. However, the way in which companies operate and manage their supply chain can affect the likelihood of slavery being a part of the final product. The Modern Slavery Act gives responsibility to companies for ensuring that no slavery has occurred, and this applies not only to the products they sell or the services they provide themselves but also to their suppliers, and the suppliers of their suppliers, all the way down the supply chain.
What are we required to do?
Primarily our requirements relate to section 54 of the Act “Transparency in the supply chain” Under the Act, any company with a turnover of more than £36m must produce a statement for each financial year listing the steps it is taking to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business. This statement must be published on company websites and visible to staff, suppliers, customers and investors. The trickle-down effect of the Act will be felt this year as businesses begin to ask more searching questions of their suppliers to seek assurance that they are also taking steps to ensure that their supply chains are free from slavery.
Our statement of principles
NHS Cheshire and Merseyside believes there is no room in our society for modern slavery and human trafficking, we have a zero tolerance for modern slavery and breaches in human rights and will ensure this is built into the processes and business practices that we, are partners and our suppliers use.
What we do:
- Require evidence that providers are publishing their modern slavery statement, when we procure a new contract.
- Provide Safeguarding training to our employees and GPs which includes modern slavery.
- Modern slavery is part of NHS Cheshire and Merseyside's safeguarding arrangements and all commissioned services provide assurance about this (specifically safe recruitment).
By having robust HR policies we:
- Provide Safeguarding training to employees and local suppliers, we will extend this to include modern slavery risks and compliance
- Ensure all UK Workers receive minimum wage and robust immigration checks
- Ensure suppliers adhere to the working time directive 1998
- We ask all our suppliers to agree to our code of conduct
- In partnership with our supply chain partners to work towards elimination of modern slavery in the supply chain, we want all our suppliers to think about the steps they can take to provide us with the assurance that;
- Modern slavery is not present in their company
- Safe and fair working conditions
- The risks within their own supply chain are understood
- Instances are appropriated reported (although this is currently not mandated for health)
- Zero tolerance, responsible management and compliance with all legal requirements is reflected in policies, procedures, practices and in contracts with suppliers
Each year we will review our approach and Publish an annual statement outlining the steps we are taking to tackle modern slavery.