Modern Slavery Act 2015 Section 54 - NELFT Slavery and Human Trafficking Statement 2024/25
NELFT aims to follow good practice and take all reasonable steps to prevent slavery and human trafficking. We are committed to ensuring that all our employees are aware of the Modern Slavery Act 2015 and their safeguarding duty to protect and prevent any further harm and abuse when it is identified or suspected that the individual may be or is at risk of modern slavery/human trafficking.
We are committed to ensuring that no modern slavery or human trafficking takes place in any part of our business or our supply chain. This statement sets out actions taken by NELFT to understand all potential modern slavery and human trafficking risks and to implement effective systems and controls. Section 54 of the Modern Slavery Act 2015 requires all organisations to set out the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.
As a Foundation Trust, we are committed to the core principles of Equality, Diversity and Inclusion which will be embedded in the Modern Slavery workstream by ensuring the people with diverse backgrounds, diverse experiences, and different cultures, have fair and equal access, experience and outcomes. We will work collaboratively and in collaboration with people with life experiences and develop relationships with organisations and communities set up to support those affected by modern slavery. It is therefore critical that we make sure our service delivery and procurement processes are assessed appropriately.
Organisational structure and supply chains
North East London NHS Foundation Trust (NELFT) was formed in 2008 under the Health and Social Care (Community Health and Standards) Act 2003. With an annual turnover of £599 million, we provide care and treatment for a population of circa 4.9 million. We employ over 7,000 staff who work across more than 200 bases in London, Essex, Kent, and Medway. We aim to ensure that local people can receive the care they need close to their homes. The Trust is rated ‘good’ by the CQC.
NELFT is a large trust both geographically and in terms of the range of services we provide. This comes with a number of challenges and opportunities in relation to the complexity of the health and care systems we work within. We provide an extensive range of integrated community and mental health services for people living in the London boroughs of Barking & Dagenham, Havering, Redbridge and Waltham Forest and community health services for people living in the south-west Essex areas of Basildon, Brentwood, and Thurrock. We provide an Emotional Wellbeing Mental Health Service for children and young people across the whole of Essex. We are the provider of all age eating disorder services and child and adolescent mental health services across Kent and Medway.
Our services include:
Community health services
- care and support for people living with long-term conditions such as diabetes.
- speech and language therapy, occupational therapy, and physiotherapy.
- health visiting, community, and school nursing.
- many services that in other areas may be provided in hospital, such as blood testing, foot care and children’s audiology.
- health promotion.
- walk-in centres in Barking and Orsett.
Inpatient rehabilitation and stroke care, provided from community wards
- Ainslie Rehabilitation Unit in Chingford.
- Brentwood Community Hospital.
- Meadow Court and King George Hospital at Goodmayes.
- Mayfield Unit in Thurrock Community Hospital.
Mental health services
- specialist inpatient and community-based treatment for people with acute mental illness
- help for children and young people with emotional, behavioural, or mental health difficulties
- care for people with dementia
- Psychological therapies (IAPT); and
- early intervention in psychosis – for people experiencing a first episode of psychosis.
Procurement process
All spend, aside from a few exceptions such as rates, is paid via Purchase order (PO) in line with the Trust’s No PO No Pay Policy. The Applicable Contract Terms Policy applies to any NHS organisation and states that where an NHS body issues a PO, the standard Terms and Conditions shall apply.
Section 19 of those standard terms and conditions state the following:
19 Modern slavery and environmental, social and labour laws
…
Modern slavery
19.2 The Supplier shall, and shall procure that each of its Sub-contractors shall, comply with:
19.2.1 the Modern Slavery Act 2015 (“Slavery Act”); and
19.2.2 the Authority’s anti-slavery policy as provided to the Supplier by the Authority from time to time (“Anti-Slavery Policy”).
19.3.1 implement due diligence procedures for its Sub-contractors and other participants in its supply chains in accordance with Good Industry Practice with the aim of avoiding slavery or trafficking in its supply chains;
19.3.2 respond promptly to all slavery and trafficking due diligence questionnaires issued to it by the Authority from time to time and shall ensure that its responses to all such questionnaires are complete and accurate;
19.3.3 upon request from the Authority, prepare and deliver to the Authority each year, an annual slavery and trafficking report setting out the steps it has taken to ensure that slavery and trafficking is not taking place in any of its supply chains or in any part of its business;
19.3.4 maintain a complete set of records to trace the supply chain of all goods and services purchased and/or supplied by the Supplier in connection with all contracts or framework agreements with the Authority;
19.3.5 implement a system of training for its employees to ensure compliance with the Slavery Act; and
19.3.6 ensure that any Sub-contracts contain anti-slavery provisions consistent with the Supplier’s obligations under this Clause 19 of this Schedule 2.
19.4 The Supplier undertakes on an ongoing basis that:
19.4.1 it conducts its business in a manner consistent with all applicable Laws including the Slavery Act and all analogous legislation in place in any part of the world in which its supply chain operates;
19.4.2 its responses to all slavery and trafficking due diligence questionnaires issued to it by the Authority from time to time are complete and accurate; and
19.4.3 neither the Supplier nor any of its Sub-contractors, nor any other persons associated with it (including any Staff):
(i) has been convicted of any offence involving slavery or trafficking; or
(ii) has been, or is currently, the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body relating to any offence committed regarding slavery or trafficking,
not already notified to the Authority in writing in accordance with Clause 19.5 of this Schedule 2.
19.5 The Supplier shall notify the Authority as soon as it becomes aware of:
19.5.1 any breach, or potential breach, of the Anti-Slavery Policy; or
19.5.2 any actual or suspected slavery or trafficking in its supply chain.
19.6 If the Supplier notifies the Authority pursuant to Clause 19.5 of this Schedule 2, it shall respond promptly to the Authority’s enquiries, co-operate with any investigation, and allow the Authority to audit any books, premises, facilities, records and/or any other relevant documentation in accordance with this Contract.
19.7 If the Supplier is in breach of Clause 19.3 or the undertaking at Clause 19.4 of this Schedule 2 in addition to its other rights and remedies provided under this Contract, the Authority may:
19.7.1 by written notice require the Supplier to remove from performance of any contract or framework agreement with the Authority (including this Contract) any Sub-contractor, Staff or other persons associated with it whose acts or omissions have caused the breach; or
19.7.2 terminate this Contract by issuing a Termination Notice to the Supplier.
The top 80% of suppliers nationally affirm their own compliance with the modern slavery and human trafficking act within their own organisation, sub-contracting arrangements and supply chain.
Organisational policies in relation to slavery and human trafficking
The Trust has internal policies and procedures in place that assess supplier risk in relation to the potential for modern slavery or human trafficking, and Trust activities and policies are required to have an Equality Impact Assessment (EQIA) completed.
NELFT’s Safeguarding Standard Operating Policy and procedure includes information on modern day slavery/human trafficking, and the NELFT Incident Reporting Policy states that staff should report incidents of all types. This includes concerns regarding modern slavery and human trafficking. By using the local risk management system, the appropriate teams, including safeguarding and Freedom to Speak Up are made aware.
All staff have access to the NELFT Safeguarding Advice Service for support and guidance when they are concerned about modern day slavery or trafficking.
The Trust has a Freedom to Speak Up Policy which details how staff can raise any concerns that they may have confidentially or anonymously. This can be through a Freedom to Speak Up email inbox, anonymous online form or through a conversation with the Freedom to Speak Up Guardian, who will provide support to the individual raising a concern. Staff are provided with this information at corporate induction. A Freedom to Speak Up Strategy is also in place.
Assessing and managing risk and due diligence processes in relation to slavery and human trafficking
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.
The Trust reviews its Modern Slavery and Human Trafficking Statement on an annual basis and presents it at a public meeting of the Board of Directors. This demonstrates a public commitment, ensures visibility and encourages reporting standards.
To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain:
- The Trust adheres to the National NHS Employment Checks / Standards (this includes employees UK address, right to work in the UK and suitable references)
- The Trust has systems to encourage the reporting of concerns and the protection of people who raise concerns.
- The Trust purchases a significant number of products through NHS Supply Chain, who’s ‘Supplier Code of Conduct’ includes a provision around forced labour. Other contracts are governed by standard NHS Terms & Conditions. High value contracts are effectively managed and relationships built with suppliers.
- The majority of our purchases utilise existing supply contracts or frameworks which have been negotiated under the NHS Standard Terms and Conditions of Contract, these all have the requirement for suppliers to have suitable anti-slavery and human trafficking policies and processes in place. Where a suitable framework exists we use them in preference to tendering. These are run by NHS procurement hubs and contain the standard Terms & Conditions.
- The Trust request all suppliers to comply with the provisions of the UK Modern Slavery Act (2015), through agreement of our ‘Supplier Code of Conduct’, purchase orders and tender specifications. All of which will set out our commitment to confirming there is no modern slavery or human trafficking related to NELFT service delivery and business.
- The Trust upholds professional codes of conduct and practice relating to procurement and supply, including through our Procurement Team’s membership of the Chartered Institute of Procurement and Supply (CIPS).
Effective action taken to address modern slavery - performance indicators
The Trust is committed to social and environmental responsibility and has zero tolerance for slavery and human trafficking. Any concerns identified regarding slavery and human trafficking are escalated as part of the organisational safeguarding process. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes NELFT’s slavery and human trafficking statement for the current financial year.
All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking, with the Procurement department taking responsibility for overall compliance.
A Freedom to Speak Up Report is submitted to the People and Culture Committee of the Board on a quarterly basis which includes an overview of the number of concerns raised by staff and the category that they fall into.
Training on modern slavery and trafficking
Safeguarding training is mandatory for all staff and includes information on trafficking and modern-day slavery in order to promote the knowledge and understanding of escalating concerns via the Home Office national referral mechanism/duty to notify process.
Signed:
Paul Calaminus, Chief Executive Officer, 24 September 2024
Approved by the NELFT Board of Directors: 24 September 2024
Next review: September 2025
Financial year: 1 April – 31 March