Modern slavery

Last updated: 7 May 2021

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.

The Trust (GHNHSFT) fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS has to play. We are strongly committed to ensuring our supply chains and operational activities are free from ethical and labour standards abuses.

Slavery and human trafficking statement for financial year 2019/20

During the last financial year the Trust took, and continues to take, the following steps to ensure that slavery and human trafficking is not taking place:

• we confirm the identities of all new employees and their right to work in the United Kingdom.
• all staff are appointed subject to references, health checks, immigration checks and identity checks. This ensures that we can be confident, before staff commence duties, that they have a legal right to work within our Trust.
• we have a set of values and behaviours that staff are expected to comply with, and all candidates are expected to demonstrate these attributes as part of the selection process.
• by adopting the national pay, terms and conditions of service, we have the assurance that all staff will be treated fairly and will comply with the latest legislation. This includes the assurance that staff received, at least, the national minimum wage from 1 April 2015.
• we have various employment policies and procedures in place designed to provide guidance and advice to staff and managers but also to comply with employment legislation.
• our equality and diversity, grievance, respect and dignity at work for staff policies additionally give a platform for our employees to raise concerns about poor working practices.
• our policies and practices promote and support diversity and inclusion both as an employer and service provider; we recognise and acknowledge that diversity and inclusion are key corporate social responsibilities and a diversity network for all staff has been in place since 2017.
• our mandatory safeguarding training includes modern slavery as a topic. All clinical staff receive training as part of our Trust bespoke level 2 safeguarding adult e-learning training and also level 3 safeguarding adult training.
• our Trust “Safeguarding Adults at Risk Policy”, and the countywide multi-agency safeguarding policy, to which our Trust is a partner signatory, also includes modern slavery and we have produced communications materials to raise awareness amongst staff and anyone working on or otherwise attending our sites.
• our Freedom to Speak: Raising Concerns (whistleblowing) Policy gives a platform for employees to raise concerns for further investigation, and our Freedom To Speak Up Guardian and safeguarding teams actively ensure they are accessible to staff.
• the procurement team work on the principle of zero tolerance of modern slavery in our supply chain. Our standard terms and conditions require suppliers to comply with relevant legislation and tender evaluations include social economic factors. A large proportion of the goods and services procured are sourced through Government supply frameworks and contracts also require suppliers to comply with relevant legislation.
• we continue to work with our suppliers directly and via partners, such as NHS Supply Chain, to support initiatives related to modern slavery.

Review of effectiveness

The Trust will continue to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly within supply chains. We aim to:

• raise awareness and support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working at our Trust can have in keeping present and potential future victims of modern slavery and human trafficking safe
• ensure that all staff continue to have access to training on modern slavery and human trafficking which will provide the latest information and the skills to deal with it
• embed social value best practice into commercial processes which will achieve improved social value awareness and compliance across all our commercial activities
• impact assess all new or reviewed policies for diversity and inclusion compliance

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation.

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 2020.