Modern slavery statement

Modern Slavery and Human Trafficking Act 2015, annual statement 2023 to 2024

This is an act to make provision about slavery, servitude and forced or compulsory labour and about human trafficking, including provision for the protection of victims, to make provision for an Independent anti-slavery commissioner and for connected purposes.

The Modern Slavery Act and its explanatory notes are available on the Parliament website (opens in a new window).

Definition of Offences

Slavery, servitude and forced or compulsory labour

A person commits an offence if either:

• the person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude
• the person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour

Human trafficking

A person commits an offence if:

• the person arranges or facilitates the travel of another person (victim) with a view to being exploited
• it is irrelevant whether the victim consents to travel and whether or not the victim is an adult or a child

Exploitation

A person is exploited if one or more of the following issues are identified in relation to the victim:

• slavery, servitude, forced or compulsory labour
• sexual exploitation
• removal of organs
• securing services by force, threats and deception
• securing services from children, young people and vulnerable persons

Rotherham, Doncaster and South Humber offer the following statement regarding its efforts to prevent slavery and human trafficking in its supply chain.

Section 54 of the Modern Slavery Act 2015 (opens in a new window) 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.

The trust has internal policies and procedures in place that assess supplier risk in relation to the potential for modern slavery or human trafficking. 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.

Procurement

The trust procurement strategy  includes a commitment to the trust’s obligations under the act which details actions which are taken during the procurement process. In addition template commercial agreements have also been updated to include an obligation that suppliers will comply with the act and ensure that their suppliers and sub-contractors will too.

As part of daily process the procurement department identify and prioritise high risk areas in supply chain utilising guidance and resources as available.

There are no specific obligations placed on public sector procurers under the act, albeit there will be an expectation that procurers seek some confirmation that suppliers are complying with their obligations, as applicable. The department of health has updated the NHS Standard terms and Conditions for the Provision of Goods and Service (2018) to incorporate requirements under the Modern Slavery Act.

The trust has written to all their suppliers requesting they affirm their compliance with the legislation.

Internal audit undertake an annual audit on non-pay expenditure as part of their audit plan. The audit includes a statutory compliance element. In future this will include the Modern Slavery and Human Trafficking Act requirements.

The due diligence processes in relation to slavery and human trafficking in its business and supply chains

The Procurement department 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 adheres to the National NHS employment checks or standards. This includes employees UK address, right to work in the UK and suitable references.

We have in place systems to encourage the reporting of concerns and the protection of whistle blowers.

Where possible the procurement department will build long standing relationships with the trusts suppliers and make clear our expectations of business behaviour. With regards to national or international supply chains, we expect these entities to have suitable anti-slavery and human trafficking policies and processes.

The parts of trust business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk

Rotherham, Doncaster and South Humber NHS Trust (RDaSH) is committed to social and environmental responsibility and has zero tolerance for modern slavery and human trafficking. Any identified concerns regarding modern slavery and human trafficking would be escalated as part of the organisational safeguarding process and in conjunction with partner agencies; such as the local authority and police.

With regard to training the trust has undertaken specific training of staff. The trust’s senior procurement team are or are working towards chartered institute of purchasing and supply (CIPS) qualified and abide by the CIPs code of professional conduct. The trust’s internal supply chain management has undertaken specific training related to modern slavery and human trafficking. The trust intranet includes a module which is available to all members of staff which provides a basic knowledge and understanding on modern slavery and human trafficking to all staff.

The trust has evaluated the principal risks related to slavery and human trafficking and identify them as:

• reputational
• lack of assurances from suppliers
• lack of anti–slavery clauses in contracts
• training staff to maintain the trust’s position around anti-slavery and human trafficking

Performance indicators have been developed during the year to provide the reader with an ability to assess the effectiveness of the statement.

Actions taken by procurement

As part of our responsibilities under this act we have to demonstrate that our supply chains confirm their compliance with this act. There a number of actions we have  undertaken to ensure that our suppliers are transparent and comply with this act. These are:

1. written out to all our suppliers to ensure they comply with this Act. The Act requires that suppliers with a global turnover of £36 million or more, provide their own mandatory modern slavery statement and suppliers with a turnover of up to £36 million provide a compliance statement
2. the trust procurement strategy has been updated to reflect this act
3. will create and populate an ethical procurement module by January 2020 which will include:
   • assurance letter to suppliers
   • our annual statement
   • guidance document of Modern Slavery Act
   • trust procurement strategy
4. the trust tender documents to include a link to our ethical procurement module by January 2020.
5. the trust pre-qualification questionnaire includes a specific question which confirms the supplier’s compliance with the act
6. all tenders issued by the Procurement team will include a 10% weighting for social value
7. all the trust procurement staff have undertaken training on this act to ensure new suppliers are checked for their compliance and act as gatekeepers to ensure non-compliant organisations are reported via our organisational safeguarding process in conjunction with partner agencies, such as police and local authorities

Aim 

The aim of this statement is to demonstrate the trust follows good practice and all reasonable steps are taken to prevent slavery and human trafficking.

All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility lead for overall compliance.

Lynne Beedle, Head of Procurement, March 2023

Page last reviewed: January 22, 2024
Next review due: January 22, 2025