1. Introduction
What is modern slavery? Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. It can include:
- Sexual Exploitation
- Labour Exploitation
- Forced Criminality
- Organ Harvesting
- Domestic Servitude
- Debt Bondage
Anyone can become a victim of modern slavery, with particularly vulnerable groups including:
- unaccompanied, internally displaced children;
- children accompanied by an adult who is not their relative or legal guardian;
- young girls and women;
- former victims of modern slavery or trafficking.
1.2 Wealden District Council (the Council) is committed to improving its practices to prevent slavery and human trafficking in its corporate activities and to ensuring that the services it commissions (and where applicable, the associated supply chains) are free from slavery and human trafficking. The Council has a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships.
1.3 The Council recognises its responsibility to notify the Secretary of State of suspected victims of slavery or human trafficking as contained in Section 52 of the Modern Slavery Act 2015 and to take a robust approach to modern slavery and human trafficking as a public authority, an employer and contractor of other bodies.
1.4 Councils have a key role to play in tackling modern slavery, including in identifying and supporting victims and working in partnership locally. Councils’ role can be separated into four distinct areas:
- Identification and referral of victims
- Supporting victims – for example this can be housing/homelessness services
- Community safety services and disruption activities
- Ensuring that the supply chains the Council procures are free from modern slavery.
1.5 This Statement sets out the Council’s actions and activities to understand potential modern slavery risks related to our services (directly provided and commissioned) and to seek to ensure no slavery or human trafficking takes place in our services or supply chains.
2. Organisational structure and supply chains
This statement covers the activities of the Council. The council is a local authority based in Hailsham, East Sussex, which provides a wide range of statutory and discretionary services, delivered both directly by the Council and through external contractors.
2.4 The procurement of services is an important part of a councils’ expenditure and understanding our supply chains and assessing the risk to those working in it is not easy and requires commitment, support and collaboration. Councils are uniquely placed with the wide range of goods and services that we procure placing us in a strong position to support the fight against modern slavery.
2.5 The East Sussex Procurement Hub (ESPH) is the shared procurement service for Wealden District Council, Rother District Council and Hastings Borough Council. ESPH was formed in 2010 and manages the procurement activities for all three Councils. Collectively, these Councils procure a diverse range of goods, services and works, including:
- Works and Construction
- Consultancy
- Vehicle Management
- Financial Services
- Environmental Services
2.6 As a significant amount of the Council’s goods and services are procured via ESPH, its contribution to anti-slavery in our supply chain activities is vital. The Corporate Procurement Strategy sets out the positive approach taken to combat modern slavery (set out in more detail in the Annex).
3. Partnerships
The Council works in partnership with a wide number of agencies in order to combat modern slavery:
- The Safer Wealden Partnership
- National Crime Agency
- Operation Discovery: launched in December 2017, the partnership supports operations in East Sussex including Wealden and aims to share information and intelligence to safeguard potential victims and make it difficult for offenders to operate in East Sussex
- Sussex Police
- Gangmasters and Labour Abuse Authority.
4. Policies in relation to Slavery and Human Trafficking
4.1 The Council reviews its policies and procedures on an ongoing basis to ensure they remain compliant and fit for purpose. The policies and procedures contained in the Annex to this Statement are considered to be key contributors in meeting the requirements of the Modern Slavery Act 2015.
5. Due Diligence Process and Risk Management
As part of the Council’s commitment to identify and mitigate risks of modern slavery, we will:
- Robustly undertake thorough recruitment and selection processes for all employees;
- Continue and build on the partnerships referred to in section 3;
- Providing training and awareness raising for staff and partner organisations to develop understanding of modern slavery and human trafficking
- Maintain and raise awareness of the Council’s whistle-blowing and Safeguarding policies;
- Mitigate the risk of slavery and human trafficking occurring in our supply chains by applying appropriate measures as part of the due diligence process before a contract is awarded including: – a requirement for suppliers to self-certify that they comply with the Modern Slavery Act 2015 with appropriate evidence; the investigation of abnormally low bids to ensure that there is sound reasoning behind the bid; robust contract management and diligent monitoring.
- Seek to identify and categorise procurements based on risk. Although modern slavery can affect virtually any industry and economic sector, there are a number of core characteristics that place workers at heightened risk of being exploited. Government guidance (PPN 02/23: Tackling Modern Slavery in Government Supply Chains) sets out the characteristics that can help organisations to identify which procurements may be at higher risk.
- Consider the use of Key Performance Indicators to measure the effectiveness of steps being taken by the Council as outlined in this Statement.
6. Training on modern slavery and trafficking
6.1 The Council’s Safeguarding Policies can be accessed via the Council’s intranet annually and at least annually, all staff are encouraged to familiarise themselves with the Safeguarding Policies and to discuss any concerns with designated Safeguarding leads. All staff are required to complete an e-learning package on safeguarding children and vulnerable adults which forms part of the mandatory refresher courses. Councillors have access to a comprehensive package of learning and development including access e-learning packages, which all serves to support them in carrying out their duties both within the Council, as well as when out working in the community for their constituents.
7. Sources of Guidance and Reporting of concerns
7.1 The Government have produced statutory guidance pursuant to Section 49 of the Modern Slavery Act 2015 to identify and support victims of modern slavery.
7.2 The Local Government Association has produced a range of guidance documents and resources to support councils with their work on modern slavery.
7.3 All Modern Slavery concerns raised by council staff, councillors and volunteers can initially be raised with the Investigations Team by contacting by contacting 01323 443350 or email: investigations@wealden.gov.uk. The Investigation Team can help provide appropriate advice and support. This may involve, as appropriate, referral via the Safeguarding Officer / Procedure or National Referral Mechanism or taking advice from the Modern Slavery Partnership.
7.4 The advice to residents and communities if they are affected by slavery, or suspect someone is at risk, is to:
- call 999 if it is an emergency
- call 101 for non-emergencies
- call Crimestoppers anonymously on 0800 555 111
- call the Modern Slavery Helpline on 0800 012 1700
- report online via the Modern Slavery Helpline
8. Approval and Review
8.1 The Director of Community has been designated to lead and oversee development of the Council’s work to combat modern slavery.
8.2 This Statement is made in accordance with Section 54(1) of the Modern Slavery Act 2015.
8.3 This Statement has been approved by the Council’s Corporate Management Team and will be reviewed and updated (as appropriate), at the end of each financial year.
Signed by:
Trevor Scott, Chief Executive
Date: 9th February, 2024
Councillor Kelvin Williams, Portfolio Holder for Public Health, Wellbeing and Asset Management
Date: 9th February, 2024
The Strategy sets out the positive approach taken by the Council to combat modern slavery which includes:
- Train all relevant staff using the Chartered Institute of Purchasing and Supply’s online course on Ethical Procurement and Supply (Public Sector).
- Require contractors to comply fully with the Modern Slavery Act 2015, wherever it applies, with contract termination as a potential sanction for noncompliance.
- Challenge any abnormally low-cost tenders to ensure they do not rely upon any potential contractor practising modern slavery.
- Highlight to our suppliers that contracted workers are free to join a trade union and are not to be treated unfairly for belonging to one.
- Publicise our whistle-blowing system for staff to blow the whistle on any suspected examples of modern slavery.
- Require our contractors to adopt a whistle-blowing policy which enables their staff to blow the whistle on any suspected examples of modern slavery.
- Regularly review our contracted spending to identify any potential issues with modern slavery.
- Highlight to our suppliers any risks identified concerning modern slavery and refer them to the relevant agencies to be addressed.
- Refer for investigation via the National Crime Agency’s national referral mechanism any of our contractors identified as a cause for concern regarding modern slavery.
- Annually report on the implementation of this policy.
Community resilience and wellbeing is a Council priority. It refers to the sustained ability of the community to use available resources to respond to, withstand, and recover from adverse situations. The priority explains how more social connection increases quality of life and wellbeing for all generations and the importance of
everyone being able to live a healthy and happy life whatever their background or situation.
This includes supporting the needs of our tenants and leaseholders. it is possible that an individual tenant or leaseholder could be subject to exploitation. For example, the Council must be alert to cuckooing or the potential for someone to become a victim of modern slavery. Alongside partners within the Wealden Strategic Partnership action will be taken to tackle all forms of exploitation.
The Council is committed to safeguarding the welfare of children and vulnerable adults. It has comprehensive Safeguarding Children and Adults Policies, which all staff and councillors are expected to read and adhere to. The Council carries out regular safeguarding training for all staff, has safeguarding leads within departments and participates in multi-agency partnerships to protect and safeguard people.
The Council has a robust and transparent recruitment and selection policy and procedure, designed to recruit staff in a fair and consistent way that supports equality of opportunity, and which seeks to ensure that all new workers that are recruited into the Council are subject to requisite pre-employment checks. Any offer of employment is subject to ensuring that all new employees are able to confirm their identify, qualifications and are eligible to work in the United Kingdom. All offers are also made subject to medical clearance and the receipt of two satisfactory employment references. The Council safeguards agency workers by ensuring agencies used are reputable and have appropriate policies in place to safeguard workers.
The Council operates a job evaluation scheme to ensure employees are paid fairly and equitably. The Council’s pay policy is based on fairness, affordability, consistency and market rates. The Council meets the recommended pay limits under the ‘Real Living Wage’ and is committed to ensuring that its pay strategy is legally compliant, transparent and easily understood, so enabling the organisation to attract, retain and develop a skilled and flexible workforce.
These Codes of Conduct make clear to employees and Members the professional actions and ethical behaviours expected of them when working for, and representing the Council on official business. The Codes promote a high standard of conduct based around the Nolan Principles of Public Life with the aim of maintaining public confidence in services provided, with any breaches thoroughly investigated.
Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns.
This sets out the decision-making arrangements used by the Council. It explains the responsibilities of the Council, the Members, and staff. It includes the Contract Procedure Rules which are intended to promote good purchasing practice, public accountability and deter corruption. The Constitution sets out how the Council authorises and manages spending and contracts with other organisations. It covers issues pertinent to the anti-slavery agenda such as ensuring that supply chain partners operate fair and ethical working practices when purchasing goods, works and services.
EDI is a Council priority in the Council Strategy. The Council is committed to equality of opportunity in our approach to service delivery, employment and community leadership, and is an integral part of its business processes. We are also committed to identifying, understanding and eliminating all barriers that prevent access to services, information and employment by people with one or more protected characteristic.
This policy provides a clear framework which is intended to give people the confidence to raise workplace concerns without fear of reprisal or victimisation. This policy is important for individuals wanting to raise concerns about modern slavery and/or related issues.
The Five Core Values underpin everything that we do here at Wealden. The values and behaviours underpin the work of the Council and the behaviours that employees are expected to display.
- Work Together
- Empathy
- Ambitious
- Lead
- Deliver