Modern Slavery Act 2015 - Annual Statement 2022-23
In accordance with the Modern Slavery Act 2015, East Lancashire Hospitals NHS Trust (ELHT) makes the following statement regarding the steps it has taken in the financial year 2022-23 to ensure that Modern Slavery i.e. slavery and human trafficking, is not taking place in any part of its own business or any of its supply chains.
Organisations Structure and Business
ELHT is an integrated provider of hospital and community healthcare services, with over 1,000 beds and almost 10,000 staff providing a comprehensive range of local services to the 566,000 population of East Lancashire, as well as specialist services to Lancashire and South Cumbria, meeting the often complex needs of a wide range of patients. We have an annual turnover of over £500 million.
ELHT provides over one million hospital and community contacts for patients across:
- Emergency and elective inpatient services
- Day case services
- Outpatient services
- Diagnostic and therapeutic services
- Adult and children community services
The majority of acute services are delivered at the main hospital sites in Blackburn and Burnley. ELHT also provides:
- Adult community healthcare services across East Lancashire
- A range of hospital and community services at Accrington, Clitheroe and Pendle Community Hospitals
ELHT is committed to:
- Comply with the Modern Slavery Act 2015 and regulatory requirements
- Make suppliers and service providers aware that we promote the requirements of the legislation
- Develop an awareness of human trafficking and modern slavery within our workforce
- Consider human trafficking and modern slavery issues when making procurement decisions
ELHT’s Policies on Modern Slavery
We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and, in so far as is possible, to requiring our suppliers hold a corresponding ethos. To identify and mitigate the risks of modern slavery and human trafficking in our own business, ELHT uses robust recruitment procedures, details of which are found in its Pre and Post Employment Checks Policy (HR01 V4). The policy supports compliance with national NHS Employment Checks and CQC standards. The Trust has a number of controls in place to ensure compliance with employment legislation including adherence to NHS Employment Check standards which includes right to work and suitable references. In addition, the Trust has developed and implemented a Human Trafficking Policy, Practice, Guidelines 2020 (C119) which is aimed at all staff and is intended to help frontline staff and managers to identify individuals who may have been trafficked and provide good practice guidance. This policy applies to all permanent, locum, agency, bank and voluntary staff at the Trust.
ELHT’s Safeguarding Children and Safeguarding Adults policies incorporate sections on modern slavery. In addition, modern slavery is referenced within the Safeguarding Children and Adult mandatory training from Levels 1-3, which applies to all staff employed by the Trust. The Trust safeguarding training is in line with the requirements of the National Safeguarding Training Intercollegiate Guidance for both adults and children.
ELHT’s staff must:
- Undertake Safeguarding training appropriate to their roles and responsibilities.
- Work with the Procurement Department when looking to work with new suppliers so appropriate checks relating to modern slavery can be undertaken.
Working with Suppliers
The Trust has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity in all its business dealings. The Trust works in partnership to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of its supply chains, consistent with the Trust’s disclosure obligations under the Modern Slavery Act 2015. The Trust expects the same high standards from all contractors, suppliers and other business partners.
Procurement ensures all expenditure commitment is via the NHS Terms and Conditions for goods and services which includes extensive conditions, relating to Modern Slavery that the Supplier and each of its sub-contractors must adhere to.
Procurement has implemented the government’s Social Value Model which requires a minimum of 10% weighting in all procurements dedicated to Net Zero and Social Value, including the elimination of Modern Slavery. This ensures the trust only contract with companies who comply with modern slavery legislation.
Procurement are also aware that the owners of the frameworks that are utilised (NHS Supply Chain, Crown Commercial Services, NHS Shared Business Services etc) are working with their supply chains to ensure the eradication of modern slavery so where a decision to utilise a framework in favour of running a Find a Tender Service (FTS), the framework terms and conditions still provide appropriate measures to manage identified modern slavery which ultimately is likely to be the immediate termination of said contracts. Framework owners also utilise their own supplier selection criteria ahead of framework/contracts awards which minimises the likelihood of the trust contracting with non-compliant suppliers
Contract management of strategic and higher risk contracts provides the on-going opportunity to identify modern slavery and manage this effectively. The Trust reserves the right to terminate contracts immediately if the other party is in breach of its obligations under the Modern Slavery Act 2015.
Many of the procurement staff are CIPS (Certificate in Procurement and Supply Operations) qualified, which includes modules on ethical procurement practices to ensure they are best placed to notice and manage instances of modern slavery. The procurement team have also undertaken government modern slavery training.
The Trust follows good practice, ensuring all reasonable steps are taken to prevent slavery and human trafficking and will continue to support the requirements of the Modern Slavery Act 2015 and any future legislation.
Original document signed on behalf of the Trust Board by:
Mr Richard Smyth, Non-Executive Director and Chair of the Audit Committee Mrs Michelle Brown, Executive Director of Finance
22 June 2023