Modern Slavery Act annual statement

The Modern Slavery Act 2015

The Modern Slavery Act is a piece of legislation which sets out a range of measures on how modern slavery and human trafficking should be dealt with in the UK. Whilst not all the Act is directly relevant for business, section 54 entitled ‘Transparency in supply chains’ impact the corporate sector. The Act, which came into force on 29 October 2015, requires many businesses to disclose a ‘slavery and human trafficking statement’. Hertfordshire Partnership University NHS Foundation Trust complies with this requirement in the following statement, which was approved by the Information Governance Committee in July 2024.

Modern Slavery and Human Trafficking Statement 2024-25

Introduction

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. It encompasses slavery, servitude, human trafficking, and forced labour. 

Hertfordshire Partnership University NHS Foundation Trust has a zero-tolerance approach to any form of modern slavery and supports the eradication of modern slavey and human trafficking, recognising the significant role the NHS has to play in both combatting it and supporting victims.

As a Trust we are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.  

Overview

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Trust’s slavery and human trafficking statement for the financial year ending 31 March 2024. The statement sets out the steps that Hertfordshire Partnership University NHS Foundation Trust (HPFT) has taken and is continuing to take to make sure that modern slavery or human trafficking is not taking place within our business or supply chain, or in any part of our business during the year ending 31 March 2024.

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 aim of this statement is to demonstrate that Hertfordshire Partnership University NHS Foundation 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. 

We have a zero-tolerance approach to any form of modern slavery or human trafficking in any part of our business activity. We are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.

About Us

Our Trust is a provider of integrated inpatient and community mental health and learning disability services treating and caring for over 400,000 people, across Hertfordshire and within Buckinghamshire, Norfolk and Essex.  In 2022/23 we had an annual turnover of over £393 million.  We have a longstanding partnership with Hertfordshire County Council and are one of the few integrated social care providers of mental health services in England.  We also deliver a range of nationally commissioned specialist services including specialist tier 4 services for children and young people, perinatal services and medium and low secure learning disabilities services.

We employ over 4,000 people who deliver these services within the community and inpatient settings.

As a University NHS Trust we are proud of the strong relationship with the University of Hertfordshire, an important partner supporting workforce development, research, training and innovation.

We have been an NHS Foundation Trust since our authorisation in August 2007 and continue to value the opportunities that this provides in building upon, and improving, our services.   The Trust is rated ‘outstanding’ by the Care Quality Commission.

Our Commitment

• We are fully aware of the responsibilities we have towards our service users, carers, staff and local communities.  Our overall approach is to ensure that we are compliant with legislative and regulatory requirements.  We aim to follow good practice and take all reasonable steps to prevent modern slavery and human trafficking.
  
  
• We are committed to promoting a proactive and inclusive approach to belonging and inclusion in both employment and service provision which supports and encourages an inclusive culture which values diversity; this includes a commitment to building a workforce which is valued and whose diversity reflects the communities it serves, enabling the Trust to deliver the best possible healthcare services to the community.
  
  
• We aim to design and provide services, implement policies and make decisions that meet the diverse needs of our service users and carers, the population we serve and our people ensuring that none are placed at a disadvantage.
• We are guided by a strict set of ethical values in all of our business dealings and expect our suppliers to adhere to these same principles. We are committed to ensuring there is no modern slavery in any part of our business in so far as possible and require our suppliers to hold similar ethos.
  
  
• We are committed to ensuring that all our staff 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 an individual may be or is at risk of modern slavery and human trafficking.
  
  
• We ensure modern slavery guidance is embedded into the Trust safeguarding policies. Staff are expected to report concerns about modern slavery and human trafficking, and management are expected to act upon them in accordance with our policies and procedures.  Guidance on modern slavery and human trafficking – what it means, what are the types and who is affected, what to do if you suspect someone of being subjected to slavery, and further advice, support and resources – can be found on the Trust’s intranet site.
  
  
• We adhere to the National NHS Employment Checks/Standards this includes right to work in the UK, employees’ UK address and factual references.

Governance and policies

To identify and mitigate the risks of modern slavery and human trafficking in our business and in our supply chain, we:

• Operate a robust recruitment and selection policy, including appropriate pre-employment checks reflecting the national NHS Employment Checks/Standards requirements on directly employed staff. Agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will.
  
  
•  Implement a range of controls to protect staff from poor treatment and/or exploitation which comply with all respective law as and regulations; these include provision of fair pay rates, fair terms of conditions of employment and access to training and development opportunities.
  
  
• Consult and negotiate with Trade Unions/Staffside on proposed changes to employment, work organisation and contractual matters.
  
  
• Have systems to encourage the reporting of concerns including an active freedom to speak up process so that all staff know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.
  
  
• Have an incident reporting policy that states that staff should report incidents of all types and this includes concerns regarding modern slavery and human trafficking.
  
  
• Provide regular Freedom to Speak Up reports to the Trust Board which includes an overview of the concerns raised by staff and the category they fall into.
  
  
• Have a Standards of Business Conduct policy which explains the manner in which we behave as an organisation and about how we expect our staff and suppliers to act.
  
  
• Equality impact assess all our people, procurement and commercial policies to ensure that colleagues are always treated fairly.

Working with Suppliers 

• The Trust applies the NHS standard Terms and Conditions for PO’s, Goods, Services and the provision of Goods and Services which are used for the majority of procurements and require suppliers to comply with relevant legislation.
  
  
• A large proportion of the goods and services procured are sourced through Government supply frameworks and contracts which also require suppliers to comply with relevant legislation.
   
• Social value considerations are also included in specifications and evaluation criteria where this is appropriate and legal to do so.
  
  
• The Trust procures goods and services from a range of providers and while contracts may vary from small one-off purchases to large service contracts, all spend is, with very few exceptions, subject to the NHS Standard terms and conditions which holds the supplier to adhere to the requirements of Modern Slavery, Environmental, social and labour law requirements.
  
  
• Ensuring that our suppliers are carefully selected through our robust supplier selection criteria and processes.
  
  
• Evaluate specifications and tenders with appropriate weight given to social value.
  
  
• Upholding professional codes of conduct and practice relating to procurement and supply.
  
  
• Purchasing 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.
  
  
• Utilising 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 our local NHS procurement service and contain the standard Terms and Conditions.
  
  
• 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 Trust service delivery and business.
  
  
• High value contracts are effectively managed by stakeholders in the trust and relationships built with suppliers.
  
  
• Trust staff must contact and work with the procurement team when looking to work with new suppliers so appropriate checks can be undertaken.

Training

All staff have a personal responsibility for the successful prevention of modern slavery and human trafficking.  Advice on modern slavery human trafficking is available to staff through our safeguarding policies and procedures, and through our safeguarding leads.  Safeguarding training is mandatory for all staff via our online training system and courses include awareness of modern slavery.

Confirmation

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