Modern Slavery Statement
This information was last updated May 2020.
In accordance with the Modern Slavery Act 2015, we are obliged to submit a Modern Slavery Statement each financial year. This sets out the actions we have completed, and what steps we will take in future to ensure there is no modern slavery or human trafficking in any part of our business or supply chains.
- What is Modern Slavery?
- The Role of Local Authorities
- Existing Policies and Procedures
- Due Diligence Processes
- Action Plan and Ownership
- Reporting and guidance
This Modern Slavery Statement for 2020 to 21 sets out what steps we have completed, and what steps it will take in future to ensure that there is no modern slavery or human trafficking in any part of our business, including our supply chains.
In accordance with the Modern Slavery Act 2015, we are required to produce a slavery and human trafficking statement each financial year.
Modern slavery encompasses slavery, servitude, forced and compulsory labour, and human trafficking. Traffickers and slave drivers coerce, deceive and force individuals against their will into a life of abuse, servitude and inhumane treatment (HM Government Modern Slavery Strategy, 2014).
According to the Local Government Association (LGA), the term ‘Modern Slavery’ includes a range of different types of exploitations, that may or may not occur together. The different types of exploitations include but are not limited to:
- sexual exploitation
- domestic servitude
- forced labour
- criminal exploitation
- other forms of exploitation, such as: organ removal; forced begging; forced benefit fraud; forced marriage and illegal adoption
The 2019 UK Annual Report on Modern Slavery states that in 2018 there were 6,985 potential victims referred to the National Referral Mechanism (the UK’s identification and support system for victims of modern slavery) - a 36% increase since 2017. Of these, 689 referrals related to cases in the East of England - a 30% increase from the 528 cases referred in 2017.
The same document indicates that the number of modern slavery crimes recorded by the Police for 2018 to 2019 was 5,059 (a 49% increase compared to the previous year), whilst the UK Modern Slavery Helpline indicates that in 2018, 22 cases of modern slavery were reported to them as having occurred in Cambridgeshire.
Within the district itself, we have worked with partner agencies, such as Cambridgeshire Constabulary, to respond to incidents of modern slavery. In one recent example, 5 vulnerable workers were found to be living in unacceptable conditions on an agricultural nursery site in the district. Incidents like this and figures such as those detailed above, serve as a reminder that modern slavery is a continuing issue, requiring a coordinated response on a national, local and regional scale.
Within their Tackling Modern Slavery: A Council Guide (2017) document, the LGA highlight the following roles of local authorities in tackling modern slavery:
- Identification and referral of victims
- Supporting victims – this can be through safeguarding children and adults with care and support needs and through housing/homelessness services
- Community safety services and disruption activities
- Ensuring that the supply chains councils procure from are free from modern slavery.
Each of these points have been included as an area of focus within the action plan detailed later in this statement.
We have a range of policies, processes, procedures and practices which help to ensure that we are acting ethically and with integrity to prevent slavery and human trafficking, including the following:
- Safeguarding Policy: we are committed to safeguarding and promoting the welfare of children and adults at risk of harm and their families. We have signed an agreement with Cambridgeshire County Council to work within their Adult Safeguarding policy guidelines and procedures. We take our responsibilities seriously and expect all staff, partners and contractors to share this commitment. We ensure our procurement and contracting policies and procedures adequately reflect our safeguarding responsibilities, and that all incidents of poor practice, allegations and suspicions are taken seriously, reported, and are always responded to. Additionally, all staff are expected to attend regular safeguarding training.
- Whistleblowing Policy: we encourage staff, contractors and elected Members who have serious concerns about any aspect of our activities, to come forward and voice those concerns. Our Whistleblowing Policy has been prepared in consultation with staff and with the help of the independent charity, Public Concern at Work. It commits us to ensuring that whistle-blowers will suffer no recrimination or victimisation as a result of raising a genuine concern about malpractice.
- Pay Policy: We are committed to ensuring that its pay strategy is fair and equitable, affordable, transparent and easily understood, enabling the organisation to attract, retain and develop a skilled and flexible workforce. Our staff salaries are evaluated using the National Joint Council (NJC) Job Evaluation Scheme which is based on the principle of joint ownership, openness, transparency and equality.
- Equality and Diversity Scheme: we are committed to the equality of opportunity in our approach to service delivery, employment and community leadership. 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 characteristics.
- Recruitment Process: our Recruitment and Selection policy and procedures are designed to recruit staff in a fair and consistent way that supports equality of opportunity. Our recruitment processes are open and robust with procedures for checking that interview attendees are eligible to work in the UK and for requesting and following up applicant references. We also aim to ensure that interview panel members have received interview training, covering equality and diversity, to ensure a consistent and fair process.
- Agency Workers: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Code of Conduct: All employees of South Cambridgeshire District Council are expected to work to our code of conduct, including fair and equitable treatment of all staff, customers, and residents.
- Partnership Working: we work closely with several partner organisations. These organisations are also expected to adhere to policies which protect against modern day slavery and discrimination.
- Safeguarding Training: This includes how to spot the signs of modern slavery and how to make a referral. Safeguarding training is mandatory for all members of staff at South Cambridgeshire District Council.
- Procurement Training: This training includes awareness of modern slavery and actions that are taken to prevent the modern slavery from occurring within our supply chain. In the past year, around 70 individuals have completed this training.
- Safeguarding Lead and Officers: We have a designated Safeguarding Lead (Geoff Clark - firstname.lastname@example.org) and safeguarding officers have been identified across our services (a list of these can be found on our intranet).
In all our procurement activity, we aim to be consistent with the highest standards of integrity and to ensure fairness in allocating contracts.
Equality and diversity, social responsibility and safety are important criteria in the provision of goods and services procured. These criteria are achieved through the following requirements:
- key contractors must have safeguarding policies, procedures and training in place.
- larger contractors must undertake regular audits of their safeguarding policies, procedures and training, reporting the outcome to us.
- the Official Journal of the European Union (OJEU) tender processes requires potential suppliers to confirm that they meet the requirements under the Modern Slavery Act 2015. This will continue to be the case under any replacement for the OJEU tender processes post-Brexit.
- any supplier engaged by us is contracted to do so in line with the authority’s Modern Slavery Statement, Safeguarding Policy; Equality and Diversity Scheme; Code of Conduct and Whistleblowing Policy.
- should we look to procure or import products or services from outside the EU, we would undertake further consideration of supply chains in order to account for potential risks.
- We expect all suppliers of goods and services to have their own policy relating to working practices or modern slavery, or for evidence to be available to ensure their standards are in accordance with our expectations. We request that our suppliers ensure the same of their own supply chains.
Suppliers to us must abide by all employment legislation and regulations. We examine, as appropriate, suppliers’ past records in respect of their treatment of staff and their conduct in relation to modern day slavery and human trafficking.
Our zero-tolerance approach to modern slavery includes communication to all suppliers, contractors and business partners at the outset of the business relationship with them and reinforced as appropriate thereafter. Where there are questions over the conduct of a supplier then these shall be investigated, and the appropriate action taken.
The table below sets out our modern slavery prevention objectives for 2020 to 2021. These are categorised using the four roles of local authorities in tackling modern slavery, as set out by the LGA:
|Local Authority Role||Action||Team/Service|
|Identification and referral of victims||Run communications to raise awareness around modern slavery across the organisation.||Policy, Performance and Projects|
|Identification and referral of victims||Ensure all staff complete safeguarding training that includes modern slavery referral processes for us.||HR|
|Identification and referral of victims||Provide an enhanced ‘Modern Day Slavery’ online e-learning module to all staff.||HR|
|Supporting victims – this can be through safeguarding children and adults with care and support needs and through housing/ homelessness services||Ensure all staff complete safeguarding training that sets out what to do when someone is thought to be experiencing abuse or neglect.||HR|
|Supporting victims – this can be through safeguarding children and adults with care and support needs and through housing/ homelessness services||Work with partners to carry out the South Cambridgeshire Community Safety Partnership communications plan which features Modern Day Slavery. This includes awareness campaigns e.g. National Anti-slavery day (18 October).||Sustainable Communities|
|Supporting victims – this can be through safeguarding children and adults with care and support needs and through housing/ homelessness services||Ensuring the ‘Community Eyes and Ears’ leaflet and project principles are circulated across South Cambridgeshire. This project addresses Modern Day Slavery as well as a range of other issues.||Sustainable Communities|
|Raise awareness of modern slavery and how to report it amongst South Cambridgeshire licenced taxi drivers, through the Taxi Proficiency and Safeguarding course.||Licensing|
|Community safety services and disruption activities||Continue to play a leading role within the South Cambridgeshire Community Safety Partnership. This includes joint work with Cambridgeshire Constabulary, Cambridgeshire Fire and Rescue Service, Local Authorities and a range of other agencies to protect vulnerable people living in the district that may be exposed/coerced into modern slavery and trafficking.||Sustainable Communities|
|Community safety services and disruption activities||Work with partners to carry out the South Cambridgeshire Community Safety Partnership action plan which features Modern Day Slavery.||Sustainable Communities|
|Community safety services and disruption activities||Highlight modern slavery as one of several issues for focus at the annual Community Resilience Event.||Sustainable Communities|
|Community safety services and disruption activities||Continue to work in partnership with other agencies such as Cambridgeshire Constabulary in response to reported incidents of modern slavery.||Environmental Health|
|Ensuring that supply chains are free from modern slavery||Undertake a review of our existing contract’s list to determine whether any additional action is required.||Procurement|
|Ensuring that supply chains are free from modern slavery||Modern slavery is included within the procurement training that is delivered to all our staff purchasing goods and services on behalf of the us.||Procurement|
|All roles||Identify an Anti-Slavery Member Champion.||Cabinet|
We are the lead member of the South Cambridgeshire Community Safety Partnership. This partnership includes joint work with Cambridgeshire Constabulary, Cambridgeshire Fire and Rescue Service, Local Authorities and a range of other agencies to protect vulnerable people living in the district that may be exposed/coerced into modern slavery and trafficking.
All modern slavery concerns raised by our staff, councillors and volunteers are reported via the National Referral Mechanism.
Reporting for Council employees
Any South Cambridgeshire District Council employees affected by slavery, or who suspect someone is at risk are advised to:
- Report concerns to a Safeguarding Officer. A list of designated Safeguarding Officers can be found on our staff directory, located on our Intranet. The Safeguarding Lead is Geoff Clark, email@example.com.
- Following the ‘reporting a concern’ process for child or adult safeguarding process.
Reporting for residents and communities
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 08000 121 700
- Report online via the Modern Slavery Helpline
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