Modern Slavery Act Trust Statement

The Trust is aware of our responsibilities towards patients, service users, employees and the local community and expects all suppliers to the Trust to adhere to the same ethical principles.  We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships.

Currently, all awarded suppliers sign up to our terms and conditions of contract which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with the Trust’s stance on anti-slavery.  In addition, an increasing number of suppliers are implementing the Labour Standards Assurance System (LSAS) as a condition of contract for tenders within high risk sectors and product categories and indeed this has been referenced in the Government’s Modern Slavery Strategy.  Many aspects of the LSAS align to the seven reporting areas that the Government has outlined and should appear within any slavery and human trafficking statement.

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner.  These include:

  • Recruitment policy.  We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff, and 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
  • Equal Opportunities.  We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations.  These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities
  • Safeguarding policies.  We adhere to the principles inherent within both our safeguarding children and adults policies.  These are compliant with Medway multiagency agreements and provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain
  • Whistleblowing policy.  We operate a Freedom to Speak Up, Raising Concerns at Work and Whistleblowing Policy so that all employees 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
  • Standards of business conduct.  This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act

Our approach to procurement and our supply chain includes:

  • Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes
  • Requiring that the main contractor provides details of its sub-contractor(s) to enable the Trust to check their credentials
  • Random requests that the main contractor provides details of its supply chain
  • Ensuring invitation to tender documents contain a clause on human rights issues
  • Ensuring invitation to tender documents also contain clauses giving the Trust the right to terminate a contract for failure to comply with labour laws
  • Using the standard Supplier Selection Questionnaire (SQ) that has been introduced (which includes a section on Modern Day Slavery)

Trust staff must contact and work with the Procurement department when looking to work with new suppliers so appropriate checks can be undertaken.

Supplier adherence to our values: we are zero tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit.

Where it is verified that a subcontractor has breached the child labour laws or human trafficking, then this subcontractor will be excluded in accordance with Regulation 57 of the Public Contracts Regulations 2015.  The Trust will require that the main contractor substitute a new subcontractor.

More information can be found in the Trust's Modern Day Slavery Policy