Modern Day Slavery and Human Trafficking Statement 2023 - 2024

The Trust is fully 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.  The Trust is committed and will not tolerate modern slavery in any of its forms of slavery and servitude, forced or compulsory labour and human trafficking within our activities or our supply chains.

The Trust continues to fully support the government’s objective to eradicate modern slavery and human trafficking and we acknowledge our role in both combating it and supporting victims. The Trust is committed to ensuring our supply chains and our business activities are free from ethical and labour standards abuse.

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.

People - Human resources policies provide processes and procedures to ensure that our employees and those employed in our supply chains are treated fairly at all times; these include:

  • Confirming the identities of all new employees and their right to work legally in the UK.
  • To have assurance from approved agencies that pre – employment clearance has been obtained for agency staff and to safeguard against human trafficking.
  • All staff appointed are subject to references, immigration and identity checks, this is to ensure staff have the legal right to work in the UK.
  • The Trust has a set of values and behaviours that staff are expected to comply with, and all candidates are expected to demonstrate these attributes as part of the recruitment selection process.
  • Adopting the national pay, terms and conditions of service, the Trust has the assurance that all staff will be treated, fairly and that pay, terms and conditions will comply with the latest legislation.
  • The Trust has various employment policies and procedures in place designed to provide guidance and advice to staff and managers and also to comply with the relevant legislation. These are accessible on the intranet.
  • The Trust is committed to creating and ensuring a non – discriminatory and respectful working environment for all staff, this is in line with its corporate social responsibilities.
  • The Trust’s Equality, Diversity and Inclusion, Grievance, Respect and Dignity at Work and Whistleblowing policies and procedures additionally give a platform for all employees the Freedom to Speak Up and to raise concerns about poor working practices.
  • Ensuring appropriate mechanisms to regularly review and monitor progress on promoting and supporting diversity and inclusion within the Trust.
  • All staff are required to undertake mandatory training in relation to diversity and inclusion and safeguarding.

Whistleblowing (Freedom to Speak Up) – The Trust’s Whistleblowing policy gives a platform for employees to raise concerns for further investigation and offers support to individuals that have suffered fiscal or professional detriment as a result of whistleblowing. 

  • The Trust operates a Freedom to Speak Up, Raising Concerns at Work, so employees feel empowered to raise concerns around poor practices, health and safety or illegal activities which may bring harm to the Trust.

Safeguarding – The Trust is committed to the principles setup in our safeguarding adults and children policies. 

  • The Trust is compliant with Medway multiagency agreements.
  • Ensure clear safeguarding guidance so that employees, contractors, patients and the public are able to raise safeguarding concerns about how they are being treated or/ and about working practices at the Trust.

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: the Trust has zero tolerance 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.