Modern Slavery and Human Trafficking Statement
The Modern Slavery Act 2015 introduced changes in UK law focused on increasing transparency in supply chains, to ensure our supply chains are free from modern slavery (that is, slavery, servitude, forced and compulsory labour and human trafficking).
As both a local leader in commissioning health care services for the population of Bristol, North Somerset and South Gloucestershire and as an employer, NHS Bristol, North Somerset and South Gloucestershire Integrated Care Board (ICB) provides the following statement in respect of its commitment to, and efforts in, preventing slavery and human trafficking practices in the supply chain and employment practices.
NHS Bristol, North Somerset and South Gloucestershire ICB considers human trafficking and slavery to be morally abhorrent, and entirely at odds with the ICB’s values, as well as those of the society in which we live and work. The ICB will use the legislative and procedural tools available to us to ensure that the ICB does not support or encourage any person or organisation involved in these practices, and where possible, we will use those tools to ensure that such people and organisations are detected and dealt with by the authorities.
Our organisation
NHS Bristol, North Somerset and South Gloucestershire ICB is a clinically led commissioning organisation in England and we work collaboratively across the health and care system to commission health care services including acute, community, primary care, mental health and learning disability services. We are responsible for buying health services for approximately 1 million people in our area.
Our commitment to Prevent Slavery and Human Trafficking
The NHS Bristol, North Somerset and South Gloucestershire ICB Board, Executive Management Team, commissioners and all employees are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and, in so far as it is possible, to hold our suppliers to account to do likewise.
Our approach
The ICB recognises that Safeguarding is everybody’s business and encourages it to be central to all decision making with the organisation. In order to achieve this we ensure that we have arrangements in place to provide strong leadership, vision and direction for safeguarding. We make sure we have clear accessible policies and procedures in line with relevant legislation, statutory guidance and best practice. The ICB Safeguarding Team have a strong profile at Corporate Induction to introduce themselves to all new employees. Statutory and Mandatory training for Safeguarding includes awareness on modern slavery. The ICB commits that the only providers that will be awarded contracts will meet all mandatory conditions set out in general and service conditions, as per the NHS Standard Contract 32.3.5. During 2024-25 as part of our commissioning assurance process we will request spot check with providers what plans and arrangements they have in place to prevent slavery in their activities and supply chain. During 2025-26 we will bring any learning together over this exercise in order to strengthen or provide further assurance to the ICB Board.
Our policies and arrangements
Our recruitment processes are robust and adhere to safe recruitment principles. This includes strict requirements in respect of identity checks, work permits and criminal records. Our policies, such as Safeguarding Adults, Children in Care and Children policies, Freedom to Speak up Guardians provide an additional platform and guidance for our employees to raise concerns about poor and inappropriate working practices.
Monitoring and Assurance
The ICB aims to be as effective as possible in ensuring that modern slavery and human trafficking is not taking place in any part of our business or supply chains by:
- Effective interagency working with local authorities, the police and third sector organisations which includes appropriate arrangements for preventing and responding to modern slavery and human trafficking. In particular, working with our leading third sector organisation based in the area called Unseen
- Supporting and attending the Anti-Slavery Partnership covering the Avon and Somerset Constabulary area
- Continuing to undertake robust NHS employment checks and payroll systems
- Ensuring good communication across different teams within the ICB in relation to contractual requirements and safeguarding/prevention of abuse and neglect
- Requiring the ICB’s providers to provide the ICB with assurance around safeguarding compliance within the agreed framework ensuring Modern Slavery and human trafficking are part of the organisation’s Mandatory Safeguarding Children and Adults training programme.