Modern Slavery and Human Trafficking Act (2015) Statement
At London North West Healthcare NHS Trust (LNWHT) we are committed to ensuring that no modern slavery or human trafficking takes place in any part of our business or our Supply chain. This statement sets out actions taken by LNWHT to understand all potential modern slavery and human trafficking risks and to implement effective systems and controls. The Section 54 of the Modern Slavery Act 2015 requires all organisations to set out the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.
The aim of this statement is to demonstrate the LNWHT follows good practice and all reasonable steps are taken to prevent slavery and human trafficking.
Trust Board approval
The Trust Board has considered and approved this statement and will continue to support the requirements of the legislation.
With regard to training the LNWHT has not undertaken any specific training of staff. The department’s senior procurement team are all Chartered Institute of Purchasing and Supply (CIPS) qualified and abide by the CIPs code of professional conduct.
Over the next year, the LNWHT’s internal supply chain management will be required to undertake specific training related to modern slavery and human trafficking.
The LNWHT considers the principal risks related to slavery and human trafficking and identifies them as:
- Lack of assurances from suppliers
- Lack of anti–slavery clauses in contracts
- Training staff to maintain the trust’s position around anti-slavery and human trafficking
Performance indicators will be developed during the year to provide the reader with an ability to assess the effectiveness of the statements from targeted suppliers.
The Trust has internal policies and procedures in place that assess supplier risk in relation to the potential for modern slavery or human trafficking. The top 80% of suppliers nationally, affirm their own compliance with the modern slavery and human trafficking act within their own organisation, sub-contracting arrangements and supply chain.
All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility for overall compliance.
To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain, we:
- Purchase a significant number of products through NHS Supply Chain, whose ‘Supplier Code of Conduct’ includes a provision around forced labour
- Where possible, build long standing relationships with suppliers
- The Trust will 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 ensuring no modern slavery or human trafficking related to our business
- Uphold professional codes of conduct and practice relating to procurement and supply, including through our Procurement Team’s membership of the Chartered Institute of Procurement and Supply
- The Trust will write bi-annually to the top 250 suppliers by spend requesting them to affirm their compliance with the legislation. The resultant Supplier Policies shall be logged, scanned and recorded in the Trust Contract Register
- The Trust will ask for evidence of Policy existing as part of all formal tender processes
- The Trust undertakes an annual audit on non-pay expenditure as part of their audit plan. The audit includes a statutory compliance element. In future this will include the modern slavery and human trafficking act requirements.