Modern Slavery & Human Trafficking Statement 2023 - 2024

Introduction

Modern Slavery can take many forms including slavery, servitude and forced or compulsory labour and human trafficking. The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom designed to combat modern slavery in the UK.

Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 requires all commercial operations in the UK with a turnover in excess of £36million to publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains.

The Trust has a zero-tolerance approach to any form of modern slavery, and this statement sets out the steps the Isle of Wight NHS Trust (the Trust) will take to ensure that modern slavery and human trafficking is not taking place within our business or supply chain.

All members of staff within the organisation have a personal responsibility for the successful prevention of modern slavery and human trafficking, with the Procurement Department taking a lead responsibility for compliance in the supply chain.

The Trust is committed to acting ethically, with integrity and transparency in all business dealings, and putting effective systems in place to safeguard against modern slavery taking place within the business or our supply chain.

Organisation structure, business, and supply chains

The Trust is the only integrated acute, community, mental health and ambulance health care provider in England. Established in April 2012, the Trust provides a full range of health services to an isolated offshore population of 140,000 and an annual turnover of around £330million.

Our Acute Care Services has 246 beds and handles 22,685 admissions each year. We have 32 Mental Health beds and Community Mental Health Teams supporting a case load of 1,300 patients. 

The Island’s ambulance service delivers all emergency and non-emergency ambulance transport for the Island’s population. With 21,712 emergency calls and 25,292 emergency vehicles dispatched each year the service operates from a single base across the Island. 

Following an inspection by the Care Quality Commission in 2021 we received a rating of ‘Good’.

In May 2024, our Community, Mental Health and Learning Disability Services will no longer be part of the Isle of Wight NHS Trust as they transfer to a new organisation partnering with neighbouring trusts to form the new Hampshire and Isle of Wight Healthcare NHS Foundation Trust.

Policies in relation to slavery and human trafficking

The Trust has several internal policies to ensure that we are conducting our business in an ethical and transparent manner. These include:

  • Recruitment and Selection Policy: we operate a robust recruitment policy, including eligibility to work in the UK checks for all directly employed staff. Audits are undertaken by the approved framework for all agency workers engaged via approved frameworks 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. We also require external agencies supplying temporary staff to demonstrate compliance with the legislation. Our Overseas Recruitment Team have robust systems and processes in place for ensuring that our overseas recruitment complies with modern slavery and human trafficking laws.
  • Equal Opportunities: we have a range of controls to protect staff from poor treatment and/or exploitation, which complies 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 both within our safeguarding child and adult policies. These 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.
  • Raising Concerns (Whistle Blowing) Policy: we operate a raising concerns 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 NHS code explains the way we behave as an organisation and how we expect our employees and suppliers to act.

Due diligence processes in relation to slavery and human trafficking

NHS South of England Procurement Services (SoEPS) provide a full range of services, including A to Z Strategic and Category Sourcing, Data Management and Consultancy services, Commissioned Healthcare, Operational Procurement, Supply Chain Management, and Advanced Inventory Management to Portsmouth Hospitals

University NHS Trust, Isle of Wight NHS Trust, and other NHS Clients. In delivering services they:

  • Comply with the Public Contract Regulations 2015, including application of the mandatory and discretionary exclusion grounds relating to modern slavery under Reg 57.
  • Use the CCS Standard Selection Questionnaire which asks suppliers to confirm their compliance with s.54 of the Modern Slavery Act 2015
  • Include PPN06/20 Social Value Model requirements within our tenders (one of the policy outcomes is on identifying and managing the risks of modern slavery)
  • Use the standard NHS Terms and Conditions when procuring goods and services, which include several requirements and obligations on suppliers in relation to modern slavery.

We undertake appropriate pre‐employment checks and require our agencies on approved frameworks to do the same. We protect staff from poor treatment and/or exploitation and comply with all respective laws and regulations including fair pay rates and terms of conditions of employment. We consult and negotiate with Trade Unions on proposed changes to employment, work organisation, and contractual relations.

Our Freedom to Speak Up (FTSU) Guardian supports people to raise and manage concerns in a confidential, supportive and anonymised manner, with appropriate signposting. This is a key role in promoting an open and honest culture of listening and learning, so that concerns raised are acted upon in a fair manner, and the speak up function is being actively promoted across the Trust.. The FTSU Guardian is also connected to a regional network of FTSU Guardians and has links with the ‘Respect Me’ service, staff networks and ‘whistleblowing’ line.

The Trust has a specialist Safeguarding Team which supports the organisation to ensure that we have robust safeguarding arrangements across all areas.

Risk assessment and management

We have a robust policy detailing how the Trust effectively manages risks; our aim is to promote a risk awareness culture in which all risks are identified, assessed, understood and proactively managed. This will promote a way of working that ensures risk management is embedded in the Trust’s culture and becomes an integral part of the Trust’s objectives, plans, practices and management systems.

Key performance indicators to measure effectiveness of steps being taken

  • KPI 1 - Requirement for Procurement staff to complete annual training on modern slavery.
  • KPI 2 - Reporting any suspected modern slavery violations to an Executive Director immediately upon detection and investigating the reports within 72 hours.
  • KPI 3 - Modern Slavery Assessment Tool will be completed for all new requirements over £2m which are assessed as medium to high risk of Modern Slavery.
  •  KPI 4 - Documented evidence of Modern Slavery as a standing Agenda item with Supplier Relationship meeting on a quarterly basis.
  • KPI 5 - The recruitment process for substantive staff is audited on a regular basis (average every two years), by the Trust’s auditors. This includes pre-employment checks and the rights to work in the UK.
  • KPI 6 - Monitoring of incidents and Freedom to Speak Up themes to identify any concerns relating to modern slavery.

Training on modern slavery and trafficking

Training is provided as part of our mandatory training package. Equality, Diversity and Human Rights training, Safeguarding Adults training, Safeguarding Children training, and Prevention of Radicalisation training all include role relevant modern slavery awareness, and staff are required to complete the courses every three years (except for Equality, Diversity and Human Rights training, which is completed once during the onboarding process). We also provide further support and resources on modern slavery and human trafficking on our staff intranet.

Staff are also able to access training provided by our Multi-agency Children’s Partnerships and Safeguarding Adults Boards.

We have teams responsible for safeguarding of adults and children, to whom staff are responsible for reporting of concerns and who will train staff on how to recognise issues of concern.

Review of effectiveness

In 2023/24, no concerns were identified by the Trust or brought to the Trust’s attention indicating non-compliance with the Modern Slavery Act 2015. We intend to continue to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in our supply chains. In 2024/25, our anti-slavery programme will include:

  • continuing to effectively monitor our contracts and supply chain to ensure that new and existing suppliers are compliant with the Modern Slavery Act 2015.
  • continuing to have robust recruitment systems and processes in place including for overseas recruitment and temporary workers.
  • strengthening our Freedom to Speak Up processes to ensure all staff feel confident and safe to raise concerns.
  • work with partners such the local councils and the police, as required, to ensure robust procedures are in place.
  • continuing to deliver safeguarding training and specialist support for all our staff; and implementing any new guidance or best practice.

Trust Leadership Team approval

The statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement. The Trust Leadership Team has considered and approved this statement 22/04/24 and will continue to support the requirements of the legislation.

Reporting and Signposting

If you suspect someone could be a victim of modern slavery, contact Isle of Wight Police on 999, 101 or through the Hampshire Constabulary website:  Home | Hampshire Constabulary

Alternative contacts, available 24 hours a day, 365 days a year:

Appendix 1: Isle of Wight Modern Slavery Statement 2022-23

Isle of Wight NHS Trust is committed to working towards eradicating modern slavery and human trafficking. We will actively ensure this by an ongoing review of all our strategies and business arrangements.

Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for several reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.

The Modern Slavery Act 2015 introduced changes in UK law and focused on increasing transparency in supply chains to ensure they are free from modern slavery. We are committed to working with local partners to improve our practice in combatting slavery and human trafficking and to raise awareness, disrupt and respond to modern slavery.

Definitions of Offences

Slavery, servitude and forced or compulsory labour - a person commits an offence if:

I. The person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the person is held in slavery or servitude, or;

II. The person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced for compulsory labour

Human trafficking - a person commits an offence:

I. If the person arranges or facilitates the travel of another person (victim) with a view to being exploited.

II. It is irrelevant whether the victim consents to travel and whether the victim is an adult or child.

A person is exploited if one or more of the following issues are identified in relation to the victim:

• Slavery, servitude, forced or compulsory labour

• Sexual exploitation

• Removal of organs

• Securing services by force, threat, and deception

• Securing services from children, young people, and vulnerable people

Assurance arrangements to prevent slavery and human trafficking

As one of the largest employers on the Isle of Wight and an organisation that contracts out many services, the governing body fully support the governments objectives to eradicate slavery and human trafficking and will work to ensure it doesn’t exist in any part of our business including in our supply chains. As an organisation, our commitment to social environmental responsibility is aligned to our approach to combatting modern slavery and human trafficking, which is part of our overarching safeguarding strategies and business arrangements.

Our actions include the following:

Safeguarding

Our overall approach is driven by compliance with legislative and regulatory requirements and the delivery of best practice in fields of contracting and employment. Our Safeguarding Adults Policy and Safeguarding Children Policy show our commitment to the eradication of modern slavery.

Workforce

We confirm the identities of all new employees and their right to work in the UK. This includes staff contracted through external agencies, who are sourced through approved frameworks. Our Grievance Policy and Freedom to Speak Up: Raising Concerns (whistleblowing) Policy give our employees multiple avenues to raise concerns about poor practice. Our Recruitment and Selection Policy also supports good practice and further protects workforce rights.

Training and promotion

Our online Equality, Diversity and Human Rights training, Safeguarding Adults training, Safeguarding Children training, and Prevention of Radicalisation training all include role- relevant modern slavery awareness, and staff are required to complete the courses every three years (except for Equality, Diversity and Human Rights training, which is completed once during the onboarding process). We also provide further support and resources on modern slavery and human trafficking on our staff intranet.

Suppliers / tenders

We comply with the Public Contracts Regulations 2015 and use the mandatory Crown Commercial Services (CCS) Standard Selection Questionnaire on procurements, which exceeds the prescribed threshold. Bidders are required to confirm their compliance with the Modern Slavery Act 2015.

When procuring goods and services, we additionally apply the standard NHS Terms and Conditions which require suppliers, and their sub-contractors, to comply with relevant modern slavery legislation.

Sub-contracts

Our Procurement and Contracting Team is qualified and experienced in managing healthcare contracts, which includes using our routine contract management meetings with our providers to address any issues of modern slavery.

This above statement on modern slavery is made pursuant to Section 54 of the Modern Slavery Act 2015 and therefore constitutes our modern slavery statement for 2023/24.

Reporting and signposting

If you suspect someone could be a victim of modern slavery, contact Isle of Wight Police on 999, 101 or through the Hampshire Constabulary website: Home | Hampshire and Isle of Wight Constabulary

Alternative contacts, available 24 hours a day, 365 days a year:

• The Modern Slavery Helpline, via 08000 121 700 or www.modernslaveryhelpline.org/report

• Crime Stoppers, via 0800 555 111 or www.crimestoppers-uk.org

• The Salvation Army’s confidential referral hotline, via 0800 808 3733 or www.salvationarmv.orq.uk/modern-slavery