Modern slavery and human trafficking statement

EXECUTIVE SUMMARY

This Statement is made pursuant to S54 of the Modern Slavery Act 2015 and sets out the steps that North West Anglia NHS Foundation Trust has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses domestic servitude, forced labour, criminal exploitation and sexual exploitation. The Trust has a zero-tolerance approach to any form of modern slavery or human trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to put effective systems and controls in place to safeguard against any form of modern slavery taking place within our business or our supply chain.

AIM OF THIS STATEMENT

The aim of this statement is to demonstrate that the Trust follows good practice, and all reasonable steps are taken to prevent slavery and human trafficking. All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking, with the Procurement department taking lead responsibility for compliance in the supply chain.

ABOUT THE ORGANISATION

The Trust is a statutory, not-for-profit, public benefit corporation and runs three main hospitals i.e. Peterborough City Hospital, Hinchingbrooke Hospital and Stamford and Rutland Hospital.

In addition, we deliver outpatient and radiology services at Doddington Hospital, the Princess of Wales Hospital in Ely and radiology services at North Cambridgeshire Hospital in Wisbech and Peterborough City Care Centre. We provide and develop healthcare according to the core NHS principles: free care, based on need and not the ability to pay.

The Trust serves a growing catchment of approximately 850,000 residents living in Cambridgeshire, Lincolnshire and the neighbouring counties of Leicestershire, Norfolk, and Bedfordshire.

The main purchasers of the Trust's services are Cambridgeshire and Peterborough Integrated Care Board and Lincolnshire Integrated Care Board. The Trust also is contracted to provide services by Leicester, Leicestershire and Rutland ICB, Bedfordshire, Luton and Milton Keynes ICB and Norfolk and Waveney ICB. Across all these areas, NHS England purchases healthcare for specialised and nationally commissioned activity such as Cancer Services, Dental and Screening Programmes, as well as healthcare for locally based Armed Forces and patients currently resident locally in His Majesty's Prison Services.

OUR STAFF

All staff are employed in line with nationally agreed pay frameworks, commencing from Band 2 which the entry point is above the National Living Wage and the National Minimum Wage.

Bank workers, agency workers or other interim workers provided by 3rd party arrangements are all paid on agreed rates either linked to national NHS pay rates or are individually agreed based on market rates. All are above the National Living Wage and National Minimum Wage.

Where individuals are employed through third party contractors based on our sites, systems and processes are in place through the Trust's procurement and contract management arrangements to ensure their employment terms comply with the law. As a Trust we encourage, rather than require, contractors who use lower paid workers to pay the National Living Wage.

We have strengthened our checks on international recruitment, including updated recruitment and selection training for recruiting managers and revised documentation checks aligned with the latest NHS Employers guidance.

Confirmation of identities of all new employees and their right to work in the United Kingdom. Employees are paid in line with best practice national guidance. The Trust's Resolution Policy and the Freedom to Speak Up, Raising Concerns in a Safe Environment Policy additionally gives a platform for our employees to raise concerns about poor working practices.

The Care Quality Commission noted a “notable rise” in referrals for modern slavery abuses across the health and care sector in 2022; double the number of referrals compared to 2021. As a Trust we take proactive steps to fully understand, identify, monitor, and mitigate against the growing risks in this area.

  • ·         The Trust does not recruit internationally for HCAs.
  • ·         For the use of HCAs agency to cover interim roles, the following governance processes are in place:

o   The Flexible Staffing team is responsible for maintaining robust arrangements;

o   Only agencies on a national framework are used which have been through the robust checks required to be added to the framework;

o   Conducts its own checks at the point of employment; and

o   Maintains oversight of how much is paid to the employee versus what the agency keeps as fees.

RAISING CONCERNS

The Trust has a Freedom to Speak Up, Raising Concerns in a Safe Environment Policy in place which incorporates the NHS England National Framework Policy for Freedom to Speak Up, which all NHS organisations and others providing NHS healthcare in primary and secondary care in England are required to adopt as a minimum standard to help normalise speaking up for the benefit of patients and staff. Its aim is to ensure all matters raised are captured and considered appropriately.

The policy also advises staff on external organisations that concerns can be raised to if they feel unable to do so internally.

Staff are encouraged to raise concerns without fear of retaliation and are also able to raise concerns anonymously.

The Trust has two full time Freedom to Speak Up Guardians to support staff with raising concerns as well as a network of Freedom to Speak Up Champions.

There is also a nominated Non-Executive Director for Speaking Up.

SAFEGUARDING AND AWARENESS TRAINING

The Trust has a specialist Think Family Safeguarding Team which supports the organisation to ensure robust safeguarding arrangements in accordance with Safeguarding Legal Frameworks, across safeguarding adults, children and maternity agendas.

Modern Day Slavery awareness is integrated into all of the Trust's Safeguarding polices and training, of which is in accordance with the Core Skills Training Framework (CSTF) and relevant Intercollegiate Guidance Documents. Awareness is also raised through safeguarding supervision, and information on the Trust intranet and Trust website. This is to ensure our staff know how to raise concerns if they suspect modern slavery or human trafficking when interacting with patients, staff or other service users.

Training on modern slavery and human trafficking is available to staff through Trust induction; further training is also undertaken as part of the Trust's mandatory Safeguarding Adults and Children training programmes, including clinical update days with further emphasis delivered within the level 3 training programmes.

The Trust delivers specific adult and children safeguarding training for all Trust Board members to ensure they possess a knowledge base equivalent to Level 1 staff; plus additional competencies related to their governance role.

As a Trust we are continuously looking at ways to increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.

Strategic approach:

The Trust's policies, procedures, governance, and legal arrangements are robust, ensuring that proper checks and due diligence are applied in employment procedures to ensure compliance with this legislation. The Trust also conforms to the NHS employment check standards within our workforce recruitment and selection practices, including through our managed service provider contract arrangements. This strategic approach incorporates analysis of the Trust's supply chains and its partners to assess risk exposure and management on modern slavery.

The Trust will continue to support the requirements of the Modern Slavery Act 2015 and any future legislation. This statement constitutes the Trust's slavery and human trafficking statement for the financial year 2025/26.

WORKING WITH SUPPLIERS

Processes are in place for identifying and mitigating risk and putting in place contractual terms to gain assurance that slavery and human trafficking have no place in our business or supply chain. The Trust works with suppliers to ensure that they treat their obligations towards modern slavery with the same importance that we do.

In order for a supplier to take part in an above threshold tender exercise (including local tenders and national Framework Agreements) a Pre-Qualification Selection Questionnaire must be completed. This addresses specific questions around the Modern Slavery Act and any breaches of labour laws which result in disqualification of unsuitable organisations.

Within our Procurement processes for above threshold tenders we include mandatory exclusion questions about complying with Section 54 of the Modern Slavery Act 2015, as detailed in the Pre-Qualification Selection Questionnaire.

For any Procurement processes below threshold, the standard Selection Questionnaire exclusion questions and standard selection questions can be used as a guide in developing appropriate and proportionate questions as part of a one-stage procurement process. In below threshold procurements questions assessment of the suitability, capability, legal status, and financial standing of a potential supplier, the questions are relevant and proportionate.

For works contracts valued between the supplies and services threshold and the works threshold we use a two-stage process and make use of the Pre-Qualification Questionnaire (PQQ) where appropriate.

·         The PQQ includes mandatory questions relating to eradicating modern slavery in supply chains, complying with environmental obligations, meeting social value and ensuring any contractors and suppliers are financially secure.

·         For works contracts we often utilise national Dynamic Purchasing Systems, for suppliers to qualify to be listed they must complete the mandatory requirements of the PQQ.

The standard Selection Questionnaire asks potential suppliers to initially self-declare their status against the exclusion grounds and selection questions. Usually, we will only check the status of the winning supplier. This reduces the burden on unsuccessful suppliers and on organisations providing evidence for those checks and aligns with the process required in the Public Contracts Regulations 2015 for the European single procurement document (ESPD).

If a potential supplier, or any organisation they rely on to meet the selection criteria has breached any of the exclusion grounds, they have the opportunity to explain how and what action they have taken to rectify the situation.

The Procurement team are able to ask any potential supplier at any time during the procurement to submit all or part of the evidence if it is necessary to ensure the proper conduct of the procedure.

As part of the NHS Net Zero commitment outlined in the 2020 “Delivering a 'Net Zero' National Health Service” report, NHS England published the NHS Supplier Roadmap. As part of the roadmap, a Sustainable Supplier Assessment (also known as The Evergreen Supplier Assessment) was launched in 2023 to enable suppliers to benchmark their progress against the roadmap.

The Evergreen Sustainable Supplier Assessment is a self-assessment and reporting tool for suppliers to share sustainability information with the NHS, providing a single route for information and data sharing between suppliers and the NHS.

After completing the assessment, suppliers receive a sustainability maturity score against NHS priorities, which signposts their current position and pathway to progress.

Suppliers will perform an annual self-assessment, which will also include modern slavery requirements. Requirements of suppliers include, but are not limited to, publication of an ethical sourcing policy, completion of a supply chain risk assessment and modern slavery audits in supply chain hotspots identified through risk assessments.

The Trust has adopted central government's Social Value Model (Procurement Policy Note 06/20), which requires a minimum 10% weighting in all procurements dedicated to Net Zero and Social Value, including the elimination of modern slavery, as of 1 April 2022. Examples of other questions include the supplier's approach to diversity and inclusion, employment standards and ethical leadership.

Any Social Value commitments made by successful suppliers can then reflected in the Contract terms.

The majority of the Trust's Procurement team holds membership of the Chartered Institute of Procurement and Supply (CIPS) and comply with their Code of Professional Conduct.

The Pharmacy Service purchases medicines that have been procured through the NHS Commercial Medicines Unit. This NHS body complies with the Trust's Modern Day Slavery statement. Outside of these contractual arrangements the Trust also purchases some small volumes of medicines from specialist suppliers and wholesalers. Each of these companies are subject to the Medicines and Healthcare Products Regulatory Agency oversight and licensing and are therefore also compliant with the Trust statement.

REVIEW OF EFFECTIVENESS

In 2024/2025, 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 2025/2026, our anti-slavery programme will include:

  • As part of our compliance to relevant safeguarding legislation, policy and practice we shall continue to deliver robust think family safeguarding training to all staff across the Trust, promoting learning and robust case management around anti-slavery and human trafficking
  • continue to effectively monitor our contracts and supply chain to ensure that new and existing suppliers are compliant with the Modern Slavery Act 2015
  • continue to have robust recruitment systems and processes in place including for overseas recruitment and temporary workers
  • continue to strengthen our Freedom to Speak Up processes to ensure all staff feel confident and safe to raise concerns
  • continue to deliver safeguarding training mapped to each staff member's role along with ongoing support for all staff, and
  • implement any new guidance or best practice to further mitigate any risks relating to modern slavery and human trafficking

BOARD APPROVAL

The Board has considered and approved this statement and will continue to support the requirements of the legislation.