Background and Purpose
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 a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.
The Modern Slavery Act 2015 introduced changes in UK law, which focus on increasing transparency in supply chains.
As both a local leader in commissioning health care services for the populations of Barnet, Camden, Enfield, Haringey and Islington and as an employer, North Central London Clinical Commissioning Group (the CCG) 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.
As an authorised statutory body, the CCG is the lead commissioner for health care services (including acute, community, mental health and learning disability services) across North Central London.
The Governing Body, 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 is possible to holding our suppliers to account to do likewise.
Our commitment to Prevent Slavery and Human Trafficking
Our overall approach will be governed by compliance with legislative and regulatory requirements and the maintenance and development of good practice in the fields of contracting and employment.
All of our contracting and commissioning staff have mandatory safeguarding training which includes awareness on Modern Slavery.
During 2020/21 as part of our commissioning assurance process we will request evidence via the NHS contract schedule from all our providers in regards to their plans and arrangements to prevent slavery in their activities and supply chain.
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 and Children policies, Bullying and Harassment policy, Grievance policy and Raising Concerns at Work (whistleblowing) policy provide an additional platform for our employees to raise concerns about poor and inappropriate working practices.
Our procurement approach follows the Crown Commercial Service standard. When procuring goods and services, we apply NHS Terms and Conditions (for non-clinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.
Review of effectiveness
We intend to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers. In 2020/21 the CCG will commit to:
- CCG Designated Safeguarding Leads providing expert support and advice into the commissioning process and supporting multi-agency work to respond to modern slavery and human trafficking.
- Gaining assurance that all commissioned services have access to training on how to identify those who are victims of modern slavery and human trafficking. This training will include the latest information for staff to develop the skills to identify and support individuals who come into contact with health services.
- Work with NHS funded and partner organisations to ensure modern slavery and human trafficking are appropriately prioritised and feature prominently in safeguarding work plans.