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 population of Bristol, North Somerset and South Gloucestershire and as an employer, Bristol, North Somerset and South Gloucestershire Clinical Commissioning Group (CCG) provides the following statement in respect of our commitment to, and efforts in, preventing slavery and human trafficking practices in the supply chain and employment practices.
As an authorised statutory body, Bristol, North Somerset and South Gloucestershire CCG is the lead commissioner for health care services (including acute, community, mental health and learning disability services) in the Bristol, North Somerset and South Gloucestershire area – covering a population in excess of one million.
Our commitment to Prevent Slavery and Human Trafficking
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 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 2019-21 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 procedure and Raising a Concern 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 2019-21 we will commit to:
- continuing to provide expert support and advice, via CCG Designated Safeguarding Leads, into the commissioning process and supporting multi-agency work to respond to modern slavery and human trafficking
- continuing to gain 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
- continuing to work with NHS funded and partner organisations to ensure modern slavery and human trafficking are appropriately prioritised and feature prominently in safeguarding work plans.
In the last year we have supported the development of the NHSEI Modern Slavery Incident Response Framework which provides guidance on how safeguarding colleagues and Emergency Preparedness, Resilience and Response teams can work together to ensure protocols are in place should these incidents occur.
We have also supported the local Anti-Slavery Partnership in disseminating important information about Modern Slavery, how to raise awareness and where to signpost concerns.
As we transition into an Integrated Care System, this statement will be updated in April 2022 accordingly.
Signed By Julia Ross (Chief Executive), on behalf of Bristol, North Somerset and South Gloucestershire CCG.