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Modern Slavery Act 2015

Obligations

The UK Modern Slavery Act became law on the 26th March 2015. It aims to prevent all forms of labour exploitation, and to increase transparency of labour practices in supply chains. Under the additional clause (clause 6) added retrospectively to the Act, it also requires eligible commercial organisations (over £36m turnover per annum) to make a public statement as to the actions they have taken to detect and deal with forced labour and trafficking in their supply chains – the ‘Transparency in Supply Chains obligation’.

There is clear direction from HM Government, in the guidance issued with the Act, that eligible organisations will commit time and resources to understanding, and working to combat, the issue of slavery in its supply chain. Additional specific direction came from the then Home Secretary Teresa May that organisations must increase their supply chain accountability.

Under the Act, eligible organisations must publish an annual statement in line with their financial year end. The next mandatory publication date for LPT will be 31/3/17. All eligible organisations must have published by 30 June 2017. All eligible organisations must then publish annually.

The scope of the obligation is to state the steps the organisation has taken (or state that no steps have been taken), to detect and deal with forced labour or human trafficking in the supply chain. Whilst a non-compliance statement was deemed acceptable for the first year of publication, there is an expectation of evidenced year on year improvement in the actions carried out within the organisation to detect and deal with forced labour or human trafficking in the supply chain.

For clarity, ‘supply chain’ has a much wider implication than just the purchasing of goods and services carried out, by procurement teams. It also includes the supply chain of the carrying out of its own business.

This means, that for LPT, in addition to the purchasing of goods and services carried out by the Procurement Team and HIS, the definition includes spend incurred by pharmacy, capital schemes, purchasing cards, petty cash, healthcare expenditure, payments to statutory and other agencies, and any other goods and services purchased by LPT.

As ‘supply chain’ also includes the carrying out of its own business, HR recruitment for permanent staff, bank and agency staff, and other bought in medical and non-medical consultants falls within the scope of the Act.

What has LPT done?

LPT is developing Trust-wide fact-sheet around the Modern Slavery Act to raise awareness to highlight what it is, where information can be found, why is it important, personal responsibilities and where this is embedded in the working of the Trust.

LPT is in the process of identifying which policies require the addition of appropriate reference to the Modern Slavery Act and its requirements. These will then be submitted for scrutiny and approval.

The Trust’s e-learning module on Equality and Diversity now includes training on the awareness of human trafficking and forced labour, and provides advice on what to do if this is suspected. The module is mandatory for all new staff and refresher training, and participation can be monitored and reported on.

Due diligence – Questions have been prepared for inclusion in tender documentation for goods and services procurement, and business development healthcare services to determine eligible bidders’ compliance with the requirements of the Modern Slavery Act. Successful suppliers will be added to the Trust’s Modern Slavery Act database.

Agency Staff provision and the recruitment process have processes in place to detect and prevent the incidence of modern slavery.

LPT has established a database of Modern Slavery Act Statements published by all eligible suppliers. An eligible supplier for 2016 2017 is one where the value of business with the Trust is greater than £10,000 per annum. Based on the latest whole year data (2015–2016), of the 1,400 suppliers used, 324 were eligible. 180 of these, including local and district authorities, healthcare organisations, and higher education establishments exceeded the threshold of £36m, requiring them to publish their own statements. 56% have either published statements, or are due to publish by June 2017, the deadline stated in the act. Technically a number of these published statements are non-compliant, for example, not published on the organisation’s web-site page. LPT would expect that further guidance will be issued as compliance targets are met or not met.

During the financial year 2017/2018, a programme of validation for all suppliers will commence. Year on year validation will be carried out, as the expectation of the Act is that published statements demonstrate improvement in detection and prevention of modern slavery, and that organisations can demonstrate their own improvement in detecting and preventing incidences of modern slavery.

LPT is signed up to the Business and Human Rights Registry, which collates statements and locations by organisation. There is no obligation on organisations to publish their statements or details on this website or on any other. There are several databases in existence, but none are comprehensive.

During financial year 2017/2018, LPT plans to establish a central, shared e-filing space, which will allow all Trust activity to be monitored and audited. Measures will be developed to monitor compliance, and escalation processes will be established to highlight where slavery or human trafficking may be suspected

You can download a signed copy of this progress statement from our chief executive, Dr Peter Miller, (March 2017)

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