1. Introduction
1.1 This statement sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business or our supply chains. This statement relates to actions and activities during the financial year 1 April 2023 to 31 March 2024.
1.2 As part of Local Government, both as an employer and purchaser of a wide range of goods’, services and works, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. In addition to our responsibility as an employer, we also acknowledge we have a duty as a Council to notify the Secretary of State of suspected victims of slavery or human trafficking as introduced by section 52 of the Modern Slavery Act 2015.
1.3 The council is absolutely committed to preventing slavery and human trafficking in our corporate activities and to ensure that our supply chains are also free from slavery and human trafficking in line with Clause 54 of the 2015 Modern Slavery Act and subsequent government guidance and best practice.
2. Modern Slavery Act 2015
Read the Modern Slavery Act 2015.
3. Our organisation’s structure, our business and our supply chains
3.1 The council is a local authority, which provides a wide range of statutory and discretionary services for its residents, businesses, visitors and partners. The council only operates within the United Kingdom. Whilst the risk of slavery and human trafficking within our organisation and supply chains is considered low; we remain vigilant and will manage any risks presented.
From an organisational perspective, it is recognised that modern slavery is a crime that is prevalent within the UK, across many industries and as such, it is a risk that the council takes seriously. However, rather than this risk being looked at in isolation, modern slavery is managed alongside a range of other risks that must be dealt with as part of our business activities, for example, implementing responsible procurement and contracting, safeguarding of children and vulnerable adults, health and safety and more.
There is no typical victim of modern slavery. Victims are men, women and children of all ages, ethnicities and nationalities and cut across the population. However, it is normally more prevalent among the most vulnerable or within minority or socially excluded groups.
We have determined that there are no areas of our business that are considered to be at high risk of slavery or human trafficking. However, the kinds of situations where people could be in forms of modern slavery include forced labour, deception or abuse of vulnerability for the purpose of exploitation may include:
- men or women held in domestic servitude who never goes out and perhaps shows signs of physical abuse
- men or women working in fields, for example, fruit picking and living in caravans or substandard housing
- men or women working in small groups on casual manual labour such as block paving and tarmacking
- women working in pop-up brothels, often in small residential dwellings that regularly move around
- pop-up car washes
- nail bars
- men and women working in social care settings
Where people may be subject to sexual or domestic exploitation or abuse, forced to work long hours for little or no pay in poor conditions under verbal or physical threats of violence to them or their families or subject to criminal exploitation.
Risks specific to North Yorkshire have been identified as follows:
- criminal exploitation with links to County Lines - drug transportation across county borders - which for adults may include the cuckooing of their addresses and children being targeted and utilised to run drugs for adult dealers
- car hand wash stations
- nail bars
- restaurants and takeaways
- food processing warehouses
- online sexual exploitation of children
- social care settings
These risks are key priorities for multi-agency safeguarding children, adults and community partnerships. Please see section 6 below.
3.2 Our structure is shown on our website here.
North Yorkshire is a place with a strong economy and a commitment to sustainable growth that enables our citizens to fulfil their ambitions and aspirations. The overall population is expected to increase from 618,100 in 2019 to 651,804 by 2043. Within this increase, the population is projected to become substantially more aged.
3.3 The Council Plan details how we intend to adapt to meet the challenges up until 2027. It sets out our vision and values and describes a three-pronged approach - to provide leadership, enable individuals, families and communities to do the best for themselves, and to ensure the delivery of our own high-quality services.
The plan identifies five ambitions centred around delivering our vision of building on North Yorkshires natural capital, strong economy and resilient communities, to improve the way local services are delivered to support a good quality of life for all.
- place and environment
- economy
- health and wellbeing
- people
- organisation
The plan describes how the council needs to continue to change, details some of our recent achievements and sets out our priorities for action for the next year. It also details where our funding comes from and what it is spent on.
3.4 Our organisation
The council protects our own employees from becoming victims of modern slavery, through fair and robust recruitment practices, pay and conditions, and having support mechanisms in place such as access to whistleblowing, and an employee assistance programme.
Our regulatory services and corporate partnerships with other public sector community safety organisations, enables us to share and act upon intelligence to prevent, reduce and successfully prosecute criminal activity whilst providing support to those effected by labour exploitation in our communities.
3.5 Our supply chains
Procurement at the council is a centralised function and spends around £650m with approximately 5,000 suppliers each year. All spending figures relate to the period 1 April 2023 to 31 March 2024 and 297 suppliers are uncategorised. Our procurement activity is focused around three main categories of spend:
- people
- place
- professional services
People
The people procurement team includes contracts for older people, adults with disabilities, mental health service, education, children and families and public health.
Place
The place procurement team is focused on highways and major schemes, waste, energy construction and schools.
Professional
The professional procurement team includes contracts for finance, technology, insurances, integrated passenger transport and food.
The procurement and contract management service takes the lead on tackling modern slavery in our supply chains, although there is recognition that responsibility and effort permeates and extends throughout the organisation, particularly in those areas more susceptible to modern slavery.
Our procurement activity complies with the council's procurement and contract procedure rules, the wider Public Contract Regulations 2015 and the Modern Slavery Act 2015.
Our category management approach helps identify at risk markets and supply chains.
To comply with the Modern Slavery Act 2015, we:
- ensure our professional and technical ability tender questions within the procurement sourcing process require a bidder to evidence their compliance with the Modern Slavery Act if they are a relevant commercial organisation as defined by Section 54 of the Modern Slavery Act 2015. Any bidder who fails to evidence their compliance with the required legislation shall be excluded from participating further in the tender process
- bidders who have been convicted of certain modern slavery offences under the Modern Slavery Act within the last 5 years must be excluded from our procurements, unless they can demonstrate that they have taken measures to remedy the failures and prevent recurrence
- companies who bid and who have failed to meet their legal obligations in the last three years risk being excluded from public procurements, unless they can demonstrate that they have taken measures to remedy the failures and prevent recurrence
- incorporate contract term clauses that specify the supplier’s contractual obligation concerning modern slavery
- any supplier engaged by us to undertake the supply of goods, works or services is contracted to do so in line with any relevant safeguarding, equality and diversity code of conduct, and whistleblowing policies
- report any suspected or known incidents of slavery/trafficking to the relevant Police Authority, and the Public Health, which are the direct link with the Serious & Organised Crime Unit, and Modern Slavery Partnership for York & North Yorkshire. Under Section 52 of the Modern Slavery Act 2015, Local Authorities are under a duty to notify the Home Office if they identify a potential victim of modern slavery
Whilst we are aware that modern slavery can occur much closer to home, some of the global sourcing activity presents the highest risk to human rights within the supply chains we use. We procure items such as stationery, arts and crafts, sport and early years products through our Public Sector Buying Organisation, Yorkshire Purchasing Organisation. Some of these items are sourced direct from overseas suppliers with a number of products classified as globally sourced from factories across China, Taiwan and Thailand. Yorkshire Purchasing Organisation have put in place a robust procurement and audit process. Ethical audits to the Ethical Trade Initiative Base Code as a minimum are requested as part of the tender process and Yorkshire Purchasing Organisation request factories are re-audited at least every three years.
Within our procurement and contract management team, we already have many staff who hold or are working towards a professional qualification from the Charted Institute of Procurement & Supply. The Charted Institute of Procurement & Supply have a wide range of eLearning modules available for members including the Ethical Procurement and Supply which we encourage all staff to complete. This training covers three topics:
- environmental procurement
- fraud, bribery and corruption
- human rights
This eLearning raises awareness of how more sustainable and ethical outcomes can be achieved through ethical procurement. Internal training and guidance are provided to staff who are responsible for sourcing around working with the Modern Slavery Act. The council is also committed to raising awareness by collaborating with similar organisations to discuss issues relating to modern slavery.
As we move into 2024-25, we are very aware of a number of our supply chains struggling with recruitment and retention and the risk that this poses to the continued safe delivery of services, plus a potentially heighted risk in supply chains due to this scarcity of labour.
A significant area of spend for the council is in relation to Adults Social Care, spending approximately £229m net in 2023-2024. With an aging population demand for these services is increasing. There is a growing concern about modern slavery within this sector across the UK. The Homecare Association which represents domically care providers has reported a rise in new companies registering as Care Quality Commission and concerns linked to the exploitation of workers.
The Care Quality Commission has also spoken out about modern slavery now being a feature of the UKs social care market.
Acknowledging the potential exploration of this area, the council has taken steps to improve our due diligence and support the market including:
- understanding if any of the workforce is international as part of our onboarding conversations to the councils Approved Provider List
- as part of the annual contract review with Providers, we seek assurance around understanding the international workforce and associated sponsorship
- undertaking a review of existing terms and conditions to bolster requirements for Providers to notify the council if there is a change in Sponsorship status
- as part of the council's assurance process, Quality Assurance Officers undertake onsite visits to care settings
- utilise our wider networks across the region which includes other Local Authorities; the Local Government Association; the Independent Care Group; Health partners etc
- as part of our work with the care sector to transform services, we are keen to adopt the principles of the Ethical Care Charter, the over-riding objective of which is to establish a minimum baseline for the safety, quality and dignity of care by ensuring employment conditions which:
a) do not routinely short change people and;
b) ensure the recruitment and retention of a more stable workforce through more sustainable pay, conditions and training levels
Areas which we will be exploring further to help manage and mitigate this risk include:
- as part of the Yorkshire and Humber Strategic Procurement Group, a modern slavery benchmarking tool has been designed to support the Yorkshire and Humber councils in assessing their organisation in relation to other partner councils. By adopting a data-driven approach, we aim to identify prevailing issues, assess the effectiveness of existing anti-slavery measures, and ultimately foster collaboration among councils. This will allow SPG partners to conduct a desktop exercise with the intention of collectively implementing best practice
- The Modern Slavery Assessment Tool. The Modern Slavery Assessment Tool is a modern slavery risk identification and management tool. It has been designed to help public sector organisations work in partnership with suppliers to improve protections and reduce the risk of exploitation of workers in our supply chains. It also aims to help public sector organisations understand where there may be risks of modern slavery in the supply chains of goods and services we have procured. The tool asks suppliers questions about the processes they have in place for managing modern slavery risks and provides automated recommendations on how to improve their anti-modern slavery processes
- investigate how we can utilise the Walk Free Global Slavery Index to identify countries that use child and forced labour to produce goods and services to help inform our at-risk supply chains
- establish a cross organisational Modern Slavery Board to ensure a consistent approach to training and development for our employees and understand what support we can provide to our supply chains to raise awareness. The Board will also be responsible for delivery of the councils action plan
4. Our policies in relation to slavery and human trafficking
We review our policies and procedures on an ongoing basis to ensure they remain compliant and fit for purpose. The following policies and procedures are considered to be key in meeting the requirements of the Modern Slavery Act 2015.
4.1 Safeguarding
We embrace our responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and adults at risk. We have comprehensive Safeguarding Policies which all staff and councillors are required to work within. We work within multi-agency partnerships to protect and safeguard people, in particular these key partnerships are Safeguarding Adults Board, Safeguarding Children’s Board, North Yorkshire and York Modern Slavery Partnership, Health & Wellbeing Board.
4.2 Recruitment
Our recruitment processes are transparent and reviewed regularly. They include robust procedures for vetting new employees, which ensures they are able to confirm their identities and qualifications. To comply with the Asylum, Immigration and Nationality Act 2006, all prospective employees supply evidence of their eligibility to work in the UK. References are also secured.
All managers are required to complete mandatory safer recruitment training.
4.3 Agency workers
We currently source our agency workers through one supplier. This supplier complies with the Modern Slavery Act 2015 and our employment and safeguarding policies. Our contract ensures compliance with the Act throughout the agency supply chain. For instance, we can view identification documents, references and disclosure and barring certificates for agency workers - this helps us ensure that the person introduced by the agency is the person completing the assignment and we have transparency in the payment of agencies and agency workers.
4.4 Pay
We operate a Job Evaluation Scheme to ensure that all employees are paid fairly and equitably in a nationally agreed pay framework. Equal pay is evaluated and governed by the Corporate Pay and Reward Group in partnership with trade unions.
4.5 Employee code of conduct
Our Employee Code of Conduct makes clear to employees the actions and behaviours expected of them when representing the council. We strive to maintain the highest standards of employee conduct and ethical behaviour and breaches are investigated and appropriate action taken.
4.6 Whistleblowing
We encourage all our employees, customers and other business partners to report any concerns related to the direct activities or the supply chains of the council. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
5. Due diligence
With numerous categories of spend, we have a wide range of supply chains each with individual characteristics, covering goods, works and service-based supply chains. We therefore identify the areas of high risk to human rights and act accordingly.
Our category sourcing strategies highlight those spend areas, markets and supply chains which present the greatest risk of modern slavery abuses. These plans form the basis of our procurement approach.
The council, in its position as a member of the Yorkshire and Humber Strategic Procurement Group and the National Advisory Group for Procurement, will continue to encourage collaboration amongst local authority procurement services in the region, to share best practice and learning, seeking to improve the response of the region as a whole.
6. Staff training and learning
We have a programme of training and learning to ensure staff are well equipped to perform well within their roles. Modern Slavery training is available to all staff, it enables officers particularly in community facing roles to identify and know how to report suspected incidents of abuse and neglect, including modern slavery and trafficking.
Any manager of a service where safeguarding knowledge is required, for instance, dealing with members of the public who may have vulnerabilities, must complete statutory and mandatory training.
We also work in partnership with a wide range of agencies to prevent abuse and neglect, to detect and report occurrences and to support victims. As part of this, we ensure appropriate reference to Modern Slavery and human trafficking.
This includes our work as part of:
- North Yorkshire & York Modern Slavery Partnership
- North Yorkshire Community Safety Partnership
- our multi agency Safeguarding Children’s Board
- our multi agency Safeguarding Adults Board
- our Health and Wellbeing Board
7. Approval
This statement has been approved and it will be reviewed and updated annually.
Richard Flinton
Chief Executive
North Yorkshire Council
Cllr Carl Les
Leader of the Council
North Yorkshire Council