ßÙßÇÂþ»­

Modern Slavery Statement for the financial year ending 2024 to 2025

Contents

Introduction

ßÙßÇÂþ»­ remains committed to ensuring that public money is spent responsibly and our activities and those working on behalf of the authority are conducted in an ethical, responsible and sustainable manner.

Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 requires certain organisations to publish an annual modern slavery statement outlining the actions taken each year to tackle modern slavery risks within their operations and supply chains. While not required by the transparency provision to publish a statement, ßÙßÇÂþ»­ recognises the important role the public sector must play in helping to address this critical issue and has voluntarily chosen to report on our activities.

This is the Council’s 2024 to 2025 statement. The structure and content of the statement remains the same as our previous statement, with sections updated to reflect key activities undertaken during the 2024 to 2025 financial year.

As part of the Council’s Organisation Strategy for 2023 to 2028, we are committed to fostering a sustainable economy that benefits everyone, tackling health inequalities, enabling a greener future and nurturing empowered and thriving communities. Our Community Vision for ßÙßÇÂþ»­ outlines the aspirations and hopes of our residents, Council staff, businesses, universities and organisations from the public, voluntary, community and faith sectors across the county.

We aim for everyone in ßÙßÇÂþ»­ to feel safe and have access to opportunities in education, skills development and employment and appropriate care and support to help them reach their full potential. This is key to ensuring that everyone feels included in our community. We strive for ßÙßÇÂþ»­ to be a place where everyone feels at home, where our businesses prosper, effective infrastructure is in place and where the environment is clean, safe and green. Our work is underpinned by our overarching ambition to ensure that no one – both current and future generations - is left behind.

At the time of writing this statement, local government is undergoing significant changes. The Procurement Act 2023 which came into effect on 24 February 2025, established a new public procurement regime aiming to improve and simplify procurement processes and make it easier for smaller businesses to contract with public sector authorities.

Separately, discussions and plans around local government reform are set to transform the structure and responsibilities of local authorities, representing the most significant shift in local government in half a century. These developments are a pivotal moment in local governance, impacting how services are procured, delivered and managed across our communities.

Amidst these changes, ßÙßÇÂþ»­ remains committed to tackling modern slavery. With an estimated 50 million victims globally and over 100,000 in the UK, this is a grand challenge that is closely interconnected with broader global issues such as those highlighted in the United Nations’ sustainable development agenda.

The Council is dedicated to doing our part to help foster a “just transition” – that is, ensuring that vulnerable populations, including residents, communities and workers at risk of exploitative practices, are not overlooked as we pursue our net-zero future.

As a local authority, we recognise that we have several roles to play to help address the problem of modern slavery. This includes safeguarding vulnerable adults and children from exploitation and harm, identifying potential victims in our role as first responders, and working to implement measures that protect workers in our operations and supply chains from modern slavery and other unethical labour practices.

Our 2024 to 2025 modern slavery statement provides an update on all six areas recommended by Section 54 of the Modern Slavery Act 2015:

  • our organisation structure and supply chains
  • policies in relation to modern slavery
  • risk assessment
  • due diligence measures
  • how we measure our performance, and
  • training available to our staff

The Council recognises the important role the public can play in shining a light on modern slavery practices. As Section 54 of the Modern Slavery Act 2015 encourages public scrutiny of modern slavery statements, we have included information for reporting suspected or actual cases to the relevant authorities.

Due to the complex and ubiquitous nature of modern slavery, there are different people, teams and local partnerships working to address it and related concerns such as issues around vulnerability and safeguarding. Consequently, it is challenging to document all activities including training, support and correspondence.

Therefore, this statement may not fully reflect all actions taken by the authority, but it provides insight into key activities with certain sections of the document updated as necessary.

This statement has been updated to reflect the authority’s current approach and activities undertaken in the 2024 to 2025 financial year. It relates to key steps taken by the Council between 1 April 2024 and 31 March 2025.

Our organisation structure and supply chains

ßÙßÇÂþ»­ provides a range of services to over 1.2 million residents in ßÙßÇÂþ»­ including providing social care to children and the elderly, maintaining roads and providing libraries and waste management services. The Council employs approximately 8,554 staff corporately.

Our Corporate Leadership Team provides strategic direction to the whole Council which is organised into the following directorates:

  • Resources
  • People and Change
  • Adults, Wellbeing and Health Partnerships
  • Children, Families and Lifelong Learning
  • Place
  • Community Protection and Emergencies

ßÙßÇÂþ»­ have a shared procurement service with Brighton and Hove City Council and East Sussex County Council. Our partnership helps to deliver lean procurement support, shared learning to achieve excellent outcomes and shared resource for the delivery of value for money for our residents. Collectively, we comprise of one of the largest public procurement spends in local government, with an expenditure circa £2 billion a year with external suppliers across the three local authorities. As we deliver a significant amount of our projects annually via our shared procurement service, its contribution to our anti-slavery in supply chain activities is vital. Accordingly, this work is driven by our procurement service for the benefit of the three authorities and our supply chains.

Beyond work undertaken in our procurement service to mitigate modern slavery risks in our supply chains, the Council also has people and teams across the authorities working on addressing related concerns such as issues connected to abuse, vulnerability, safeguarding, and community and partnership.

During the 2024 to 2025 financial year the Council spent approximately £1,296m with 6,498 suppliers.

  • Education, health and social care: £699m
  • Assets and infrastructure: £442m
  • Corporate and Business: £156m

Policies in relation to slavery and human trafficking

ßÙßÇÂþ»­ recognises the importance of policies to communicate our commitments and expectations of our staff, suppliers, and those who we do business with, to effectively address modern slavery. We also recognise that modern slavery sits on the extreme end of the labour exploitation continuum.

Therefore, we have several policies, procedures, and codes of conduct with respect to abuse, fair labour and employment conditions that work to prevent and respond to a range of issues, including modern slavery, in our operations and supply chains. This includes whistleblowing, recruitment, health and safety, and grievance policies. Details of key policies and their relevance to modern slavery can be found in the Annex.

In July 2024, our procurement service published a revised Supplier Code of Conduct. The Code of Conduct outlines the Council’s expectations of suppliers with regards to ethical conduct when bidding for and delivering contracts. Our Code is centred around three key principles: people, planet and public service.

These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly and maintain high standards of integrity and professionalism in their business dealings. Under our “People” principle, we affirm our commitment and expectation for supply chain partners to respect and uphold labour and human rights.

We expect all suppliers to adhere to the principles outlined in the Code and where specific risks or opportunities are identified, we elaborate on relevant aspects of the Code in procurement and contract management activity. In June 2024, training session on the Code was delivered to the procurement team to increase their awareness of it and its implementation.

In our last statement, we set a performance measurement to review a sample of projects to ensure that the Code was being implemented to tackle modern slavery in high-risk projects. However, this has been removed as the Code is communicated in all procurements, regardless of modern slavery risk.

However, in cases where specific risks and opportunities related to modern slavery are identified in a project, further due diligence measures are implemented in addition to the general application of the Code (see section on due diligence). As part of our broader procurement policy efforts, our procurement policy team will routinely review projects to ensure that the Code is communicated to all suppliers and that they are committed to adhering to its principles.

Risk assessment

As a public sector body, we recognise the risk of modern slavery facing vulnerable people and service-users in our community, as well as workers in the supply chains supporting our activities. We also acknowledge that modern slavery is an issue that is prevalent in the UK.

While we have an ambition to work with local supply chains, the risk of slavery still exists as the unfortunate reality is that no supply chain is entirely free of modern slavery or unethical labour practices.

Modern slavery can take place at any stage of a supply chain, from the extraction of raw materials to the delivery and use of a final product while people delivering and receiving services can be subjected to exploitative practices by perpetrators internal and/or external to an organisation.

To aid our understanding of risks and inform our due diligence approach, we regularly consult and communicate up-to-date information on high-risk goods and services within the UK and beyond. Regarding modern slavery concerns in services we provide and the communities we serve, we recognise vulnerable service-users including children, young people, and vulnerable adults.

Within our supply chains, we recognise risks in our third party spend in high-risk areas such as adults social care, construction, and facilities management but acknowledge that the Council's exposure to modern slavery issues is likely much greater due to the extent and nature of our activities.

The risk of modern slavery in our procurement activity and supply chains is reviewed at a category and project level. Procurement officers are encouraged to flag projects that fall within our prioritised categories with regular guidance issued by our Senior Policy Lead on Modern Slavery (SPL-MS), based in the procurement team on mitigating potential risks.

Our SPL-MS also has visibility of projects and directly supports the embedding of modern slavery requirements in those where policy-related risks or opportunities have been identified. This means that we can ensure that modern slavery and unethical labour considerations are built into our tendering activity, identify areas to improve, and assess other key projects that fall outside our prioritised categories but nevertheless carry an element of risk in the supply chain.

In our procurement activity, we often prioritise our due diligence on projects based on risk characteristics such as industry type, the nature of the workforce (such as reliance on low skilled or agency workers), and complexity of business model and supply chain (such as sub-contracting arrangements) and opportunities to manage risks.

Due to the activities and services we undertake and deliver as a local authority, we expect the type of risks we are likely to encounter to remain consistent and unlikely to vary significantly.

Due diligence

This section of our statement reports on activities aimed at understanding and managing risks within our operations and communities and our supply chains.

Our operations and communities

The Council has numerous legal responsibilities to protect and safeguard vulnerable adults, children and young people. Under the Care Act 2014 we have a duty to safeguard adults with care and support needs. We also have a duty under child protection legislation, notably the Children Act 1989, the Children Act 2004 and the Children and Social Work Act 2017 to safeguard children and young people in need in our local area.

ßÙßÇÂþ»­ is also a first responder organisation. This means we have a responsibility to refer potential victims into the . This is the government's framework for identifying and supporting potential victims of modern slavery. Under section 52 of the Modern Slavery Act 2015, we have a statutory duty to notify the Home Office of potential victims of modern slavery that we come across.

Adults who give their consent and child victims can be referred into the NRM. Where a potential adult victim has not consented to a referral, the Council still has a duty to notify (DtN) the Home Office to support intelligence gathering.

In 2024, 19,125 potential victims of modern slavery were referred to the .

Of these, ßÙßÇÂþ»­ referred 40 potential victims into the NRM. Of the 40 potential victims, 39 were children (aged 17 and under). Two DtN referrals were also made.

With regards to adult safeguarding, Section 42 of the Care Act requires local authorities to make enquiries, or ask others to do so, if they believe an adult with care and support needs is at risk of abuse or neglect in their area and to find out what, if any, action may be needed to protect them. The Care Act 2014 includes modern slavery as a type of abuse, as well as being a serious crime, therefore, managing cases of modern slavery is closely linked to safeguarding adults procedures.

A section 42 duty is triggered when three requirements of the Care Act have been met. This is when an adult: has care and support needs, is experiencing or is at risk of abuse or neglect and, as a result of those care and support needs, is unable to protect themselves from the risk or experience of abuse or neglect.

During the 2024 to 2025 financial year, 13 safeguarding cases reported as a modern slavery concern progressed to a section 42 safeguarding enquiry. This figure only reflects the cases that have been enquired upon and is not indicative of all safeguarding concerns received by the Local Authority.

Our supply chains

During the 2024 to 2025 financial year, our shared procurement service continued to maintain the Councils’ collective efforts to combat modern slavery in our supply chains. Key due diligence work undertaken across our procurement partnership in the 2024 to 2025 financial year included:

  • Reviewed new and updated guidance published by central government to help shape our approach. This includes and on tackling modern slavery in government supply chains.
  • Reviewed the and the and requirements pertaining to modern slavery and labour market regulations, encouraging staff to complete transforming public procurement training, and review anti-slavery approach to ensure alignment.
  • Kept informed of anticipated legislative changes such as the and measures needed to support the regulations’ requirements.
  • Amended guidance to procurement team on managing modern slavery risks in tendering activity to ensure it aligns with relevant legislation and statutory guidance.
  • Attended events to keep informed of modern slavery and unethical labour practices. Examples of this include: a stakeholder webinar held by the Gangmasters and Labour Abuse Authority in January 2025; care sector training held by the Modern Slavery and Organised Immigration Crime Unit in October 2024; a procurement roundtable on tackling modern slavery and ESG (Environmental, Social and Governance) in supply chains hosted by risk management experts in September 2024; and a case study webinar of construction companies experience tackling modern slavery in their supply chains hosted by the Supply Chain Sustainability School in May 2024. These sessions, along with our participation in networks such as the Local Government Association’s Modern Slavery Network, kept us informed about modern slavery issues, approaches to tackling them, and insights to help shape our training, guidance and engagement with different stakeholders.
  • Revised our Procurement Report template to include modern slavery to ensure that policy considerations, where relevant, are taken into account in procurement activity and strategy.
  • Monitored procurement activity to identify and prioritise projects that are at-risk of modern slavery and unethical labour practices and putting measures in place to mitigate these. This includes incorporating relevant considerations in specification requirements, award criteria, and contract terms and conditions. With the authority procuring hundreds of projects, different methods have been used to identify potential high-risk projects. This includes having procurement officers complete an initial triage of projects and also having our policy lead monitor and prioritise projects in our procurement forward plan.
  • Included in our new Procurement Specific Questionnaire a question for relevant suppliers to submit compliant modern slavery statements.
  • Elaborated our commitment to addressing modern slavery and promoting decent working practices, as outlined in our Supplier Code of Conduct which was revised and launched 1 July 2024. We have included commitments to the Supplier Code of Conduct in our tender materials, including in Request for Quotations for below threshold procurements.
  • Reviewed spending outside procurement such as purchase cards and ad hoc spends to understand where risks may lie and whether practical due diligence measures could be adopted.
  • Given the risks of modern slavery and labour exploitation in the care sector, we updated guidance on our website for care providers on overseas recruitment.
  • Updated modern slavery requirements in our Procurement and Contract Standing Orders. This is particularly important for purchases that are made outside the formal procurement process such as purchase card spend.
  • Issued reminder to contract managers of suppliers' obligations in relation to Section 54 Transparency in Supply Chains of the Modern Slavery Act 2015 and to encourage suppliers to go above minimum requirements and report on the suggested areas outlined in the legislation to ensure a level playing field.
  • Reviewed sample of projects to understand if and how modern slavery considerations were embedded and areas for improvement in future projects across the partnership.
  • Worked more closely with consultants supporting procurement activity to ensure they understand our due diligence requirements and are embedding these in projects to manage risks.
  • Delivered training to staff on tackling modern slavery (see section on training).
  • Paid closer attention to framework agreements to understand if and how modern slavery was covered when the framework was established, how the framework monitors requirements and obligations and considered ways to strengthen due diligence measures in call-off contracts.
  • Published a modern slavery statement outlining activities undertaken to tackle modern slavery during the 2023 to 2024 financial year on our website and on the Government’s modern slavery registry.

Training on modern slavery available to staff

The Council continue to have the following training available to all staff on our e-learning platform.

Human Trafficking and Modern Slavery

This is a 45-minute e-learning course which offers an understanding of modern slavery and the scope of the problem in the UK. It includes information on what modern slavery is, key pieces of legislation dealing with modern slavery, spotting the signs that someone may be a victim, how to respond, and how to get potential victims help and refer them into the NRM.

Introduction to Modern Slavery in Supply Chains

This is a 60-minute e-learning course designed by the Council's Senior Policy Lead on Modern Slavery in the procurement service to help staff in supply chain management roles understand the unique issue of modern slavery in supply chains. It includes information on key findings of the Global Slavery Index 2022 in relation to forced labour in supply chains, the current legislative landscape, the International Labour Organization's Indicators of Forced Labour, high-risk sectors for forced labour, examples of cases within the UK and public sector responsibility for addressing modern slavery risks within our supply chains. This training was developed to ensure consistency in training received for staff working across Orbis Procurement partnership as well as others in operational roles.

A modern slavery session was also delivered by our SPL-MS to 133 staff in Adults, Wellbeing and Health Partnerships. The learning space session covered modern slavery and labour abuse risks in supply chains, specific risks to workers in the adult social care sector, spotting signs of exploitation and how to report concerns.

In addition to the training available above, during the 2024 to 2025 financial year, a 1-hour training session on responsible contracting was delivered to 54 procurement and contracting staff on developing appropriate contract terms and conditions – including drafting contract KPIs and quality requirements, and lessons learned from current projects that can help inform our broader due diligence approach to managing modern slavery risks.

This session was delivered by the Council’s SPL-MS. The procurement policy team also delivered a 1-hour training session to procurement staff to launch the revised Supplier Code of Conduct. The session aimed to improve staff’s understanding of the purpose of the Code of Conduct, how it should be used and what it is aiming to achieve.

Key performance indicators to measure effectiveness of steps being taken

Our general approach to tackling modern slavery, particularly within our supply chains, is heavily informed by existing research, best practices, and statutory guidance. Research on modern slavery statements often report that one of the areas organisations tend not to report on are indicators to measure effectiveness of anti-slavery efforts.

The Council therefore recognises this as an area for improvement and is working to strengthen how we measure our overall approach. As aforementioned, a challenge the Council faces with tracking actions to tackle modern slavery and consequently their effectiveness, is the number of activities and correspondence undertaken in this area by different people, teams and services across the authority, particularly those that handle concerns such as safeguarding whose work captures modern slavery issues alongside others.

The indicators below have been drawn from and inspired by external guidance and demonstrate what our organisation believes is feasible for us to monitor at this stage in our journey to managing modern slavery risks.

These indicators support our anti-slavery efforts by:

  • helping us to understand potential risks
  • ensure that we are taking action
  • understand the effectiveness of our approach
  • identify areas that require improvement.

We will monitor and report on our indicators on an annual basis in our modern slavery statements.

What are we measuring Challenges and limitations Why we are measuring it How we are measuring it 2024 to 2025
Potential cases of modern slavery Reports of potential cases of modern slavery can be made through various channels within the local authority and the process for addressing different types of concerns may differ. As a result, the number of cases that have been reported in this statement may not reflect all potential cases or concerns received by the local authority. Identifying cases not only ensures that potential victims have access to necessary support, but also gives us insight into the risks we may encounter as an authority, vulnerabilities within our community, operations, and supply chains, and our overall response to these challenges. Number of reports made through the following channels: Our whistleblowing helpline, Adult safeguarding enquiries and NRM (end of year summary 2023 statistics). Whistleblowing: 0, Adult Safeguarding (s42 enquiry): 13, NRM: 40 referrals and 2 DtN
Training of key supply chain management staff Despite the availability of Council-wide training on our e-learning platform, the authority recognises the importance of providing regular and targeted training for our staff. However, it can be challenging to mandate this type of training due to the large number of staff members who have various roles and responsibilities. Additionally, staff may have access to training (both internal and external) provided by their teams or services. As a result, the training reported may not accurately reflect all staff members who have accessed modern slavery training. Targeted training ensures that staff responsible for key aspects of service delivery are equipped with the necessary knowledge and skills to address modern slavery within their specific roles. Number of training delivered to staff and attendance. Procurement ran 1 session with 54 attendees and Adults, Health and Wellbeing staff ran 1 session with 133 attendees.
Review active high-risk projects to understand how modern slavery considerations were embedded Due to capacity limitations, it is not feasible to assess tender materials for all projects previously awarded that may present a high-risk of modern slavery. To leverage insights from current contracts to inform our handling of future high-risk projects and our overall approach to managing risks in procurement and contract management activity. Project sampling across the partnership. During the 2024 to 2025 financial year, 20 active projects across the Orbis Partnership with a total contract value of approximately £595m were reviewed by our SPL-MS
Identification of projects across the partnership that may be at high-risk for modern slavery practices. This assessment is not a confirmation of risk or the appropriate approach needed to respond. In most cases, projects may require further assessment, taking into account various factors such as the complexity of the procurement, the route to market, nature and characteristics of potential risks, and opportunities and challenges to managing these. Additionally, some projects may experience delays or changes before the procurement process even begins and anti-slavery measures may need to be considered at a later stage. Further, there is also a risk that some projects may go unflagged. Procurement officers regularly receive reminders to flag projects. To understand Orbis partner authorities’ exposure to potential modern slavery risks and opportunities to manage these. Number of projects across the partnership that have been flagged as potentially high-risk by procurement officers. At the time of drafting this statement, there are 348 projects in total that have been flagged. (As projects are at various stages of the tendering process, this figure represents the total number of projects presently in our project management system rather than by financial year.)

Reporting concerns of modern slavery

For further information on modern slavery and how to spot the signs that someone may be a victim, please see: and .

Reports of suspected or actual cases of modern slavery can be made via the following channels.

Non-emergency concerns: call the Modern Slavery Helpline on 08000 121 700 or local police on 101 (ask for their Modern Slavery Team)

Emergency, immediate danger, or threat to life situation: call 999

ßÙßÇÂþ»­ Whistleblowing: Our counter fraud initiatives and strategies

Concerns for an adult with care needs: Adult Safeguarding: 0300 470 9100

Concerns for a child with care needs: Children’s Single Point of Access: 0300 470 9100

Approval of statement

This statement has been approved by the Corporate Leadership Team on 12 August 2025. It will be reviewed and updated on an annual basis.

Signed by:

Tim Oliver, Leader of the Council. Date: 5 September 2025

Terence Herbert, Chief Executive. Date: 18 September 2025

Annex – Organisational Policies

The following lists the policy and then its relevance to tackling modern slavery.

Council Constitution

ßÙßÇÂþ»­’s Constitution sets out how the council conducts its business, how decisions are made and the procedures to be followed to make sure that these are efficient, transparent and accountable to local people. The “Procurement and Contract Standing Order” in the Constitution sets out how the Council authorises and manages spending and contracts with other organisations.

The procurement approach is relevant to tackling modern slavery as it covers issues such as: social sustainability measures to ensure that supply chain partners operate fair and ethical working practices; the requirement of procurement teams to work closely with human resources to manage direct and indirect employment arrangements (such as temporary workers, agencies, and consultants); and ensuring that relevant policies and codes of conduct are communicated to suppliers.

It also includes a specific section on modern slavery which requires Council officers to have regard to the risk of unethical labour practices in the supply chains of goods, services and works that being procured.

Whistleblowing Policy

Our whistleblowing policy enables individuals to feel confident in raising serious concerns and reassures that they will be protected from possible reprisal or victimisation.

The policy covers: all Council employees; members of the Council; those carrying out work for the Council on its premises, such as agency workers, contractors, and consultants; providers of works services and supplies, including external contractors; and those providing services under a contract with the Council in their own premises, for example, care homes.

The policy provides information on how individuals may raise concerns confidentially and how they will be dealt with. This policy is important for individuals wanting to raise concerns about modern slavery and/or related issues.

Social Value Policy

The aim of this policy, and the accompanying guidance, is to set out how ßÙßÇÂþ»­ will deliver maximum social, economic and environmental value, not only through its commissioning, procurement, and contract management activities but also through enabling wider collaboration and resource sharing between people and organisations across the county.

The policy and accompanying guidance are relevant to tackling modern slavery as they encourage commissioners to identify social issues that might be connected to a project or service. This is relevant for projects or services where the risk of poor working practices and modern slavery are high.

Officer Code of Conduct

The purpose of this Code is to help employees support the Council’s aim to provide high quality services fairly and efficiently in line with its values. The Code of Conduct, which applies to all Council employees, agency workers, contractors and their staff, outlines the expectations of the organisation in terms of the behaviour of individuals whilst working for, or on behalf of, the Council.

This is relevant to the anti-slavery agenda as the Code expects employees to behave ethically and maintain high standards of personal conduct and be aware of and act in accordance with the Council’s values and behaviours.

Health and Safety

The Council has various policies which aim to promote high standards and good practices in relation to health, safety, and welfare. This includes the Health, Safety and Wellbeing Policy which sets out the general approach to the management of health and safety and the way in which managers and employees should control risks.

These procedures are important to tackle modern slavery as victims may be at increased risk of work-related injuries due to inadequate protective equipment and health and safety measures, including appropriate training.

Working Time Regulations Policy

The Council recognises that excessive overtime beyond permitted national legal limits can contribute to forced labour practices when coupled with forms of threat. The Working Time Regulations Policy sets out the Council’s position regarding working time in line with the Working Time Regulations 1998.

This policy applies to all ßÙßÇÂþ»­’s employees who are defined in the regulations as “workers” and includes all permanent, part-time, temporary, and casual employees and relief workers employed by the Council. Managers using agency workers are expected to ensure that the limits to working time and rest break requirements are applied to these workers when they are working for the Council.

Recruitment

The Council has several recruitment policies to ensure that we have the right people with the right skills in the right place at the right time.

The policies below are relevant to the anti-slavery agenda as they cover aspects of work where vulnerable people could be taken advantage of and exploited. The Council recognises that victims of modern slavery can be exploited in legitimate jobs with legal terms of employment but exploited by others unrelated to the Council.

Therefore, the policies below are important to ensure that potential victims and vulnerabilities are identified during the resourcing and recruitment process.

Key policies include:

Resourcing policy

This covers various aspects of the resourcing process such as human resource planning, internal progression, recruitment, selection, and induction. It ensures that relevant eligibility and safeguarding checks are in place in the hiring process. This includes ensuring eligibility of successful candidates to work in the UK and confirming qualifications and experience.

Safe employment and disclosure and barring service policy

This enables the Council to fulfil its statutory obligations to perform appropriate background checks on employees and volunteers who carry out certain roles that involve working with children, young people, and vulnerable adults. This policy applies to individuals who are, or wish to be, directly engaged by the Council to carry out work duties and voluntary activities on its behalf. The policy does not cover contractors or agency workers.

Short term resourcing needs policy

The policy covers the management of temporary or short-term resourcing needs, including the use of agency workers or consultants. Managers are responsible for ensuring there is a clear business case based on the urgency of service needs, potential scarcity of skills and the impact insufficient staffing would place on the service prior to engaging a temporary worker. The Council have a managed service provider who supplies all agency workers.

The Council have set out the responsibilities for the agency as a hiring manager throughout their assignment. The policy recognises the rights of agency workers including the rights under the Agency Workers Regulations 2010 which gives agency workers the entitlement to the same or no less favourable treatment as comparable employees with respect to basic employment and working conditions, if and when they complete a qualifying period of 12 weeks in a particular job.

Equality policy

EDI in Employment Statement: In line with the Council’s ambition to ensure “no one left behind,” this statement outlines our commitment to EDI and the steps we will take to ensure a respectful and supportive environment for all employees.

This includes having inclusive staff networks to improve staff experiences within our organisation, making reasonable adjustments to ensure disabled people are not put at a substantial disadvantage compared to non-disabled people, and monitoring and evaluating our workforce diversity.

The Council recognises that certain vulnerable, marginalised, and underrepresented groups are at a higher risk of poor labour and employment practices and therefore our policies and associated guidance, such as our Ending Bullying and Harassment Policy, ensure that every member, manager, and employee have a duty to be aware of equality issues in their daily activities.

Grievance Policy and Procedure

The Grievance Policy and Procedure aims to create a working environment in which all employees can freely raise concerns and seek a resolution promptly, fairly, and informally wherever possible. Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns.

Domestic Abuse

This policy gives guidance on how to recognise domestic abuse, including honour-based abuse, how to support employees who are suffering domestic abuse and how to deal with employees who are perpetrating domestic abuse.

This policy applies to all employees on ßÙßÇÂþ»­ Pay terms and conditions of employment and those employment groups who choose to adopt ßÙßÇÂþ»­ Pay policies. It will also apply to teachers in schools where the Council is the employer of staff, and in other maintained schools who choose to adopt the policy.

The policy educates managers on signs that may indicate an underlying domestic violence issue such as a drop in performance, increased absenteeism, deliberate isolation at work and showing obvious signs of stress and nervousness. While this policy focuses specifically on domestic abuse, it is important for tackling modern slavery as cases may share similar indicators of abuse.

Trade Unions

At ßÙßÇÂþ»­ unions meet very regularly with the Council’s management to discuss a wide variety of issues and to feedback staff concerns and issues.

The Council provides information to staff on the benefits of trade union membership and information on how to join a union. The Council also has a Trade Union Recognition and Facilities Time Agreement in place with ßÙßÇÂþ»­ Trade Unions.

The agreement explains trade union recognition and representation within the Council, sets out the arrangements for the management of relations between ßÙßÇÂþ»­ and the trade unions it recognises for the purposes of collective bargaining, documents a framework for negotiation, consultation and information-sharing and sets out the facilities time that ßÙßÇÂþ»­ will provide to the unions recognised for collective bargaining purposes to enable them to represent the interests of their members who are employees of the council.

The Council recognises that trade union representation in the workplace can help reduce the risk of modern slavery by representing the interest of workers, ensuring fair working practices, supporting workers in negotiating their terms and conditions, and the resolving of grievances.

ßÙßÇÂþ»­ Safeguarding Adults Policy and Procedures

Our safeguarding adults work is an important part of our work in Adult Social Care. The aim of this policy is to set the direction for our safeguarding adults work.

It outlines the Council’s commitment to adult safeguarding including:

  • preventing harm and reduce the risk of abuse or neglect to adults with care and support needs;
  • stop abuse or neglect wherever possible;
  • safeguard adults in a way that supports them in making choices and having control about how they want to live;
  • promote an approach that concentrates on improving life for the adults concerned;
  • raise public awareness so that communities, alongside professionals, play their part in preventing, identifying and responding to abuse and neglect;
  • provide information and support in accessible ways to help people understand the different types of abuse, how to stay safe and what to do to raise a concern about the safety or well-being of an adult address what has caused the abuse or neglect.

ßÙßÇÂþ»­ Safeguarding Children Partnership Procedures Manual

These procedures contain the ßÙßÇÂþ»­ Safeguarding Children Procedures which cover the areas served by the ßÙßÇÂþ»­ Safeguarding Children Partnership. The manual reflects current legislation, government statutory guidance and expectations, and accepted best practice. It advocates a child-centred approach to ensure that the welfare of children is safeguarded and promoted.

This includes protecting: Protecting children from maltreatment; preventing impairment of children’s health and development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.

Supplier Code of Conduct

The Council believes that its supply chain plays a vital role in making a positive contribution to its communities and society. Procuring in an ethical, fair, responsible and sustainable way which allows us to work with successful bidders to align with our policy objectives is a priority.

The Council's Supplier Code of Conduct embeds these policy objectives and provides a detailed expectation of our supply chain. We expect our suppliers and their supply chains to follow three key principles which focus on people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly, maintaining high standards of integrity and professionalism in their business dealings.


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