This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Trust’s slavery and human trafficking statement for the financial year ending 31 March 2023. The statement sets out the steps that East London NHS Foundation Trust (ELFT) has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain, or in any part of our business during the year ending 31 March 2023.
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.
ELFT has a zero tolerance approach to any form of modern slavery or human trafficking in any part of our business activity. We are committed to acting ethically and with integrity and transparency in all business dealings, and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chain.
- We are fully aware of the responsibilities we bear towards our service users, staff and local communities. Our overall approach will be governed by compliance with legislative and regulatory requirements and we aim to follow good practice and take all reasonable steps to prevent modern slavery and human trafficking
- We are committed to promoting a proactive and inclusive approach to equality in both employment and service provision which supports and encourages an inclusive culture which values diversity; this includes a commitment to building a workforce which is valued and whose diversity reflects the communities it serves, enabling the Trust to deliver the best possible healthcare services to the community
- We aim to design and provide services, implement policies and make decisions that meet the diverse needs of our service users and carers, the population we serve and our workforce ensuring that none are placed at a disadvantage
- We are guided by a strict set of ethical values in all of our business dealings and expect our suppliers to adhere to these same principles. We are committed to ensuring there is no modern slavery in any part of our business in so far as possible and require our suppliers to hold similar ethos, again in so far as possible
- We are committed to ensuring that all our staff are aware of the Modern Slavery Act 2015 and their safeguarding duty to protect and prevent any further harm and abuse when it is identified or suspected that an individual may be or is at risk of modern slavery and human trafficking.
- We ensure modern slavery guidance is embedded into the Trust safeguarding policies. Staff are expected to report concerns about modern slavery and human trafficking, and management are expected to act upon them in accordance with our policies and procedures. Guidance on modern slavery and human trafficking – what it means, what are the types and who is affected, what to do if you suspect someone of being subjected to slavery, and further advice, support and resources – can be found on the Trust’s intranet site
- We adhere to the National NHS Employment Checks/Standards this includes right to work in the UK, employees’ UK address and factual references.
Governance and policies
To identify and mitigate the risks of modern slavery and human trafficking in our business and in our supply chain, we:
- Operate a robust recruitment and selection policy, including appropriate pre-employment checks reflecting the national NHS Employment Checks/Standards requirements on directly employed staff. Agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will
- Implement a range of controls to protect staff from poor treatment and/or exploitation which comply with all respective law as and regulations; these include provision of fair pay rates, fair terms of conditions of employment and access to training and development opportunities
- Consult and negotiate with Trade Unions/Staffside on proposed changes to employment, work organisation and contractual relations
- Have systems to encourage the reporting of concerns including a whistleblowing policy so that all staff know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals; and the promotion of our Freedom to Speak Up Guardian and Ambassadors
- Regular Freedom to Speak Up reports are provided to the Trust Board which includes an overview of the concerns raised by staff and the category they fall in to
- Have a standards of business conduct policy which explains the manner in which we behave as an organisation and about how we expect our staff and suppliers to act
- All our people, procurement and commercial policies are equality impact assessed to ensure that colleagues are always treated fairly.
Working with Suppliers
Our approach to procurement and our supply chain includes:
- Ensuring that our suppliers are carefully selected through our robust supplier selection criteria and processes
- Ensuring a human rights issue clause is included in specification and tender documents with a requirement for suppliers to have suitable anti-slavery and human trafficking policies and processes in place and that they comply with the provisions of the UK Modern Slavery Act (2015)
- Evaluate specifications and tenders with appropriate weight given to modern slavery and human trafficking points
- Encouraging suppliers and contractors to take their own action and understand their obligations in their processes
- Upholding professional codes of conduct and practice relating to procurement and supply
- Trust staff must contact and work with the procurement team when looking to work with new suppliers so appropriate checks can be undertaken.
All staff have a personal responsibility for the successful prevention of modern slavery and human trafficking. Advice and training on modern slavery and human trafficking is available to staff through our safeguarding policies, procedures and training, and our safeguarding leads. Safeguarding training on identifying and supporting victims of modern slavery is mandatory for all staff via our online training system.
The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation.
27 July 2023