The purpose of this statement is to ensure that The Disabilities Trust can provide assurance that it meets the compliance requirements of the Modern Slavery Act 2015. Modern slavery encompasses slavery, human trafficking and forced labour.
The statement highlights the steps that The Trust 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 during the year ending 31 March 2020.
The Trust has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically, and with integrity and transparency, in all business dealings; putting effective systems and controls in place to safeguard against any form of modern slavery or human trafficking taking place within the business or our supply chain.
We are aware of our responsibilities towards service users’ employees and the local community and expect all suppliers to the Trust to adhere to the same ethical principles. We intend to ensure that all new suppliers sign up to our terms and conditions of contract which contain a provision to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains, and that they conduct their businesses in a manner that is consistent with the Disabilities Trust anti-slavery policy.
Risk registers are completed both locally and at Trust level to evidence any risks, measures and controls affecting service users, staff, services and the wider Trust. Risk registers are retained within the Datix system allowing joined up working and monitoring of risk.
Modern slavery and human trafficking is covered within the mandatory face to face training that all staff complete on induction, this training also includes a practical knowledge assessment on the subject and the subject is included in the safeguarding children and adults e-learning module. Further advice can be found in our safeguarding policies and procedures, and from our safeguarding leads.
We are looking at ways to continuously increase awareness within our organisation and in our supply chains to ensure a high level of understanding of the risks involved with modern slavery and human trafficking.
We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:
We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff. We have an approved framework which is audited by the recruitment team 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. Compliance documentation is further checked, prior to the commencement of employment, by the Service Managers. Spot checks are completed by the Trust’s recruitment team on a weekly basis and reports are available for audit purposes.
We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all relevant laws and regulations.
We adhere to the principles inherent within our safeguarding children and adults’ policies. These are compliant with the multiagency agreements and provide clear guidance so that our employees are aware of how they can raise safeguarding concerns about colleagues or service users, or about practices within our business or supply chain.
We operate a whistleblowing policy, and have a dedicated whistleblowing number, so that all employees 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.
Our current processes regarding procurement, and estates and property, will be reviewed and will be amended to include:
In the event that a contractor or subcontractor breaches the child labour laws or human trafficking; excluding them in accordance with Regulation 57 of the Public Contracts Regulations 2015, the Trust will cease working with them and require that the main contractor substitutes a new subcontractor.
Board approval February 2019
|Irene Sobowale||Chief Executive Officer|
|Victoria Pilkington||Director Governance and Quality Assurance|
|Sue Copstick||Clinical Director|
|Naomi Carey||Director of Human Resources|
|Ann Bygrave||Operational Director|
|Helen Giblin||Head of Nursing|
Signature on behalf of the Senior Management Team:
Director of Governance and Quality Assurance