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 2019.

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.

Modern slavery and human trafficking is briefly covered within the mandatory safeguarding children and adults e-learning module. However, 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:

Recruitment policy

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.

Equal Opportunities

We have a range of controls to protect staff from poor treatment and/or exploitation, which comply with all relevant laws and regulations.

Safeguarding policies

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.

Whistleblowing policy

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:

  • Ensuring that our suppliers are carefully selected through our robust supplier selection criteria/processes
  • Requiring that the main contractor provides details of its sub-contractor(s) to enable the Trust to check their credentials
  • Randomly requesting that the main contractor provides details of its supply chain
  • Ensuring invitation to tender documents contain a clause on human rights issues and contain clauses giving the Trust the right to terminate a contract for failure to comply with labour laws
  • Requiring Trust staff to contact and work with the Procurement department when looking to work with new suppliers, so appropriate checks can be undertaken
    Ensuring supplier adherence to our values. We have zero tolerance to slavery and human trafficking and expect all our direct and indirect suppliers/contractors to follow suit
    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.