Modern Slavery & Human Trafficking Statement

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 Salisbury NHS Foundation Trust (SFT) 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 and the next financial year. 

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.  SFT 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, 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. 

Our Commitment 

We are fully aware of the responsibilities we bear towards our service users, staff and local communities. We aim to follow good practice and take all reasonable steps to prevent slavery and human trafficking. 

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 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 and, in so far as possible, require our suppliers to hold similar ethos.   

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 slavery and human trafficking, and management are expected to act upon them in accordance with our policies and procedures. We have provided our staff access to advice, support and resources 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. 

We adhere to the National NHS Employment Checks/Standards this includes right to work in the UK, employees’ UK address and factual references. 

Due Diligence 

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/Staff-side 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 into. 

• Have a standards of business conduct policy which explains the way we behave as an organisation and about how we expect our staff and suppliers to act. 

Our approach to procurement and our supply chain includes:  

• Working with NHS Supply Chain and other partners to ensuring that our suppliers are carefully selected through our robust supplier selection criteria and processes 

• Ensuring a human rights issue clause as related in the NHS Terms and Conditions for goods and services 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 consideration and weighting is given in ethical sourcing and social value is in the process 

• Using the NHS Terms and conditions of contract ensuring that appropriate clauses are contained within the contract agreements with suppliers for goods and services. 

• Encourage suppliers and contractors to take their own action and understand their obligations in their processes 

• Uphold professional codes of conduct and practice relating to procurement and supply. 

• Trust staff must contact and work with the Procurement department when looking to work with new suppliers so appropriate checks can be undertaken and adhere to the Trust procurement policy and other relevant policies. 

Policies  

Our policies and procedures are devised to reflect we take all reasonable steps to achieve these commitments as part of our due diligence. This includes, but is not limited to, the following policies: 

• Procurement policy 

• Adult safeguarding policy 

• Safeguarding children and adults training policy 

• Serious incident requiring investigation (SI) policy 

• Overseas visitors policy 

Training 

All staff have a personal responsibility for the successful prevention of 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.  

Modern Slavery awareness training is included for all staff as part of the Trusts Level 1 Adult Safeguarding Training. 

Members of the Procurement teams who are Chartered Institute of Procurement and Supply (CIPS) qualified, or studying to become qualified, abide by the CIPS code of ethics and undertake an annually revised CIPS Ethics Test. 

During 2023/24, the procurement team will undertake the CIPS Corporate Ethics Training with all relevant staff within the Procurement & Supply Chain Department taking the annual ethics test. 

Confirmation 

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation. 

June 2023