Our Modern Slavery Act Statement

NHS Midlands and Lancashire (NHS ML) believes there is no room in our society for modern slavery or human trafficking, we have a zero tolerance for modern slavery and breaches in human rights and we will ensure this is built into the processes and business practices that we, our partners, and our suppliers use.

What is modern slavery?

Slavery is a violation of a person’s human rights. It can take the form of human trafficking, forced labour, bonded labour, forced or servile marriage, descent-based slavery, and domestic slavery. A person is considered to be in modern slavery if they are:

• Forced to work through mental or physical threat
• Owned or controlled by an “employer,” usually through mental or physical abuse
• Dehumanised, treated as a commodity, or sold or bought as “property”
• Physically constrained or has restrictions placed on their freedom of movement.

The use of slavery in the production of goods and services

Typically, the products bought nowadays have passed through a long chain of producers, manufacturers, distributors, and retailers who have all participated in its production, delivery, and sale. It can therefore be difficult to certify that a product has or has not been produced using slavery. However, the way in which companies operate and manage their supply chain can affect the likelihood of slavery being a part of the final product. The Modern Slavery Act gives responsibility to companies for ensuring that no slavery has occurred, and this applies not only to the products they sell or the services they provide themselves but also to their suppliers, and their Tier 1, 2 and 3 suppliers throughout the entire supply chain.

What we are required to do

Primarily our requirements relate to section 54 of the Act “Transparency in the supply chain” Under the Act, any company with a turnover of more than £36m must produce a statement for each financial year listing the steps it is taking to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business. A statement must be published on company websites and visible to staff, suppliers, customers, and investors.

What we do

Risk Management

The majority of purchases that NHS ML make are from established frameworks, where the due diligence has already been carried out. Procurements that are carried out for larger healthcare services are done so in line with latest government requirements, guidance or best practice (i.e.  PPN notices).

NHS ML uses the NHS wide e-commerce- platform (Atamis), embedded in this is the NHS Evergreen Sustainable Supplier Assessment. This platform enables NHS suppliers to share their progress against the NHS Net Zero Supplier Roadmap and requires action on modern slavery to progress through the maturity levels of the assessment

Due diligence process

The NHS standard contracts which NHS England publishes, governs how NHS ML engages with its suppliers and require compliance with relevant legislation, including the Modern Slavery Act 2015. The NHS Standard Contract for 2024 updates to these contracts strengthen our position on Modern Slavery, extending requirements and the option to terminate for breaches of social and labour laws.

When undertaking procurement activity, NHS ML uses the government’s standard selection questionnaire, which has been built into our e-commerce system (Atamis) and includes exclusionary grounds addressing modern slavery risk.

We have adopted central government’s Social Value Model which requires a minimum 10% weighting in all procurements dedicated to net zero and social value, including the elimination of modern slavery. From April 2022, when NHS organisations adopted PPN 06/20, NHS ML has followed the specific guidance on how to apply the Social Value Model to healthcare settings.

The following questions are in line with the NHS Terms & Conditions and are included within the NHS ML tender questionnaire:

Mandatory questions:

We have produced a Supplier Code of Conduct Agreement. This supplier code of conduct is to inform all suppliers who provide goods and services to NHS ML of our ethical standards and assures our clients that our supply chain is robust.

As a supplier of goods or services to NHS any of our suppliers must comply with the code of conduct agreement which includes a strict set of ethical values and standards that we require suppliers to adhere to including:

• Laws and Ethical Standards
  • Ensure all UK workers receive minimum wage and robust immigration checks.
  • Ensure suppliers adhere to the working time directive 1998.
• Modern Slavery
• Health and Safety
• Business Continuity Planning
• Bribery
• Cyber Security
• Environment and Sustainability
• Subcontractors

Any breach of the obligations stipulated in this Supplier Code of Conduct is considered a material breach of contract by the supplier

Training

• Ethical Procurement and Sustainable Procurement training has been updated by the Chartered Institute of Purchasing and Supply (CIPS) and contains an ethical test which covers modern slavery and human trafficking. NHS ML’s Procurement team are all CIPS qualified or working towards this qualification. As such, they all abide by the CIPS code of professional conduct and have completed a CIPS ethical test which specifically covers modern slavery, this is refreshed on an annual basis.
• The Safeguarding module (Level 1) is a requirement for all employees to complete as part of their statutory and mandatory training. This Safeguarding training incorporates relevant information relating to modern slavery and provides a basic awareness. Level 2 and Level 3 safeguarding training is aligned to staff as per intercollegiate guidance and includes more detailed information on modern slavery.

The uptake of both components of these training modules are reviewed by senior management on a regular basis. 

We also have internal policies that support our commitment to eradicating modern slavery, such as:

• Supplier Code of Conduct
• Freedom to Speak Up / Whistleblowing Policy
• Safeguarding Policy
• Procurement Policy

NHS ML has been recently awarded the CIPS Corporate Ethical Mark for 2024/25. 

This shows that we have been able to demonstrate the value we place on ethical procurement and gives our suppliers, customers, potential employees and other stakeholders confidence that they are dealing with a business that is committed to ensuring its staff are trained in ethical sourcing, supplier selection and supplier management, and we have adopted ethical values in the way in which we source and manage suppliers.

Each year we will review our approach and publish an annual statement outlining the steps we are taking to tackle modern slavery.

Modern Slavery Act Statement reviewed September 2024

Signed for and on behalf of NHS Midlands and Lancashire by Janet Budd, Deputy Managing Director, NHS Midlands and Lancashire.