Modern slavery statement

Updated May 2023

What is Modern Slavery?

Modern Slavery is the illegal exploitation of other people for personal or commercial gain.

Modern Slavery can take many forms, including:

• human trafficking
• forced labour
• debt bondage/bonded labour
• descent-based slavery
• slavery of children
• forced and early marriage

Spelthorne Borough Council is absolutely committed to preventing slavery and human trafficking in its activities and wholly owned companies and to ensuring that all our supply chains are free from slavery and human trafficking.

The Council is committed to complying with all our statutory duties prescribed by the Modern Slavery Act 2015 including the duty to make a notification should we suspect an individual to be a possible victim of slavery or human trafficking.

As a public sector organisation, the Council recognises that we have a responsibility to take a robust approach to slavery and human trafficking and, furthermore, we acknowledge our requirement under Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015.

The Modern Slavery Act 2015:

Modern slavery includes a range of types of exploitation, many of which occur together.

These include but are not limited to:

• sexual exploitation: This includes sexual abuse, forced prostitution and the abuse of children for the production of child abuse images/videos
• domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties
• forced labour: This can happen in various industries including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars)
• criminal exploitation: This can be understood as the exploitation of a person to commit a crime, such as pickpocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker
• other forms of exploitation include organ removal, forced begging fraud, marriage and illegal adoption

Our commitment, actions and activities

This statement sets out the Council's actions and activities which enable us to understand all potential Modern Slavery risks relating to our services (directly provided and commissioned) and to ensure no slavery or human trafficking takes place in our services or supply chains.

This statement covers the activities of the Council. That includes direct employees of the Council, agency workers engaged through the Council's managed service and services delivered on behalf of the Council by third party organisations and in their supply chains. Whilst the risk to the Council of slavery and human trafficking is considered low, the Council remains vigilant and will take all steps available to manage the risks presented.

Where the Council commissions third parties to provide services on our behalf, providers will be required to certify and sign terms and conditions which require their compliance, and that of any sub-contractor, with all applicable statutory provisions.

Policies

The Council reviews its policies and procedures on an ongoing basis to ensure they remain compliant and fit for purpose.

Procurement

View the policies. 

The Council undertakes public procurement in accordance with the Public Contract Regulations 2015, and with its own procurement policies and procedures.

Our due diligence in selecting third party providers is recognised as a key step in identifying and preventing Modern Slavery in contracted supply chains. Our Procurement Policy includes a commitment to examining supply chains, from selection (or, where necessary, exclusion) of providers through to contract monitoring

Safeguarding

The Council's Safeguarding Strategy covers recognising the possible signs of slavery in the community and sets out how the Council will safeguard and promote the welfare of children, young persons and adults at risk who come into contact with its services and activities. The policy covers how the Council should comply with the duty to notify the Secretary of State of suspected victims of slavery and human trafficking.

Recruitment

Our processes and policies are transparent and reviewed regularly. All appointments will be subject to pre-employment checks. As a minimum these will include identity, the right to work in the UK, references from previous employers and medical fitness. Some jobs require additional checks; these may include Disclosure and Barring Service (DBS), qualifications and professional registration.

Whistleblowing

The Council is committed to the highest standards of openness, probity and accountability.

Download the policy 

All employees, Elected Members, agency staff, volunteers and contractors working for the Council who are concerned about Modern Slavery in the Council can access the Council's Whistleblowing Procedure. People who raise concerns, based on a reasonable belief, under the Whistleblowing Procedure will be protected from dismissal, victimisation or detriment because they have made a disclosure.

Council employees also have the ability to utilise the Employee Assistance Programme (EAP) and one of our recognised trade unions to also report any concerns.

Due diligence processes

The Council undertakes due diligence in all aspects of its work. The Council's due diligence and reviews include:

• reinforcing adherence to the Modern Slavery Act duties by working towards incorporating these into the relevant Council policies
• taking appropriate measures in the selection of suppliers and contractors whilst ensuring T&Cs around compliance are being met
• robustly undertaking a thorough recruitment and selection process for all employees
• providing training and awareness raising for staff and partner organisations to develop understanding of modern slavery and human trafficking
• reporting quarterly on the number of referrals to the National Referral Mechanism (NRM), number of MS1/Duty to Notify and number of intelligence reports submitted for our Local Police Area (LPA)

Employee code of conduct

Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour within services and managing our supply chain.

Our Corporate Values can be read here.

Key Performance indicators (KPIs)

Spelthorne Borough Council uses the following performance indicators to measure how effective it has been to ensure that slavery and human trafficking is not taking place in any part of its business or supply chains:

• all contractors considered for any opportunities confirming their adherence to Modern Day Slavery Act (2015)
• employees made aware of Modern-Day Slavery Act 2015 and training provided as identified  
• all employees completed mandatory Safeguarding Training
• number of cases reported on its whistleblowing system and resulting action

Risk assessment and management

The Council is confident that, as an organisation, appropriate measures are being undertaken to mitigate the risk of Modern Slavery and human trafficking through close monitoring of services and supply chains.

We recognise the need to undertake further work in our operations and supply chains to ensure that our own activities do not contribute, cause or are linked to modern slavery practices. Spelthorne Borough Council is committed to tackling this problem and being transparent in our anti-slavery activities and outcomes.

Statement review

This statement was approved by the Spelthorne Borough Council's management team and will be reviewed annually.

Practical guidance

In the course of our employment with the Council, we may come across situations and people that cause us concern. This section seeks to give some practical guidance to assist with deciding if someone may have been trafficked or is the victim of modern slavery.

Victims are trafficked all over the world for little or no money - including to and within the UK. They can be forced to work in the sex trade, domestic service, forced labour, criminal activity or have their organs removed to be sold.

There is no typical victim and some victims do not understand they have been exploited and that they are entitled to help and support. Victims are often trafficked to a foreign country where they cannot speak the language, have their travel and identity documents removed and are told that if they try to attempt an escape, they or their families will be harmed.

Key indicators of trafficking include:

• is the person in possession of their own passport, identification or travel documents or are these documents in possession of someone else?
• does the person act as if they were instructed or coached by someone else? Do they allow others to speak for them when spoken to directly?
• is the person recruited for one purpose and forced to engage in some other job? Have transport costs been paid for by facilitators, whom they must pay back through working or providing services?
• does the person receive little or no payment for their work? Is someone else in control of their earnings?
• does the victim have freedom of movement? Are they dropped off and collected from work?
• is the person withdrawn or do they appear frightened?
• has the person or their family been threatened with harm if they attempt to escape?
• is the person under the impression they are bonded by debt, or in a situation of dependence?
• has the person been physically or emotionally harmed or deprived of food, water, sleep, medical care or other life necessities
• can the person freely contact friends or family? Do they have limited social interaction or contact with people outside their immediate environment?

This list is not exhaustive. Remember, a person may display a number of the trafficking indicators set out above, but they may not necessarily be a victim of trafficking. Often you will build up a picture of the person's circumstances which may indicate that something is not quite right.

If you have a suspicion, report it.

What should I do if I suspect someone is being trafficked or the victim of slavery?

In the first instance the point of contact for all modern slavery crimes should be the local police force. If you have information about modern slavery crimes - those who are committing such crimes or where victims are at risk that requires an immediate response dial 999. If you hold information that could lead to the identification, discovery and recovery of victims in the UK, you can contact the Modern Slavery Helpline 08000 121 700.

For more information visit www.unseenuk.org

Alternatively, you can make calls anonymously to Crimestoppers on 0800 555 111

Stop the Traffik have a 24-hour hotline for victims to call or to report suspected trafficking. The number is 0800 783 2589.

The Multi-Agency Safeguarding Hub (MASH) responds to initial enquiries about children, young people and adults. Monday to Friday from 9am to 5pm. If you have a concern about a child, young person or adult, please contact the Surrey MASH: Phone: 0300 470 9100 Email: mash@surreycc.gov.uk

In an emergency where you are concerned for the persons immediate safety you should call the Police on 999.