Modern day slavery

We recognise our responsibility to notify the Secretary of State of suspected victims of human trafficking as introduced by Section 52 of the Modern Slavery Act 2015. We also have a responsibility under safeguarding to take a strong approach to any allegations of modern slavery and human trafficking.

We are committed to preventing slavery and human trafficking in our corporate activities and to make sure that our supply chains are free from slavery and human trafficking. This statement sets out our practices already in place at the council, and committed actions moving forward.

Definition of modern slavery

Modern slavery is human trafficking, slavery, servitude and forced labour and can include:

• Sexual exploitation
• Labour exploitation
• Forced criminality
• Organ harvesting
• Domestic servitude
• Debt bondage

Anyone can become a victim of modern slavery, with particularly vulnerable groups including:

• Unaccompanied, internally displaced children
• Children accompanied by an adult who is not their relative or legal guardian
• Young girls and women
• Former victims of modern slavery of trafficking
• Homeless individuals

Working with our partners

We work in partnership with agencies in order to combat modern slavery, including:

• Safer North Hampshire Community Safety Partnership
• Hampshire Constabulary
• Hampshire and Isle of Wight Modern Slavery Partnership

The Hampshire and Isle of Wight Modern Slavery Partnership’s main objectives include:

• To raise awareness of modern slavery
• To combat modern slavery by working in partnership
• To identify and support victims of modern slavery
• To pursue perpetrators of modern slavery

The full partnership strategy is available on the Modern Slavery Partnership website.

The Hampshire and Isle of Wight Modern Slavery Partnership provides guidance, training and best practice to partners across the county, making sure all organisations can tackle this issue.

At a local level, Safer North Hampshire work with Hampshire Constabulary to identify and manage any victims or perpetrators of modern slavery. Safer North Hampshire operate under the Crime and Disorder Act 1998 and the duty to prevent crime and disorder, which includes modern slavery and trafficking. A monthly meeting, the Vulnerabilities Operational Group tracks individuals of note as well as resulting actions.

Policies

We review our policies and procedures on an ongoing basis to make sure they remain compliant and fit for purpose. We believe that the following policies and procedures are key in meeting the requirements of the Modern Slavery Act.

Safeguarding

We are committed to safeguarding the welfare of children and vulnerable adults. We have a comprehensive Safeguarding Policy, which we expect all staff and councillors follow. As part of this:

• We carry out safeguarding training for all frontline staff every two years
• We have safeguarding champions across our departments
• We take part in multi-agency partnerships to protect and safeguard people

Recruitment

We vet all new employees to make sure they are able to confirm their identity, qualifications and are eligible to work in the United Kingdom. We follow up on references.

We safeguard agency workers by making sure the agencies that we use are reputable and have appropriate policies in place to safeguard workers.

Pay

We have a job evaluation scheme to make sure employees are paid fairly and equitably, taking into account The Equality Act 2010 and the National Joint Council for Local Government Services.

Our pay and reward policy is based on fairness, affordability, consistency, flexibility, market rates and to encourage and reward achievement.

Employee code of conduct

Our employee code of conduct makes it clear to our employees the actions and behaviours expected of them when representing the council.

Our code of conduct promotes a high standard of conduct based around honesty, accountability and respect to maintain public confidence in services that we provide. We make sure that any breaches are thoroughly investigated.

Whistleblowing

Our whistleblowing policy forms part of the council’s corporate governance arrangements to make sure that employees are confident in reporting and in the investigation of malpractice including, fraud, corruption, and unethical conduct.

Members' code of conduct

Our members' code of conduct makes clear the responsibilities of members, when interacting with residents and all members of the community. Making sure to do so in a fair manner, putting the public interest first.

Supply chains

It is a priority for us to make sure:

• We trade ethically
• We source goods and services responsibly
• We help prevent modern slavery and human trafficking throughout our supply chains

We are committed to:

• Full transparency of our supply chain
• Making sure people who provide products and services used by the council are treated fairly, and their fundamental human rights are protected and respected
• Making sure new suppliers understand our requirements before starting any work, and that existing suppliers meet these requirements

We procure goods and services from various suppliers which is governed by our procurement strategy and related terms and conditions.

We will carry out due diligence to make sure suppliers are aware of our expectation during any bid or tendering process, and again before new contracts are signed. We may request evidence of adequate modern slavery policies and procedures from any potential new suppliers, as well as existing ones. Prior to being engaged, all new suppliers will provide written confirmation of compliance with the Modern Slavery Act.

We may request that suppliers agree to our standard safeguarding contract clauses.

If we find a current supplier meets all statutory requirements, but has policies that are lacking or could be improved, we may look to work with them to improve these policies, or alternatively suggest an appropriate agency who can assist.

If we have serious concerns around a supplier's policies and the safety of those working for them, this should be immediately referred to the our senior management, as well as the Contracts Manager and a suitable escalation process followed.

We will report any violations or safety concerns to the appropriate authorities, including:

• Hampshire Constabulary
• Hampshire County Council Children/Adults Services
• The Home Office
• Hampshire and Isle of Wight Modern Slavery Partnership
• Barnardo’s
• Gangmasters and Labour Abuse Authority (GLAA)

Training

All our frontline staff are required to attend safeguarding training every two years. We require all staff to complete an annual e-learning package on safeguarding children.

All staff are also encouraged to familiarise themselves with the safeguarding policy itself and discuss any concerns with safeguarding champions.

We also encourage our councillors attend safeguarding training to help them carry out their duties both within the council, as well as when out working in the community for their constituents.

Review

This transparency statement has been approved by the Cabinet of Rushmoor Borough Council and will be reviewed and updated every three years by the Community Safety Team.

Reporting of concerns

All modern slavery concerns will be reported via the National Referral Mechanism.