Modern slavery act transparency statement

Slavery and Human Trafficking Policy Statement 2023/24

1. Introduction

Modern Slavery remains a hidden blight on society.  We all have a responsibility to be alert to the risks of modern slavery, however small, in our organisation and in the wider supply chain.  Trust colleagues are expected to report concerns and our management teams are expected to act upon them.  At Oxford Health NHS Foundation Trust (OHFT) we are committed to ensuring that no modern slavery or human trafficking takes place in any part of our business or our supply chain upholding the provisions of the Modern Slavery and Human Trafficking Act 2015.

This statement sets out actions taken by OHFT to understand all potential modern slavery and human trafficking risks and to implement effective systems, controls and best practice in order take all reasonable steps to prevent slavery and human trafficking.  We expect our staff and suppliers to comply with the legislation and report any concerns where they may have them.

OHFT wishes its service users, staff, and all stakeholders to be confident in the knowledge that we operate a zero tolerance approach to modern slavery and human trafficking, and we are working as best we can to ensure that such practise does not exist anywhere in our Trust or in our supply chain.

2. 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 to take all reasonable steps to prevent slavery and human trafficking.

We are committed to promoting a proactive and inclusive approach to equality in both employment and service provision which supports and encourages an inclusive culture which values diversity. This includes a commitment to building a workforce which is valued and whose diversity reflects the communities it serves, enabling the Trust to deliver the best possible healthcare services.

OHFT is guided by a strict set of ethical values in all of its business dealings and expects its suppliers to adhere to these same principles.  The Trust is committed to ensuring there is no modern slavery in any part of the business and, in so far as possible, requires suppliers to hold the same ethos.

OHFT is also committed to ensuring that all 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.

3. About Oxford Health

OHFT provides physical, mental health, learning disability and social care for people of all ages across Oxfordshire, Buckinghamshire, Bath and North East Somerset, Swindon and Wiltshire. The Trust’s services are delivered at community bases, hospitals, clinics and in people’s homes. The Trust focuses on delivering care as close to home as possible. Further information can be found on the ‘About us’ pages of the Trust’s website.

Our supply chains enable the procurement of a wide range of goods and services on behalf of our clients and service users.

4. Our Policy on Slavery and Human Trafficking

We are fully aware of the responsibilities we bear towards our service users, employees and local communities. We are guided by a strict set of ethical values in all our business dealings and expect our suppliers (i.e. all companies we do business with) to adhere to these same principles. We have zero tolerance for slavery and human trafficking.  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.

5. Due Diligence, Risk Assessment and Management

To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain we:

• Undertake appropriate pre‐employment checks on directly employed staff and agencies on approved frameworks. Agency compliance is audited to provide assurance that pre‐employment clearance has been obtained for agency staff;
• Adhere to National NHS Employment Checks/Standards. This includes right to work in the UK, employees’ UK address and factual references;
• Implement a range of controls to protect staff from poor treatment and/or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair Terms and Conditions of employment and equitable access to training and development opportunities. We are working towards embedding an overarching just and restorative learning culture throughout the organisation which will underpin our ongoing provision of fair employment terms and conditions;
• Consult and negotiate with Trade Unions on proposed changes to contractual terms and conditions and proposals relating to organisational change, in the context of ongoing dialogue to provide a supportive work environment;
• Have systems to encourage the reporting of concerns, including a whistleblowing policy (also known as Management of Concerns) 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 Trust or supply chain, without fear of reprisals. We also make every effort to promote the role of our Freedom to Speak up Guardians and Ambassadors;
• Purchase a significant number of products through NHS Supply Chain, whose ‘Supplier Code of Conduct’ includes a provision around forced labour;
• Our purchase orders and tender specifications comply with the NHS Standard Terms and Conditions, thereby complying with the UK Modern Slavery Act (2015), all of which set out our commitment to ensuring no modern slavery or human trafficking related to our business;
• Ensuring that our suppliers are carefully selected through our robust supplier selection criteria and processes. All NHS Contracts for the Supply of Goods and Provision of Non-Clinical Services have contractual clauses requiring compliance with the Modern Slavery Act (2015);
• Include a minimum of 10% Social Value criteria evaluation in our tender documents and ensure appropriate weight is given to modern slavery and human trafficking elements;
• Ensure adherence to the Cabinet Office Procurement Police Notice for Tackling Modern Slavery in Government Supply Chains by identifying and managing risks in new and existing procurement activities.
• Uphold professional codes of conduct and practice relating to procurement and supply, including through adherence to Sustainable and Ethical Values as advocated through the Chartered Institute of Procurement and Supply and/or other appropriate professional bodies; and
• Ensure ongoing due diligence through effective contract management and by building strong working relationships with suppliers;
• Monitoring of actions put in place to review and provide assurance on their effectiveness.

6. Training and Awareness

Advice and training about modern slavery and human trafficking is available to staff through our Safeguarding Children and Adults training, our Safeguarding policies and procedures and our Safeguarding leads.

As part of our recruitment process we consider the extent to which applicants have knowledge of and skills to comply with their obligations to safeguard service users which includes Modern Slavery and Human Trafficking.  It is extremely important to Oxford Health that all employed staff are supported to recognise signs and indicators of abuse which includes concerns relating to modern slavery and human trafficking. We have a responsibility as an organisation delivering care and treatment to vulnerable children and adults and we take this duty very seriously.

The organisation monitors any modern slavery issues through our Safeguarding Service and together with partner agencies.

7. Board of Directors’ Approval

This statement has been approved by the Trust’s Board of Directors on 24 July 2024 who will continue to support the requirements of this legislation. The Board will aim to review and update it on an annual basis.

The statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Oxford Health NHS Foundation Trust’s slavery and human trafficking statement for the financial year ended 31 March 2024.