Modern Slavery and Human Trafficking Statement
This Modern Slavery and Human Trafficking Statement is approved by the Council's Corporate Management Team and endorsed by the Cabinet. It will be reviewed and updated as necessary and published on an annual basis.
This Statement has been approved by:
About Stockton Borough Council
Stockton Borough Council serves a growing population of 196,600 (source: ONS 2021). As a council, we provide a wide range of services to residents, both directly and through agreements with organisations who deliver on our behalf.
The Council employs over 3000 people and spends circa £200m/year on contracts and services, in order to deliver the Council Plan. Examples of services we buy include social care, cleaning, catering, refuse collections, construction, clothing, energy, vehicles, specialist consultancy support, electronic equipment, and IT software.
The Council's responsibility
The Council recognises that it has a responsibility to take a robust approach to modern slavery and human trafficking. Modern slavery is a crime resulting in an abhorrent abuse of human rights. It is constituted in the Modern Slavery Act 2015 by the offences of 'slavery, servitude and forced or compulsory labour' and 'human trafficking'.
The Council has a zero-tolerance approach to any form of modern slavery and human trafficking in any part of the business or supply chains. The Council is responsible for ensuring that any activity as an employer and service provider safeguards people from this risk. As commissioner of activity delivered on our behalf, the Council is also responsible for ensuring that suppliers and service providers can evidence that they are actively mitigating risks of modern slavery and human trafficking in their own business and supply chains.
The Council also has a duty to notify the Secretary of State of suspected victims of modern slavery and human trafficking, in accordance with Section 52 of the Modern Slavery Act 2015.
Whilst the greatest modern slavery and human trafficking risk lies within the supply chain, the Council is alert to these risks both within the organisation itself and externally within the Borough.
Our trained safeguarding officers support staff across the Council to identify and respond to safeguarding issues which may include modern slavery and human trafficking. A modern slavery pathway has been introduced by the Teeswide Adult Safeguarding Board to ensure those found in modern slavery and human trafficking are protected and supported.
Council officers within regulatory and civic enforcement roles are alert to modern slavery and human trafficking and can recognise and refer for investigation.
The Council's recruitment processes are transparent and reviewed regularly. They include procedures for vetting new employees, which ensures they can confirm their identities and qualifications, and all workers are paid directly into an appropriate personal bank account. To comply with the Immigration, Asylum and Nationality Act 2006, all prospective employees are asked to supply evidence of their eligibility to work in the UK. References are also requested and followed up.
The Council encourages its employees to report any concerns related to the direct activities or the supply chains of the Council. The Confidential Reporting Policy is designed to make it easy for employees to make disclosures, without fear of retaliation and includes issues of possible fraud, corruption, exploitation sexual or physical abuse of clients.
The Council's Equality, Diversity & Inclusion Policy includes the Council's commitment to activity that meets legal duties, outlines the Council's commitment to equal opportunities, valuing diversity and inclusion, creating a safe and inclusive working environment free from unlawful and unfair discrimination.
Our supply chains
Stockton Borough Council operates within the United Kingdom, which is considered at low risk of modern slavery and human trafficking, relative to other parts of the world. While the Council has a high level of confidence that policies and processes are in place to protect against risks of modern slavery and human trafficking in the supply chains with regards to Tier 1 suppliers, it is more difficult to be confident about links further up the supply chain. Higher risk categories identified by the procurement team include: cleaning, construction (particularly demolition, asbestos removal, groundworks, clearance/stripping work), clothing manufacture (particularly involving imported textiles), security (manned guards), domestic furniture supply and manufacture, environmental (waste management, recycling), horticultural (grounds maintenance and plant nurseries), some social care/personal services (including taxis), recruitment/agency staff provision and dry imported foods (rice, cocoa).
The Council is committed to ensuring that its suppliers adhere to the highest standards of ethics and to ensure that suppliers treat their workers with dignity and respect and in accordance with the requirements set out in employment legislation. Whilst a high proportion of suppliers have a presence within the North-East, the Council's supply chains stretch across the world.
Raw materials and components can come from sources anywhere in the world and there may be links in the supply chain which could be involved in modern slavery and human trafficking. As the customer, the Council will make clear to our suppliers, and those wishing to do business with us, that they are required to provide confirmation that they are compliant with the Modern Slavery Act 2015. They will also be required to confirm their subcontractors and suppliers comply with the act.
The Council spends around £200m each year on supplies, services and works. This large and varied supply chain is majority based in the UK, but the Council understands that supply chains for these contracts may include countries where there is a higher risk of modern slavery and human trafficking. The Council also understands that certain types of contract activity may present greater risk to employees of exploitation, so the Council plans and manages contracts in categories, enabling better identification and risk mitigation in supply chains and production methods.
The Council's Constitution includes Contract Procedure Rules. These internal regulations govern processes for the way the Council buys supplies, services and works.
The Council has a contract with an external agency for temporary/ interim staff to deploy within the Council and meet service needs. The Agency has robust procedures in place to check identity and eligibility to work, and a process to enable payment of salary directly into an appropriate personal bank account.
How we manage the modern slavery and human trafficking risk in supply chains
This council will continue to operate in a responsible manner by adhering to legal obligations prescribed by the Modern Slavery Act 2015 in its procurement activities. Stockton Borough Council will continue to:
- require all suppliers of goods and services to comply with all applicable laws, statutes, regulations [and codes], including but not limited to, the Modern Slavery Act 2015, their own anti-slavery policy (where applicable) and this Modern Slavery and Human Trafficking Statement
- requires its service providers engaged in 'regulated activity' for children and adults to have safeguarding policies, procedures and training in place and to comply with the reporting procedures in the Council's Safeguarding Policy
- challenge any abnormally low-cost tenders to ensure they do not rely upon the potential contractor practicing modern slavery and human trafficking
- publicise its Whistleblowing/ Confidential Reporting Policy for staff to report on any suspected examples of modern slavery and human trafficking
- require our contractors to adopt a Whistleblowing/Confidential Reporting Policy which enables their staff to report on any suspected examples of modern slavery and human trafficking
- refer for investigation via the National Crime Agency's national referral mechanism any of its contractors identified as a cause for concern regarding modern slavery and human trafficking
- consider ways to increase awareness within the Council, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business
- ensure those officers in the Council's Procurement Team, who are Chartered Institute of Procurement and Supply (CIPS) members, undertake specific training related to modern slavery and human trafficking in supply chains, through the CIPS online course on ethical Procurement and Supply
- build mitigation measures into the tender process and contract terms & conditions where risks are identified, which will allow for termination of the contract if these clauses are breached
- publish details of all spend over £500 for transparency purposes, showing was paid, how much and what it was for
The Council will implement the following actions during 2023 to 2024: The Council will:
- introduce a new pre-tender modern slavery and human trafficking risk assessment to ensure appropriate identification of high-risk contracts
- adopt the new Government Crown Commercial Service's standard selection questionnaire (SQ), part 3 of the SQ includes a section on the Modern Slavery Act 2015
- identify additional appropriate and proportionate activity during the tender process to ensure bidders evidence their compliance with the Modern Slavery Act 2015, this could also include asking specific questions during tender evaluation about how a bidder will manage their modern slavery and human trafficking risk
- when appropriate, include additional clauses in contract terms and conditions in relation to modern slavery and human trafficking
- when appropriate, include assessment of how modern slavery and human trafficking risks are managed by contractors via contract management
- signpost other officers not members of CIPS but whom have a responsibility for procurement to the Local government Association - Home Offices' Modern Slavery Unit and Joint Security and Resilience Centre's E-Learning training via the Government Commercial College website
- signpost other officers who may be in a position to identify modern slavery and human trafficking in the course of their work to the Teeswide Safeguarding Adults Board modern slavery and human trafficking training
- publish the National Referral Mechanism guidance on the Council's website which describes how to identify possible indicators of modern slavery and human trafficking and how to report concerns through this National Referral Mechanism (NRM)
- review this statement annually, to identify any further actions required to manage the modern slavery and human trafficking risk