Modern Slavery Statement 2021/2022
This statement is made in accordance with s.54 of the Modern Slavery Act 2015. It sets out the steps that Southend-on-Sea City Council has taken, and is continuing to take, to ensure that modern slavery and human trafficking is not taking place within our organisation, our partners, our sub-contractors or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. We have a zero tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to ensuring effective systems and controls are in place to safeguard against any form of modern slavery taking place within the organisation or supply chain.
Our business
Southend-on-Sea City Council is a unitary local authority, serving a population of 183,100 residents. We spend around £150m per year on purchasing services, supplies and works contracts to meet the delivery of services to the public. We employ around 1,800 staff to provide a huge range of services to fulfil statutory and discretionary services for residents, businesses, visitors and partners.
In addition to our responsibilities as an employer, we are committed under s.52 of the Modern Slavery Act 2015 to notify the Secretary of State of suspected victims of slavery or human trafficking. Southend-on-Sea is located on the Thames Estuary with a long coastline. As such it is close to Tilbury docks, DP World London Gateway and Harwich docks. Southend has an airport and is close to London meaning there are several transport and access routes for consideration in relation to modern slavery and human trafficking.
Our areas of focus
We deem particular areas of focus within the Council to include children and adult services, housing (including social and private sector housing), environmental health, education and licencing. Homeless people or those at risk of homelessness are at higher risk of exploitation and falling prey to modern slavery.
We recognise that other areas of focus in the city include (*but are not limited to) restaurants, car valeting services, the sex trade and affiliated establishments, the construction industry (including sub-contractors) and forced or arranged marriages.
Our policies
We review our policies and procedures on a regular basis and operates a number of internal policies to ensure we are conducting business in an ethical and transparent manner and in compliance with the Modern Slavery Act. These include:
- The Modern Slavery Guidance sets out the organisation’s stance on modern slavery and explains how employees can identify any instances of this and where they can go for help. The guidance should be read alongside Southend, Essex and Thurrock (SET) Safeguarding Adults Guidelines.
- We operate a robust ‘Safer Recruitment and Selection Policy’, including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
- The Procurement Team is responsible for ensuring all procurement activity complies with our ‘Contract Procedure Rules’ and wider ‘Public Contract Regulations 2015’.
- We operate a ‘Whistleblowing Policy’ so that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
- Our ‘Code of Conduct’ explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.
Our suppliers
Southend-on-Sea City Council operates a supplier policy and maintains a database of registered suppliers as well as a corporate contract register. We conduct financial due diligence on all suppliers before allowing them to become a contractual supplier. This may include an online search to ensure that a particular organisation has never been convicted of offences relating to modern slavery (and on-site audits which include a review of working conditions). Our anti-slavery policy forms part of our contract with suppliers and they are required to confirm that no part of their business operations contradicts this policy.
In addition to the above, as part of our contract with suppliers, we require that they confirm to us that:
- They comply with the Modern Slavery Act 2015: Requirements under Modern Slavery Act 2015.
- They are a relevant commercial organisation as defined by section 54 ("Transparency in supply chains etc.") of the Modern Slavery Act 2015 ("the Act").
- If they answer yes to the previous question, are they compliant with the annual reporting requirements contained within section 54 of the Act 2015.
Training
Corporate Procurement provides training across the business to cover the Corporate Contract Procedure Rules (CPRs). Within the CPRs are ethical procurement requirements that link to the procurement process which tests suppliers on their compliance with the Modern Slavery Act.
In addition, Corporate Procurement has a Contract Management Framework in place and is in the process of finalising the building and testing of a corporate electronic contract management system which will be key to ensuring suppliers are monitored by contract managers in terms of compliance and regular reminders are made to suppliers to provide evidence as to how they are operating their contracts. A number of advisors within the Corporate Procurement Team have completed specific training around Modern Slavery as this is an element of formal CIPS qualifications.
Council representatives across all service areas continue to attend refreshers, ad-hoc training, events and conferences hosted by partner or external organisations as well as national and regional anti-slavery groups. This includes Council representation at the National Network Coordinators’ Forum (NNCF) and Eastern Region Anti-Slavery Partnership (ERASP).
Over the past year, the Council and the Southend Against Modern Slavery (SAMS) Partnership jointly facilitated Modern Slavery and Human Trafficking training and awareness raising to a wide range of statutory and non-statutory organisations. To date, this has included three sessions to frontline workers in July 2020 and one session to Essex University social work students in November 2020.
In addition, bespoke training packages were developed and delivered to Southend City Council social work placement students, housing officers, social landlords and third sector organisations, comprising of six sessions in January and February 2021 and two sessions to frontline medical professionals in March and April 2021. In total, training and awareness raising sessions were delivered to over 350 delegates.
We worked with key partners to promote a social media campaign for 18 October 2020 Anti-Slavery Day, with active participation from Essex Police, the SAMS Partnership, elected members and Regulatory Services to raise awareness and signpost to support services.
Next steps
We will further embed the importance of the Modern Slavery Act into our business and supply chain procedures, ensuring that our activities and that of our suppliers are committed to complying with the requirements of the Act. We will continue to monitor and audit our policies and procedures to make amendments and update staff where necessary.
We continue to work with and support the activities of the SAMS Partnership, an organisation which identifies and partners with key community stakeholders, mobilises communities and raises awareness of modern slavery and human trafficking in the community.
To ensure the city is protected from violence and criminal behaviour, we continue to combine the efforts of strategic partnership boards; (Southend Safeguarding Partnership / Health and Well-Being Board / Community Safety Partnership) through the ‘Violence and Vulnerability Group’ that draws on the Boards expertise, knowledge and spheres of influence, one that reflects our determination to keep Southend-on-Sea safe and thriving.
We also commit to:
- Deliver a programme of training and awareness raising for the workforce, partner agencies and third sector organisations.
- Promoting national campaigns to help raise awareness of modern slavery and human trafficking.
- Reviewing, and refreshing where applicable, the adult safeguarding referral pathway to better identify and support potential victims of modern slavery and human trafficking.
- Enhance data and intelligence gathering across partners to help identity and support potential victims, as well as inform disruption activities.
This statement is made under section 54(1) of the Modern Slavery Act 2015 for the financial year ending 31 March 2022.
Approval for this statement
This statement was approved by
Councillor Ian Gilbert, Leader of the Council
Alison Griffin, Chief Executive, Southend-on-Sea City Council