We fully support the government’s objectives to eradicate modern slavery and human trafficking. We are strongly committed to making sure our supply chains and business activities are free from ethical and labour standards abuses.
Current policies and initiatives
People
Our People policies are equality-impact assessed. They provide processes and procedures to make sure that our colleagues are always treated fairly. We:
- confirm the identities of all new colleagues and their right to legally work in the UK
- comply with the latest legislation on pay and employment terms and conditions, meaning we pay all colleagues at least the National Living Wage
- have employment policies and procedures that make sure we comply with the latest employment legislation, and provide guidance and advice to colleagues and managers
- are committed to creating and ensuring a non-discriminatory and respectful working environment for our colleagues, in line with our corporate social responsibilities
- have a set of values and behaviours that all staff are expected to comply with – all candidates are expected to demonstrate these attributes as part of the recruitment selection process
- have our Equality, Diversity and Inclusion, Solving Problems At Work, and Freedom to Speak Up policies which provide a platform for colleagues to raise concerns about poor working practices
- regularly review and track progress on promoting and supporting diversity and inclusion, both as an employer and service provider
- monitor trends in our Workforce data and use Equality Impact Assessments (EIA) to inform the development of people processes and the services we provide
- publish Gender Pay Gap and other workforce and pay equality data
- require all colleagues to do mandatory diversity and inclusion training and our management team have done Modern Slavery training
- require all colleagues involved in procurement and commercial activities to do CIPS Ethical Procurement and Supply training annually
NHSBSA Freedom to Speak Up policy
Our Freedom to Speak Up – Raising Concerns (Whistleblowing) policy applies to anyone who works, or has worked, for us and any organisation that provides NHSBSA services. This includes agency and temporary workers, students, and volunteers.
The policy provides a platform to raise concerns for further investigation and offers support to anyone raising concerns. The policy promotes an open, honest, and supportive culture.
Procurement and our supply chain
Over the last year, we’ve taken steps to identify, prevent and mitigate modern slavery in our procurement and supply chains. We adopted the Procurement Policy Note 05/19: ‘Tackling Modern Slavery in Government Supply Chains’ through policy, process and training and we are in the process of updating these measures in light of the new PPN relating to tackling Modern Slavery – Procurement Policy Note 02/23 – to ensure compliance.
. We achieved the CIPS Corporate Ethics Mark again on 16 January 2023, in recognition of:
- taking proactive steps to safeguard against unethical conduct in procurement and supply management
- making sure colleagues are trained in how to ethically select and manage suppliers
- adopting ethical values on sourcing and management of suppliers
- signing a Statement of Commitment to these values
Colleagues involved in procurement and commercial activities must do CIPS Ethical Procurement and Supply training annually. This helps colleagues, in relation to both existing contracts and new procurement activities, to do the following:
- identify modern slavery risks;
- manage risks effectively in supply chains and existing contracts; and
- take action when victims of modern slavery are identified.
Our procurement process includes a mandatory exclusion question about complying with Section 54 of the Modern Slavery Act 2015. We apply proportionate quality criteria to mitigate the risk of price-focused competition and to obtain detail of prospective suppliers’ working practices, policies, and procedures. Where procurements are deemed to be high risk, enhanced activities will be undertaken at SQ stage, with suppliers being asked to provide specific self-declarations for each member of their supply chain. This is to help us to assess modern slavery and human trafficking risks during the procurement process.
In line with Procurement Policy Note 06/20, we apply a minimum of 10% of the evaluation criteria to Social Value for all contract opportunities with a value of £10,000 and above and use this to address modern slavery concerns. This may include tender evaluation questions centred around a supplier’s approach to diversity and inclusion, employment standards, and ethical leadership. We make sure that any Social Value commitment made by successful suppliers are then reflected in the contract terms.
Where we identify a modern slavery risk, such as operating in a high-risk country or high-risk activities within the supply chain, we work with our suppliers to evaluate the risk. We use the Modern Slavery Assessment Tool where appropriate and develop mitigation measures which can be included in their contractual obligations.
Our standard contracts for the supply of services contain terms regarding Modern Slavery Act compliance principles. These are reviewed during our due diligence and assurance process. We also use Government framework agreements, including the Crown Commercial Service frameworks, which contain these provisions. The contracts set out the behaviours expected throughout procurement and supply chain relationships.
We include performance indicators in supplier contracts so we can monitor progress against contractual commitments. These can include Social Value and training commitments, and obligations for suppliers to conduct supply chain analysis.
We have requested suppliers under gold contracts to complete the Modern Slavey Assessment Tool (MSAT), so that we can gain a more in-depth information that that provided in suppliers’ modern slavery statements, and it is our intention to roll out MSAT to all silver suppliers in the coming 6 months. We will also be making it a requirement to complete the MSAT on any gold or high value silver procurement, giving selected suppliers a set time to complete the MSAT following appointment so that we can rely upon a contractual provision to guarantee completion of MSAT moving forwards.
Diversity and inclusion
Our Diversity and Inclusion policy recognises that we are all different and have varying needs. It demonstrates our commitment to taking equality, diversity, and inclusion into account in everything we do.
We produce an annual Diversity and Inclusion Report. This outlines strategic objectives for the coming year, reflecting not only our legal commitments but our commitment to do “good business”.
Code of Conduct for Suppliers
We expect our suppliers to adhere to the same ethical principles. Their obligations are set out in our Code of Conduct for Suppliers.
This says that all suppliers must prohibit the use of any forced, bonded, or compulsory labour. They must not engage in any practice which is inconsistent with the rights stated in the Convention on the Rights of the Child. Any young workers must be protected from any work which is hazardous or may compromise their health, wellbeing, or education.
We expect all suppliers to follow all relevant legislation relating to:
- discrimination
- recruitment
- employment
- working hours
- health and safety
- operating a safe and healthy workplace
Effectiveness and continuous improvement
We’re committed to reviewing the effectiveness of the initiatives and measures in place to identify and mitigate the risks of modern slavery and human trafficking. This will:
- ensure continuous improvement
- make us more resilient to modern slavery and human trafficking
In 2023/24, we’ll focus on enhancing our modern slavery programme and initiatives by:
- strengthening existing procurement and contract management processes to make sure that risks of modern slavery and human trafficking are assessed during selection and approval processes and throughout the contract term (in accordance with PPN 02/23 and any mandatory Common Assessment Standards introduced by the new Procurement Bill) – mitigation plans will be put in place where potential risks are identified
- continuing to make sure that suppliers evidence strong social values
- improving social value awareness and compliance across all our activities
- supporting and promoting training to colleagues and influential stakeholders in the prevention of modern slavery and human trafficking and awareness of reporting mechanisms for raising concerns
- strengthening risk identification and due diligence measures by mandating, where appropriate, suppliers to complete the Modern Slavery Assessment Tool
- continuing to benchmark our compliance with the CIPS Code of Ethics and identifying areas where measures can be enhanced and made more effective
continuing to request suppliers to complete the MSAT and widening the scope of suppliers we ask to do this.
Adoption of the statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to NHSBSA. The Board approved this statement at its meeting on 13 April 2023.