Current policies and initiatives
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.
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, Wellbeing, and Freedom to Speak Up policies, which provide a platform for colleagues to raise concerns about poor working practices or concerns about the working environment
- 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.
We will ensure that the suppliers who we contract with either embed the principles of our “Freedom to Speak Up” policy in their own policies and procedures or enable the utilisation of reporting mechanisms contained within NHSBSA’s policy, so their employees have suitable support. to raise any modern slavery and human trafficking concerns that relate to delivery of NHSBSA services.
Procurement and our supply chain
We have continued to develop and enhance steps to identify, prevent and mitigate modern slavery in our procurement and supply chains. We have adopted the Procurement Policy Note (PPN) 05/19: ‘Tackling Modern Slavery in Government Supply Chains’ through policy, process and training and have since updated these measures in light of the PPN relating to Tackling Modern Slavery – Procurement Policy Note 02/23 – to ensure compliance.
We currently await the launch of the Modern Slavery Risk Prioritisation Tool by the Cabinet Office, and once available we will take steps to implement this tool to identify risks in procurement and supply chains.
. We achieved the CIPS Corporate Ethics Mark again on 26 February 2024, in recognition of:
- taking proactive steps to safeguard against unethical conduct and business practices in procurement and supply management
- making sure colleagues are trained in how to ethically select and manage suppliers
- adopting ethical values and procurement strategies on sourcing and ongoing management of suppliers
- ensuring a safe environment in which unethical practices can be reported and remedial actions can be agreed
- 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:
- identify modern slavery risks
- manage risks effectively in supply chains and existing contracts
- 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 in relation to compliance with legislation, adoption of processes and procedures to mitigate and continue to monitor risk. 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 (MSAT) 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 ensure suppliers under critical and high-value contracts complete the MSAT, so that we can gain a more in-depth information than that provided in suppliers’ modern slavery statements.
We are developing standard clauses to be incorporated into contracts with critical and high-value silver suppliers and where the contract has been deemed to be high-risk, to make it a requirement for suppliers to complete the MSAT and to submit the results to NHSBSA on an annual basis. For high-risk contracts, we make it an obligation of suppliers to undertake supply chain mapping, flow down anti-modern slavery and human trafficking provisions to subcontractors and put in place auditable mitigation measures, as appropriate.
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 and is central to everything we do.
Our Diversity and Inclusion Report (PDF: 818KB) outlines strategic objectives, 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 (PDF: 19KB).
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 are 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 2024/25, we will 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)
- strengthening risk identification and due diligence measures and deploying the Cabinet Office’s Modern Slavery Risk Prioritisation Tool once it becomes available
- continuing to make sure that suppliers evidence strong social values and that commitments are backed by contractual obligations and KPIs
- 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
- mandating suppliers on the most critical and high-value NHSBSA contract, and suppliers on contracts that are deemed to be high risk, to complete the Modern Slavery Assessment Tool and report results on an annual basis
- ensuring suppliers understand why the provision of supply chain and modern slavery risk information is important and how it is used by NHSBSA to promote transparency and supplier buy-in
- continuing to benchmark our compliance with the CIPS Code of Ethics and identifying areas where measures can be enhanced and made more effective
- identifying enhanced anti-Modern Slavery training to be rolled commercial colleagues and key stakeholders in directorates across NHSBSA
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 9 May 2024.