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Slavery and Human Trafficking Statement for 2018/19


Modern Slavery is the term used within the UK and is defined within the Modern Slavery Act 2015. The Act categorises offences of Slavery, Servitude and Forced or Compulsory Labour and Human Trafficking.

These crimes include holding a person in a position of slavery, servitude, forced or compulsory labour, coercing people into committing crime for others or facilitating their travel with the intention of exploiting them soon after. Individuals may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.

Although human trafficking often involves an international cross-border element, it is possible to be a victim of modern slavery within your own country. Victims may be transported a few miles within a town to be forced into jobs they do not want. It is possible to be a victim even if consent has been given to be moved.

Children cannot give consent to being exploited and therefore the element of coercion or deception does not need to be present to prove an offence.

Current policies and initiatives

As commissioners of care and statutory partners in the Bedfordshire Safeguarding Adults Board and the two Local Safeguarding Children Boards (LSCBs), BCCG plays a key role in supporting the work and strategic priorities in tackling Modern Slavery and Trafficking within Bedfordshire. To support this work, the Assistant Director of Nursing and Quality is a member of the Anti-Slavery Partnership Group, led by the Bedfordshire Police and Crime Commissioners Office.

Bedfordshire CCG fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS has to play in both combatting it, and also supporting victims. In particular, we are strongly committed to ensuring our supply chains and business activities are free from ethical and labour standards abuses.

Steps taken to date include:


·         We confirm the identities of all new employees and their right to work in the United Kingdom, and pay all our employees above the National Living Wage

·         Through a number of staff policies, including Grievance and Whistle Blowing Policy, we provide a platform for our employees to raise concerns about poor working practices

Whistleblowing in the NHS

·         We are a Prescribed Person under the Public Interest Disclosure (Prescribed Persons) Order 2014, meaning primary care staff working at GP surgeries and Localities can raise concerns about inappropriate activity with us directly. We assign any concerns for further investigation and offer support to individuals that have suffered fiscal or professional detriment as a result of whistleblowing

Procurement and our supply chain

·         Our procurement approach follows the Crown Commercial Service standard and includes a mandatory exclusion question regarding the Modern Slavery Act 2015

·         When procuring goods and services, we additionally apply NHS Terms and Conditions (for non-clinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.

Review of effectiveness

We intend to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in our supply chains.

In 2018/19, our anti-slavery programme will also work to:

·         support our staff to understand and respond to modern slavery and human trafficking, including the impact that each and every individual working in the NHS can have in keeping present and potential future victims of modern slavery and human trafficking safe

·         ensure that all CCG staff have access to formal training on modern slavery and human trafficking which will provide the latest information and the skills to deal with it

·         work with NHS commissioned and funded organisations to ensure modern slavery and human trafficking are taken seriously and features prominently in safeguarding agendas and contractual requirements


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