Royal Borough of Greenwich
Modern Slavery and Human Trafficking Statement 2019/20
1 Introduction
- 1.1 This statement sets out the steps that the Royal Borough of Greenwich is taking to prevent modern slavery in its supply chains and through its own business. This Statement relates to the financial year 1st April 2019 to 31st March 2020 and is pursuant to s ensure human trafficking and slavery does not occur within them or their supply chains. The Royal Borough of Greenwich also acknowledges its duty, as set out in Section 52 of the Modern Slavery Act 2015, to notify the Secretary of State of any individual encountered in England and Wales who it believes is a suspected victim of slavery or human trafficking.
- 1.2 The Royal Borough of Greenwich understands the risks that all forms of modern slavery and human trafficking pose to our residents and communities. Royal Greenwich has a zero-tolerance approach to all forms of modern slavery and is committed to using all measures it can to prevent and disrupt it, including through its role as a commissioning and procurement activity.
2 What is Modern Slavery
2.1 The Modern Slavery Act 2015 (the Act) was published in March 2015 in response to growing concerns about the treatment of individuals and groups of people whose human rights are being abused through trafficking, enforced labour and servitude.
which occur together. These include but are not limited to:
Sexual exploitation
Domestic servitude
Forced labour
Criminal exploitation
Other forms of exploitation include organ removal, forced begging, forced benefit fraud, forced marriage and illegal adoption.
2.2 Section 52 of the Act imposes a duty on public authorities to notify the Secretary of State of suspected victims of slavery or human trafficking.
Section 54 of the Act imposes a legal duty on commercial organisations, which supply goods and/or services from or to the United Kingdom and have a global turnover above £36 million, to publish a slavery and human trafficking statement each financial year.
2.3
in its approach to procurement and commissioning activity for goods, works and services. Royal Greenwich also recognises that, to stamp out all forms of modern slavery, staff need to be trained and made aware of the signs that may indicate that criminal activity is taking place.
3 Our Policies and Standards
3.1 Royal Greenwich, both as an employer and through its provision of services through external organisations, has in place a number of procedures which contribute to the elimination of modern slavery and human trafficking.
3.2
departmental structure and management team, including how services are organised and areas of responsibility can be found at here.
- 3.3 Recruitment and Remuneration: Royal Greenwich has robust recruitment processes which are compliant with UK legislation, including pre-employment checks, referencing and Disclosure and Barring Service (DBS) checks, as appropriate. This includes full or part time employees, agency employees and contractors/ consultants. The Royal Borough of Greenwich became a London Living Wage employer in 2015.
- 3.4 Employee and Councillor Codes of Conduct: These Codes of Conduct make it clear both to employees and Councillors the behaviour and actions expected of them when representing the organisation. The Council expects the highest standards of conduct and ethical behaviour in all aspects of its activities and is committed ution can be viewed in full here.
- 3.5 Whistleblowing procedure all staff to report confidentiality any concerns, including those relating to the staff to make disclosures, without fear of retaliation. Additionally, any member of staff can raise concerns through their manager, director or other designated officers.
- 3.6 Safeguarding: Royal Greenwich has in place robust procedures to safeguard the welfare of vulnerable adults and children, working within multi-agency lnerable adults can be viewed here safeguarding children can be found here.
- 3.7 Training and Awareness: there is bespoke training on Modern Slavery and Human Trafficking available to staff. Royal Greenwich understands that those who have been abused and trafficked may not feel able to disclose their situation and understands the importance of raising awareness of signs of modern slavery across all areas of service delivery.
4 Due Diligence and Procurement, Commissioning and Supply Chain
- 4.1 The Royal Borough of Greenwich spends in excess of £350m per year on external goods, works and services and these are procured from a wide variety of local, national and international organisations, businesses and voluntary sector organisations. Each supplier, in turn, may have its own supply c approach to procurement and commissioning requires suppliers of goods and services to implement due diligence procedures in relation to slavery and human trafficking with their own suppliers, subcontractors and other participants in their supply chain where their annual turnover exceeds £36 million. For organisations with a turnover below this sum, suppliers will be asked to confirm their acceptance of this Modern Slavery and Human Trafficking Statement.
- 4.2 Additionally, as part of our procurement processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
- 4.3 T
organisation satisfies minimum levels of economic and financial standing and technical and professional capability. The Standard Selection Questionnaire includes questions on safeguarding and Modern Slavery and can be viewed here. - 4.4 Royal Greenwich expects the following standards to be met through its service delivery and contractual arrangements: Through our procurement procedures, all possible steps are taken to make potential contractors aware that slavery and human trafficking should not be present in our supply chains;
4.5
That reporting mechanisms are in place through the supply chain to enable reports of suspected criminal activity to be recorded and investigated appropriately;
Ethical business and operational practices are promoted across service delivery; and
supported.
Our approach includes:
Developing a central register of all Council contracts;
Requiring potential suppliers to provide information regarding their financial stability and compliance with good practice in employment;
Disqualification, at the tendering stage, for those potential contractors who fail to meet the terms of a contract;
Invoking sanctions against contractors who fail to comply with the terms of a co
The future inclusion of the following statement in all invitation to tender for business with the Council:
with suppliers with whom it contracts are free from modern slavery and human trafficking. The Council requires all contractors with whom it does business to comply fully with the Modern Slavery Act 2015, wherever it applies, with contract termination as a potential sanction for non-
Royal Greenwich is undertaking a revision of its procurement procedures and guidance and this will include:
The requirement for managers who commission and procure services, goods and works to be conversant in ensuring, both through the tendering process and contract monitoring, that potential areas of risk of modern slavery are identified and that appropriate actions are taken;
Incorporating the requirement for contractors to fully comply with the Modern Slavery Act 2015, wherever it applies, with disqualification in place at the tendering stage and sanctions in place for non-compliance, including termination of contract;
Requiring contractors to adopt a whistle-blowing policy, enabling their staff to report suspected examples of modern slavery. This should include requiring contractors to enable their staff to be aware of the signs associated with modern slavery;
Awareness and monitoring of particular products or geographic areas that pose high risk of modern slavery and human trafficking and taking account of this in the assessment of potential suppliers;
Providing advice to suppliers and requiring them to implement action plans, where any employment practices are found to be sub-standard; and Developing communication with monitoring bodies which screen practices in large supplier organisation and their supply chains, to provide additional intelligence to support risk assessment.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Royal Borough of modern slavery and human trafficking statement for the financial year ending 31st March 2019.
