Modern Slavery and human trafficking statement
This document sets out the steps the NHS Confederation has taken and continues to take to understand and minimise the potential risk of modern slavery in its business and supply chains.
This statement is voluntary and published in line with section 54(1) of the Modern Slavery Act 2015 whereby organisations are required to produce a Modern Slavery Statement each year.
Our commitment to the principles of the Modern Slavery Act 2015
The NHS Confederation is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.
We're committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.
Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.
We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.
Our supply chain
Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains.
Our supply chains are limited, and we procure goods and services from a restricted range of UK and sometimes overseas suppliers through a thorough procurement process. Approximately 95% of our suppliers are based in in the UK and the majority of our cost base is UK based consultancy and research.
We have a small operation in Belgium delivering our international work but with limited procurement/supply chain.
Organisational Policies
The following policies support our approach to the Modern Slavery Act:
• Recruitment Policy
• Pay and Grading Policy
• Procurement and Value for Money Policy
• Anti-financial Corruption Policy
• Whistle-blowing Policy
• Safeguarding Policy
5 NHS Confederation: [Modern Slavery Statement October 2022]
• Dignity at Work Policy
Other key documents to support this area include our Equality, Diversity and Inclusion strategy, our values and behaviours, and our Standing Financial Instructions and Scheme of Delegation.
Embedding the principles
We will continue to embed the principles through:
Our People
• providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
• ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
• ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices
Our recruitment
• continuing to undertake our checks on new employees to check they are legally allowed to work in the UK
• continuing to not offer zero hour contracts
• continuing to ensure all staff are paid in line with real living wage (national and London).
Our supply chain
• ensuring that consideration of the modern slavery risks and prevention are added to NHS Confederation’s policy review process as an employer and procurer of goods and services
• making sure NHS Confederation procurement strategies and contract terms and conditions include references to modern slavery and human trafficking and providing evidence that all individuals have a right to remain and work in the UK.
• continuing to take action to embed a zero-tolerance policy towards modern slavery. We have an option to terminate contracts for any breach of social or labour laws.
