Preventing Modern Slavery within the Council and within our Supply Chains (April 2021 to March 2022).
1. Introduction
1.1 Hammersmith & Fulham Council (H&F) is committed to tackling modern slavery and exploitation (MSE) in all its forms. In 2021, we launched our inaugural Modern Slavery Strategy which was developed in collaboration with Stop the Traffik, a charity founded in 2006 as a campaigning coalition to bring an end to human trafficking worldwide. The strategy sets out our main priorities for the next 5 years (2021 to 2026) and how we will work with our partners to achieve them. Our 4 key objectives are to:
- identify victims of MSE
- prevent MSE from occurring
- support victims of MSE
- bring exploiters of MSE to justice.
1.2 As part of our objective to prevent Modern Slavery and Exploitation, the council has signed the Charter Against Modern Slavery and pledged to report on its work to tackle modern slavery in its supply chains annually in the form of a modern slavery statement.
1.3 This is an updated modern slavery statement for Hammersmith & Fulham Council which covers the period between April 2021 and March 2022.
2. What is modern slavery?
2.1 Modern slavery is complex, but simply put, describes a situation in which someone is forced or coerced into doing something which another person gains from. It is deception or coercion for the purpose of exploitation.
2.2 The Modern Slavery Act 2015 categorises modern slavery as including offences of:
- slavery
- servitude
- forced or compulsory labour
- human trafficking.
2.3 Modern Slavery is an umbrella term, encompassing several types of exploitation including:
- forced labour
- sexual exploitation
- domestic servitude
- criminal exploitation
- forced or sham marriages
- organ harvesting.
2.4 Modern slavery is a violation of human rights, and it is one of the fastest-growing crimes in the world. Though we don’t have exact figures due to the hidden nature of MSE, some estimates suggest that there are as many as 136,000 victims of modern slavery estimated to be living in the UK. Victims and survivors can be of any age, gender, or race, but they are often taken advantage of due to their vulnerability. Many victims are people who are also experiencing homelessness and or are attempting to escape conflict, poverty, and abuse.
2.5 Modern slavery is often hidden in plain sight and is happening in supply chains across the globe, including in the UK. While eradicating modern slavery from supply chains is complex and will require multi-faceted institutionalised change, there are certain steps that organisations can take to address this issue and actively reduce the risk of modern slavery and exploitation in their supply chains.
3. What is a modern slavery statement?
3.1 The Modern Slavery Act 2015 requires certain commercial organisations in the UK with an annual turnover of £36 million or more, to publish an annual statement that demonstrates what steps they take to prevent modern slavery and exploitation from taking place in their business and in their supply chains.
3.2 Although local authorities are currently exempt from this requirement, H&F has made the decision to publish an annual modern slavery statement as part of our commitment to tackling modern slavery and demonstrating transparency.
3.3 Modern slavery statements address the specific issue of identifying and tackling modern slavery in supply chains. This is just one aspect of the work that H&F is doing to address MSE on a wider scale.
4. Preventing modern slavery within Hammersmith & Fulham Council
4.1 H&F’s Modern Slavery Strategy is clear that all organisations operating within our borough are responsible for preventing exploitation, and this includes the council itself.
4.2 The Modern Slavery Strategy highlights certain steps that organisations can take to prevent modern slavery and exploitation such as:
- ensuring staff are paid at least London Living Wage
- providing fair and safe working conditions
- requiring the same working conditions throughout their supply chain and proactively investigating this
- clearly highlighting ways employees can raise concerns if there is any suspected modern slavery or exploitation.
4.3 Hammersmith & Fulham Council have taken the following steps to prevent Modern Slavery and Exploitation:
Committing to the Charter Against Modern Slavery: We have signed up to the Charter Against Modern Slavery which recognises our responsibilities relating to human rights and modern slavery. Through the charter we have committed to training our team members to identify modern slavery, taking action with suppliers where there are concerns, and raising awareness of modern slavery within our community so we can all make informed, ethical, and legal choices.
Providing the London Living Wage: We are an accredited London Living Wage employer which means we have committed to ensuring everyone working at Hammersmith & Fulham Council receives at least the London living hourly wage of £11.95, which is significantly higher than the national minimum wage of £8.91. We believe that all employees should be fairly compensated for their work and have been an accredited London Living Wage provider since 2016.
Providing fair and safe working conditions: Hammersmith & Fulham Council is committed to providing fair and safe working conditions for all our employees. The council has adopted a range of policies to ensure that this is achieved, including our health and safety policy and our Dignity at Work policy. All employees, including managers, are provided with mandatory health and safety training as part of the induction process to ensure that staff can work in and contribute to a safe working environment. Risk assessments are regularly completed to assess the safety and appropriateness for all employee’s working environments whether working in council buildings, in the community, or at home.
Highlighting clear ways employees can raise concerns around MSE: In any instance where there may be concerns around the possibility of H&F employees being subjected to exploitative, unsafe, or unfair working conditions, we strongly encourage this to be reported immediately. Hammersmith & Fulham has a whistleblowing policy that encourages staff to raise any suspected misconduct, illegal acts, or failure to act within the council, without fear of recrimination. Whistleblowers are protected and concerns raised through the whistleblowing policy are treated with the strictest confidence and will be properly investigated. The whistleblowing policy is accessible on the staff intranet pages. The council also has dedicated internet pages specifically for providing information about MSE, what support services are available, and how to access support.
Supporting Employees to access trade union membership: As an employer, Hammersmith & Fulham Council fully recognises and supports the rights of H&F employees to access trade union membership. H&F provides trade union contact details on the intranet for staff to easily access.
Ensuring the same standards are upheld in our supply chains: Where our services are commissioned and delivered by external partners, we are taking active steps to ensure they are adhering to the same standards of preventing modern slavery and exploitation in their organisations and supply chains through our procurement process. These steps are outlined in the following section.
5. Preventing modern slavery within Hammersmith & Fulham's supply chains
5.1 As previously mentioned, Hammersmith & Fulham Council has signed the Charter Against Modern Slavery. The charter 'goes further than existing law and guidance, committing councils to proactively vetting their own supply chain to ensure no instances of modern slavery are taking place'. H&F has adopted the principles of the charter and integrated them into our own strategic action plan for tackling modern slavery and exploitation in the borough. So far, we are taking the following steps:
Providing training on MSE and supply chains: We want all employees with responsibilities around procuring services at H&F to have an understanding of the risks of modern slavery in supply chains, to know what measures can be taken to reduce risk, and to know how to report any concerns. In the 2021 to 2022 financial year, training was delivered to 60 members of staff who have procurement responsibilities in the council.
The training was delivered collaboratively by Legal and Community Safety and:
- provided an overview of modern slavery and exploitation
- highlighted our legal obligations and commitments regarding ethical procurement
- provided practical recommendations for reducing the risk of modern slavery in our supply chains at the procurement stage.
Requiring all contractors to comply fully with the Modern Slavery Act 2015: We require all contractors we work with to be fully compliant with the Modern Slavery Act 2015. If a contractor has been convicted of an offence relating to modern slavery (such as slavery, servitude, forced or compulsory labour, child labour, or an offence in human trafficking or any other form of trafficking in human beings) in the last 5 years then they are subject to mandatory exclusion at the prequalification of contractor's stage. Contractors may also be subject to discretionary exclusion on the basis of non-compliance with Section 54 of the Modern Slavery Act which requires those with a turnover of more than £36 million to publish a modern slavery statement.
Challenging abnormally low-cost tenders: We are training procurement leads to challenge abnormally low-cost tenders and to exclude low-cost tenders where the contractor relies on exploitative labour to keep costs low. As part of this process, we encourage commissioners to ask bidders to provide information on their working practices relating to workforce conditions, including wages, working hours, and rest breaks.
Immediately referring any concerns for investigation: If we identify any concerns that would indicate modern slavery and exploitation may be taking place in our supply chains, we are committed to immediately reporting these concerns via the appropriate routes (such as the Gangmaster’s and Labour Abuse Authority) be fully investigated. Any potential victims of MSE will also be referred to the National Referral Mechanism where appropriate. In this past financial year (2021 to 2022), no such risks were identified by the council. We recognise that this does not mean that our supply chains are necessarily free from exploitation, and we are committed to increasing awareness and upskilling our staff to continuously risk assess and check for any signs of exploitation.
6. Next steps
6.1 Hammersmith & Fulham Council understands that supply chains are complex. Ensuring our supply chains are completely free from exploitation will take a long-term, coordinated approach. We are committed to embedding anti-slavery principles into our procurement practices and ensuring we are implementing an approach that is collaborative across departments so that it will be sustainable long term. In the next financial year (2022 to 2023) we will:
- continue and enhance our training offer on MSE and supply chains to reach more staff
- update our procurement templates to align with the Charter Against Modern Slavery recommendations
- promote the resources available to H&F staff who may have concerns about potential exploitative practices taking place within the council or within any of our supply chains
- report on our progress in next year’s annual modern slavery statement.