Transparency within our supply chains (April 2022 to March 2023).
1. Introduction
Modern slavery is the fastest growing global crime, estimated to affect over 136,000 people in the UK.
The Modern Slavery Act 2015 defines modern slavery as the recruitment and movement of persons for purposes of exploitation. Offences listed within the act include slavery, servitude, forced or compulsory labour and human trafficking.
And may take the form of:
- forced labour
- domestic servitude
- criminal exploitation
- sexual exploitation
- forced or sham marriage
- organ harvesting.
Modern slavery can affect anyone regardless of their age, gender, nationality or religion.
Victims and survivors are targeted for their vulnerabilities and are often:
living in poverty
experiencing homelessness, isolation and abuse and poor mental health.
Modern slavery is often hidden in plain sight and is happening in supply chains across the globe and, the UK. In the financial year 2022 to 2023, 21 victims and survivors of modern slavery were identified in Hammersmith & Fulham (H&F). However, this is unlikely to be a true representation of the scale of modern slavery taking place within the borough.
2. Our commitment as a council
H&F Council is fully committed to ending modern slavery in all its forms.
In 2021, we launched our inaugural modern slavery and exploitation (MSE) strategy (pdf 1MB) in partnership with Stop The Traffik. Our strategy spans a 5-year timeframe and is split across 4 key objectives as seen in Figure 1.
As part of our objective to Prevent, H&F Council has signed the Charter Against Modern Slavery, a commitment to proactively vet our supply chains to ensure no instances of modern slavery are taking place. Each year, we will report on our progress to tackle modern slavery in the form of a modern slavery statement.
This is an updated modern slavery statement for H&F Council which covers the period between April 2022 and March 2023.
- Text description
Our overall vision is to end modern slavery.
Objective 1: Victims identified
Outcomes:
- Know the signs
- Victims can ask for help
- We know how to respond
Activities:
- Awareness raising through campaigns and training
Objective 2: Support victims
Outcomes:
- Partners follow duties and best practice
- Referrals are made
- Trauma information is in place
Activities:
- Project delivery
- Information sharing
Objective 3: Exploiters brought to justice
Outcomes:
- Exploiters identified and investigated
- Victims supported to give evidence
- Appropriate intervention is taken
Activities:
- Information sharing
Objective 4: Exploitation prevented
Outcomes:
- Employers tackle exploitation
- Demand for ethical services and products
- Adults and children can exercise their rights
Activities
- Project delivery
3. What is a modern slavery statement?
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 demonstrating the steps they have taken to prevent modern slavery and exploitation from taking place in their business and in their supply chains.
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.
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
Our modern slavery strategy is clear that all organisations operating within our borough are responsible for preventing exploitation, and this includes the council itself.
The MSE 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.
We have taken the following steps to prevent MSE.
Committing to the ‘Charter Against Modern Slavery’
H&F has 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, acting against 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 London Living Wage
We are an accredited London Living Wage employer which means we have committed to ensuring everyone working at H&F Council receives at least the London living hourly wage of £11.95 which is significantly higher than the national minimum wage of £10.42.
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
H&F Council is committed to providing fair and safe working conditions for all our employees.
The council has adopted a range of policies accessible to all staff to ensure that this is achieved.
These policies include:
- health and safety
- dignity at work
- and equity, diversity, and inclusion.
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.
H&F 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, including any sub-contractors they commission. These steps are outlined in the following section.
5. Preventing modern slavery within Hammersmith & Fulham’s supply chains
As previously mentioned, H&F Council has signed the Charter Against Modern Slavery. The Charter goes further than existing law and guidance, committing councils to proactively vet 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 at H&F with procurement responsibilities to understand 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 financial year of 2022-2023 H&F invested in a tailored training package provided by leading sustainability consultants, ActionSustainability.
The training sessions will take place in the first quarter of 2023 to 2024 and will focus on:
- legislative landscapes
- procurement due diligence
- industries at high risk of MSE
- how to challenge noncompliance among tenders.
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 based on non-compliance with Section 54 of the Modern Slavery Act which requires those with a turnover of more than £36M to publish a modern slavery statement. H&F’s annual modern slavery statement will be attached to the contract of every supplier we commission.
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 MSE 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) to be fully investigated.
We will also notify the Home Office of any victims and, or potential victims by working closely with our adult and children social care teams to ensure the relevant referrals and safeguarding procedures are completed.
In this past financial year (2022 to 2023), no such risks were identified with H&F’s supply chains.
However, we recognise that this does not mean 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
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 (2023 to 2024) we will:
- deliver the tailored training package developed by ActionSustainability.
- continue to provide MSE awareness training to a minimum of 80 council staff and, or local partners per year
- continue to promote toolkits and resources to support the due diligence processes performed by staff with procurement responsibilities
- 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
- continue to update our internal staff policies relating to fair and safe working conditions
- continue to consider new ways of ensuring our supply chains are free of modern slavery
- report on our progress in next year’s annual modern slavery statement.