Modern slavery and human trafficking statement
Avon and Somerset Constabulary (ASC) considers the obligations placed on commercial organisations under section 54(1) of the Modern Slavery Act 2015 are vital in combating modern slavery and human trafficking.
This statement sets out our current practice and constitutes ASC’s compliance statement.
Purpose
This statement sets out ASC’s actions to understand potential modern slavery risks related to its business and put in place steps aimed at ensuring there is no slavery or human trafficking, forced labour or exploitation in its own business or its supply chain
Organisational structure and supply chains
This statement covers the business activities of ASC. It covers direct employees of the Force, agency workers engaged through the Force’s managed service contract with Matrix; and services delivered on behalf of the Force by third-party organisations and their supply chains.
Countries of operation and supply
ASC operates in the United Kingdom. Whilst the risk of slavery and human trafficking is considered low, the Force remains vigilant and will take all steps available to manage the risks presented.
High-risk activities
The Force has determined there are no areas of its business considered at high risk of slavery or human trafficking:
Responsibility
Responsibility for the Force anti-slavery initiatives is as follows;
Policies: The Director of Resources will ensure appropriate recruitment and employment policies are in place and reviewed annually.
Risk assessments: Are undertaken by the relevant service area where there is deemed a risk of modern slavery or human trafficking, with the support of colleagues in HR and Procurement. The risk assessment will be signed by the appropriate service director and held centrally and demonstrate the corporate responsibility for human rights and modern slavery risk analysis.
Investigations/due diligence: Any concerns regarding modern slavery or human trafficking will be raised with the Director of Resources in the first instance.
Training: Awareness of the issue of human trafficking and modern slavery has been raised in the Chief Constable’s blog and through intranet articles with access to relevant information. A training needs analysis will determine what further development issues exist to ensure a better understanding of and the response given to any identified slavery and human trafficking risks. A review of e-learning materials is being undertaken.
Relevant policies
ASC operates the following policies which are being reviewed and updated to set out our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our services and operations:
Whistleblowing policy – The organisation encourages all workers, customers and other business partners to report any concerns related to the direct activities, or supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Employee code of conduct: ASC’s code makes it clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour in all its operations and when managing our supply chain.
Expectations of Suppliers: ASC is committed to ensuring its suppliers adhere to the highest ethical standards. Suppliers are required to demonstrate they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. We work with suppliers to ensure they meet the required standards. However, serious violations of the Force’s supplier expectations will lead to termination of the business relationship.
Agency workers managed service: The Force uses only specified reputable employment agencies to source labour and always through its managed service provider, verifies the practices of any new agency before accepting workers from that agency. The contractual audit process with the managed service provider evidence panel supplier compliance. There has been no requirement to take action as a result of the risk of slavery and human trafficking in the period covered by this statement.
Agency staff
Our managed service provider’s Modern Slavery statement sits as an appendix to the Force statement.
Practical guidance
We have published advice on spotting and dealing with Modern Slavery.
Due diligence
ASC undertakes due diligence when considering new suppliers and regularly reviews its existing suppliers. This is the responsibility of individual procurement managers.
The organisation’s due diligence and reviews include:
- mapping the supply chain broadly to assess particular product or geographical
- risks of modern slavery and human trafficking;
- evaluating the modern slavery and human trafficking risks of each new supplier
- conducting annual assessments of qualifying suppliers on financial stability, compliance with various employment policies and where risks are identified greater focus on slavery and human trafficking;
- creating a risk profile for each qualifying supplier to cover all the above issues;
- taking steps to improve substandard suppliers’ practices, including providing advice to suppliers and requiring them to implement action plans, for example, to demonstrate compliance with safer recruitment requirements; participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular;
- invoking sanctions against suppliers who fail to improve their performance in line with an action plan or who seriously violate our expectations of suppliers, including the termination of the business relationship
- All invitations to tender for business with the Force will include the following statement:
- “We are committed to ensuring there is no modern slavery or human trafficking in our supply chains. ASC will not support or deal with any business knowingly involved in slavery or human trafficking.
“We use the Crown Commercial Services Standard Selection Questionnaire which includes a self- certification element to our tendering processes this is used to assess suppliers’ policies and practices on slavery and human trafficking”.
- “We are committed to ensuring there is no modern slavery or human trafficking in our supply chains. ASC will not support or deal with any business knowingly involved in slavery or human trafficking.
Section 7 Modern Slavery Act 2015: Requirements under Modern Slavery Act
Training
The Force requires all staff responsible for supply chain management to complete training on modern slavery. We are reviewing existing training material to determine its effectiveness in light of the Modern Slavery Act 2015.
Modern slavery training will cover:
- our business purchasing practices, which influence supply chain conditions and which should, therefore, be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
- how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
- how to identify the signs of slavery and human trafficking;
- what initial steps should be taken if slavery or human trafficking is suspected;
- how to escalate potential slavery or human trafficking issues to the relevant parties within Avon and Somerset Constabulary;
- what external help is available, for example through the Modern Slavery Helpline, Gang-masters and Labour Abuse Authority and “Stronger together” initiative;
- what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and
- the steps we take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation supply chains.
Awareness-raising programme
As well as training staff, we have raised awareness of modern slavery issues by several entries in the Chief Constables blog including a link to the Annual Report of the Independent Anti-Slavery Commissioner 2015 – 2016.
Further notices will be posted in our monthly Team Talk briefing which will explain to staff:
- the basic principles of the Modern Slavery Act 2015;
- how employers can identify and prevent slavery and human trafficking;
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the Force and
- that external help is available, for example through the Modern Slavery Helpline.
Police and Crime Commissioner approval
This statement has been approved by the Police and Crime Commissioner who will receive an annual review containing any updates in the relevant Board.
Relevant documents