Modern Slavery Statement

What is Modern Slavery?

The term ‘Modern Slavery’ is an umbrella term, encompassing:

  1. Human trafficking
  2. Slavery, Servitude and Forced or Compulsory Labour.

Traffickers and slave drivers coerce, deceive and force individuals against their will into a life of abuse, servitude, and inhumane treatment. Many active organised crime groups are involved in modern slavery. But it is also committed by individual opportunistic perpetrators. These are for purposes of exploitation, including:

  • Forced Labour: being made to work for little or no money
  • Sexual Exploitation: being coerced or forced into selling sex
  • Domestic Servitude: being made to work within a home environment for little or no pay
  • Criminal Exploitation: being forced to break the law for someone else (e.g., stealing, selling drugs)
  • Forced/Sham Marriage: being made to marry someone you don’t want to marry
  • Organ Harvesting: bodily organs being removed for financial gain

In 2020-2021, 10,613 potential victims were referred to the Home Office. 47% were children, an increase on previous years. 34%, the majority, were UK nationals. The number of modern slavery offences recorded by the police was 8,354 with a 73.8% conviction rate (2021 UK Annual Report on Modern Slavery).

The role of The London Borough of Bexley

As a local authority, we have a duty to notify the Home Office of any individual encountered who we believe is a suspected victim of modern slavery or human trafficking. By referring a victim to the National Referral Mechanism (NRM), the Home Office can investigate the circumstances of someone’s exploitation further and provide the necessary support to potential victims and survivors of modern slavery.

In the London Borough of Bexley, we are committed to the opposition of modern slavery and human trafficking and are working with our partners to drive the identification, recognition, awareness, and disruption of this heinous crime. The London Borough of Bexley’s Modern Slavery Strategy and Toolkit sets out our local partnership approach (including referral pathways) and is available to read on request to the Community Safety team via email to community.safety@bexley.gov.uk.

The Bexley modern slavery partnership is made up of the following four sectors.

Local Authority

  • Procurement
  • Community Safety
  • Adult Social Care
  • Children’s Social Care
  • Youth Offending Services
  • Trading Standards
  • Licencing
  • Housing 

Public Authority

  • Metropolitan Police
  • National Crime Agency
  • Gangmasters and Labour Abuse Authority
  • Immigration authorities
  • London Fire Brigade

Specialist NGOs

  • Salvation Army
  • The Children’s Society
  • Barnados
  • Human Trafficking Foundation
  • Stop the Traffik
  • Unseen

Government

  • Single Competent Authority
  • Multi-Agency Assurance Panels (MAAPs)

We have five aims:

  1. To identify victims or potential victims.
  2. To disrupt and prevent exploitation or further exploitation.
  3. To support victims and survivors of modern slavery.
  4. To bring exploiters to justice.
  5. To ensure a whole system of understanding of our statutory responsibilities.

Further information can be found in our Modern Slavery Strategy and Toolkit.

What can I do?

We can all help end modern slavery by being aware of what to look for. Signs that someone might be a victim of modern slavery include:

  • showing signs of injury, abuse, and malnourishment
  • they look unkempt, are often in the same clothing and have poor hygiene
  • appearing to be under the control and influence of others
  • living in cramped, dirty, overcrowded accommodation
  • they have no access or control of their passport or identity documents
  • appearing scared, avoiding eye contact, and being untrusting
  • they may allow others to speak for them when addressed directly, rather than speak for themselves
  • they’re collected very early and/or returned late at night on a regular basis
  • may have inappropriate clothing for the work they are performing, and/or a lack of safety equipment
  • may be isolated from the local community and their family
  • they travel only with other workers

The above list is not exhaustive and further information on the signs to look out for can be found on the Unseen website.

If you are a victim or know someone who might be:

  • in an emergency, always call 999, or otherwise call 101 or visit your local police station
  • if an adult, call the London Borough of Bexley on 020 8303 7777 and ask for ‘Screeners’
  • if a child, call the Children’s Multi-Agency Safeguarding Hub (MASH) on 020 3045 5440
  • if unsure, you can call the Community Safety Services Team on 020 8303 7777 or email community.safety@bexley.gov.uk
  • for more information, call the Modern Slavery Helpline free on 0800 0121 700 or visit the Modern Slavery Helpline website

The UK Modern Slavery Helpline is available 24/7 to offer confidential advice and support for any victim, statutory agency, business, or member of the public regarding modern slavery suspicions or concerns. Trained Helpline Advisers are available to discuss potential signs of modern slavery and options for callers or victims in need.

For professionals seeking latest advice on how to help potential victims

For the latest advice on how to end modern slavery, including details about how to refer victims into the national referral mechanism (NRM) and the statutory guidance, please see the Government’s Modern Slavery website.

You can also find a directory of support services for victims of modern slavery on the Bexley Safeguarding Adults Board (BSAB) website.

Transparency in Supply Chains Statement

The Modern Slavery Act 2015 requires commercial organisations with an annual turnover of more than £36 million to report on the steps they take to ensure modern slavery does not take place in their business or in their supply chains. Although it is not currently a requirement for Local Authorities, the London Borough of Bexley publishes this statement to provide transparency and demonstrate our commitment to tackling modern slavery.

Preventing Modern Slavery in our Business

The London Borough of Bexley has a duty to prevent and tackle modern slavery or exploitation of its own staff. We do this by:

  • our Code of Conduct (PDF) for employees which sets out the expectations of staff, management, and the whole organisation
  • our Equality Policy (PDF) ensures there is an equal opportunity and no one group is more vulnerable to exploitation than another
  • our Whistleblowing Policy (PDF) which provides a confidential channel for staff to report any concerns of exploitation and for these to be investigated
  • our Employment Terms, including paying at least Minimum Wage to all employees
  • ensuring all staff complete mandatory training on modern slavery and human trafficking

Preventing Modern Slavery in our Supply Chains

The London Borough of Bexley recognises the role and responsibility that comes with its buying power and the need to ensure that all purchasing practices consider the ethical, environmental, and law-abiding elements when determining who it may contract with. Part of this is ensuring suppliers act in accordance with the Modern Slavery Act 2015 and take their responsibilities under all modern slavery legislation seriously. This is not only to comply with the law but also to ensure we support and safeguard vulnerable people and to make Bexley a safer borough.

We do this by embedding in our standard contracting terms and conditions the obligation for all contractors to comply with the Modern Slavery Act and all other applicable modern slavery legislation in the UK and/or to comply with statutory duties. Such legislation includes the requirement to have their own modern slavery statement and anti-slavery practices if satisfying the criteria of a commercial organisation with a turnover of more than £36 million. The standard terms and conditions also enable the London Borough of Bexley to act if there is a breach, allowing modern slavery and exploitation identified in our supply chain to be addressed.

Although we feel there is a low risk of exploitation in the Council’s supply chains, we encourage all contractors to take reasonable steps to ensure their own supply chains are free from modern slavery. More information on transparency in supply chains can be found here.

We are committed to ongoing due diligence and will work with our suppliers to put in place necessary measures to reduce or mitigate the risk of modern slavery and exploitation as necessary. The Council’s contract terms and conditions are regularly reviewed to ensure they embed not only updated legislation but the London Borough of Bexley’s values in service and project delivery.

Procurement Action Plan

The below table outlines the London Borough of Bexley’s Procurement Action Plan for 2021/22, aimed at reducing and mitigating the risk of modern slavery and human trafficking in our supply chains. This will be reviewed and updated annually.

Task Action
1. Train its corporate procurement team to understand modern slavery through the Chartered Institute of Procurement and Supply’s (CIPS) online course on Ethical Procurement and Supply. All appropriate staff now trained
2. Require its contractors to comply fully with the Modern Slavery Act 2015, wherever it applies, with contract termination as a potential sanction for non-compliance. Part of due process for every order/contract.
3. Challenge any abnormally low-cost tenders to ensure they do not rely upon the potential contractor practising modern slavery We challenge abnormally low-cost tenders as part of our current process.
4. Highlight to its suppliers that contracted workers are free to join a trade union and are not to be treated unfairly for belonging to one. This has now been added as a clause on the declaration for tenders and to our standard purchase order.
5. Publicise its whistle-blowing system for staff to blow the whistle on any suspected examples of modern slavery.

Our Corporate Modern Slavery Strategy and toolkit, mandatory training courses and training offer will ensure staff are informed on the issue of Modern Slavery and know who to contact if they want to report an issue, within the council or externally.

The Gangmaster Labour Abuse Authority are a named first responder in the Modern Slavery Act and its role is to protect vulnerable workers. Further information is available on the Gangmasters and Labour Abuse Authority website.

Prospective contractors to the Council are urged to adopt a similar whistleblowing system to that of the Council via a ‘Declaration’ document provided to all bidders on tender exercises.

6. Require its tendered contractors to adopt a whistle-blowing policy which enables their staff to blow the whistle on any suspected examples of modern slavery See above. Procurement to ensure contract managers are trained and share the information above with contactors.
7. Review its contractual spending regularly to identify any potential issues with modern slavery This is part of the current process, the training under item 1 and understanding the Corporate Strategy and attending the Modern Slavery training will enhance staff understanding - this is increased and staff are confident when reviewing spending to understand what to look for in terms of sign of Modern Slavery.
8. Highlight for its suppliers any risks identified concerning modern slavery and refer them to the relevant agencies to be addressed.

The procurement team continually work with Contract Managers to ensure they understand the issues, attend the training sessions and have seen the Corporate Strategy and toolkit.

Further information is available on the Gangmasters and Labour Abuse Authority website.

9. Refer for investigation via the National Crime Agency’s national referral mechanism any of its contractors identified as a cause for concern regarding modern slavery Guidance on the NRM is available in the Corporate Strategy. Corporate staff training will provide further clarity over the coming year.
10. Report publicly on the implementation of this policy annually. The Bexley Modern Slavery Strategy and toolkit includes an action plan. This includes an action to comply with the 10 points set out in this charter. The procurement team will provide an update on progress each year, when the strategy is reviewed beginning in April 2019. The strategy and any review information will be published on the Council's website.

For more information on Procurement and Contracting, please visit Contracts, Tenders and Procurements.

Responding to Modern Slavery and Exploitation within our Organisation or Supply Chain

Whilst the measures outlined above aim to prevent modern slavery in our organisation and supply chains and we hope not to identify modern slavery, we see fit to set out our response if we do.

If any cases are identified within our organisation, we have internal whistleblowing procedures to be followed to report and investigate these.

If any cases are identified within our business or supply chain, there may be contractual implications, including termination of the contract, and further investigation.

Information concerning suspected modern slavery or human trafficking will be passed on to the Police and any other appropriate authorities for full and proper investigation and action.

The London Borough of Bexley takes a coordinated community response to tackling modern slavery and safeguarding our residents. The same will be applicable if there is a suspicion of modern slavery in our organisation or supply chains. Please see the London Borough of Bexley’s modern slavery partnership above. We will work together to ensure victims access support and crimes are investigated to bring exploiters to justice.