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 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.
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.
|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.