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Modern slavery declaration

Modern Slavery Act 2015 Section 54 – Slavery and Human Trafficking


Modern Slavery Act 2015 Section 54 – Slavery and Human Trafficking Statement
Buckinghamshire Healthcare NHS Trust (BHT) aims to follow good practice and take all reasonable
steps to prevent slavery and human trafficking. We are committed to ensuring that all of our
employees are aware of the Modern Slavery Act 2015 and their safeguarding duty to protect and
prevent any further harm and abuse when it is identified or suspected that the individual may be or is
at risk of modern slavery/human trafficking.

We are committed to ensuring that no modern slavery or human trafficking takes place in any part of
our business or our Supply chain. This statement sets out actions taken by BHT to understand all
potential modern slavery and human trafficking risks and to implement effective systems and
controls. Section 54 of the Modern Slavery Act 2015 requires all organisations to set out the steps
the organisation has taken during the financial year to ensure that slavery and human trafficking is
not taking place in any of its supply chains, and in any part of its own business.

Trust Structure and Principle Activities
Buckinghamshire Healthcare NHS Trust is a major provider of integrated hospital and community
services for people living in Buckinghamshire and surrounding counties, providing care to over half a
million patients every year. In addition we provide specialist spinal services at our world renowned
National Spinal Injuries Centre for patients across England and internationally. The Trust is also the
regional centre for burns and plastics services.

Our aim is to provide safe and compassionate care, every time to our patients. We deliver our
services from a network of facilities including:

  • A range of community settings – health centres, schools and patients’ own homes
  • Three community hospitals in Amersham, Buckingham and Chalfont & Gerrard’s Cross.
  • Two community hubs at Thame and Marlow.
  • Two acute hospitals located in the two most densely populated areas of Buckinghamshire – High Wycombe and Stoke Mandeville, Aylesbury.
  • Florence Nightingale Hospice based on the Stoke Mandeville site, Aylesbury.

We work closely with the Buckinghamshire Integrated Care Partnership. The partners include:

  • Buckinghamshire Healthcare NHS Trust;
  • NHS Buckinghamshire Clinical Commissioning Group (CCG);
  • Oxford Health NHS Foundation Trust;
  • South Central Ambulance Service NHS Foundation Trust;
  • Buckinghamshire County Council;
  • FedBucks GP federation.

Buckinghamshire Integrated Care Partnership (ICP) is part of the wider Buckinghamshire,
Oxfordshire and Berkshire West Integrated Care System (ICS).

We procure goods and services from a range of providers. Contracts vary from small one-off
purchases to large service contracts. All spend, aside from a few exceptions such as rates, is paid via PO. The Applicable Contract Terms Policy applies to any NHS organisation and states that where an NHS body issues a PO the standard Terms & Conditions apply.

The top 80% of suppliers nationally affirm their own compliance with the modern slavery and human trafficking act within their own organisation, sub-contracting arrangements and supply chain.

Organisational policies in relation to slavery and human trafficking
BHT has internal policies and procedures in place that assess supplier risk in relation to the potential
for modern slavery or human trafficking.

BHT Safeguarding Standard Operating Policy and procedure includes information on modern day
slavery/human trafficking.

The BHT Incident Reporting Policy states that staff should report incidents of all types and this includes concerns regarding modern slavery and human trafficking. By using the local risk management system (Datix) appropriate teams, including safeguarding and Freedom to Speak Up Guardian are made aware.

All staff have access to the BHT Safeguarding team for support and guidance when they are
concerned about modern day slavery or trafficking.

BHT also has a Freedom to Speak Up Guardian who will provide support to the individual raising a
concern. Staff are provided with this information at corporate induction.

Trust activities and policies are required to have an Equality Impact Assessment (EQIA) completed.

Assessing and managing risk and due diligence processes in relation to slavery and human

We are committed to ensuring that there is no modern slavery or human trafficking in our supply
chains or in any part of our business.

The Trust reviews its Modern Slavery and Human Trafficking Statement on an annual basis and
presents it at a Board meeting in Public. This demonstrates a public commitment, ensures visibility
and encourages reporting standards.

To identify and mitigate the risks of modern slavery and human trafficking in our own business and
our supply chain:

  • The Trust adheres to the National NHS Employment Checks / Standards (this includes employees UK address, right to work in the UK and suitable references)
  • The Trust has systems to encourage the reporting of concerns and the protection of
  • The Trust purchases a significant number of products through NHS Supply Chain, whose ‘Supplier Code of Conduct’ includes a provision around forced labour. Other contracts are governed by standard NHS Terms & Conditions. High value contracts are effectively managed and relationships built with suppliers.
  • The majority of our purchases utilise existing supply contracts or frameworks which have been negotiated under the NHS Standard Terms and Conditions of Contract, these all have the requirement for suppliers to have suitable anti-slavery and human trafficking policies and processes in place. Where a suitable framework exists we use them in preference to tendering. These are run by NHS procurement entities and are governed by NHS Standard Terms & Conditions.
  • All suppliers are required by law to comply with the provisions of the UK Modern Slavery Act (2015). This will be reinforced where appropriate by Standard Selection Questionnaires as part of tender processes along with use of NHS Standard Terms
    and Conditions either direct with suppliers or through framework agreements.

Effective action taken to address modern slavery – Performance Indicators

The Trust is committed to social and environmental responsibility and has zero tolerance for Modern Slavery and Human Trafficking. Any identified concerns regarding Modern Slavery and Human Trafficking are escalated as part of the organisational safeguarding process. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes BHTs slavery and human
trafficking statement for the current financial year.

All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility for overall compliance. A Freedom to Speak Up Report is submitted to the Board on a 6-monthly basis which includes an overview of the number of concerns raised by staff and the category that they fall into.

Training on modern slavery and trafficking

Safeguarding training is mandatory for all staff and includes information on trafficking and modern day slavery in order to promote the knowledge and understanding of escalating concerns via the Home Office national referral mechanism/duty to notify process.

This statement has been approved by the Board, who will review and update it on an annual basis.

  • Approved by Board: 29 July 2020
  • Next review: July 2021