We produce a Modern Slavery Act Statement which explains what steps we have taken to make sure that there is no slavery or human trafficking within our organisation, our sub-contractors, partners or supply chains.
Modern Slavery Act statement
Introduction
This statement is designed to satisfy the requirements of Section 54 of the Modern Slavery Act 2015, by setting out the approach of Harlow Council to modern slavery, human trafficking, forced labour and labour rights violations in the organisation and its supply chains.
Organisation structure and supply chains
The council discharges statutory functions including waste collection, licencing and environmental health and planning and building control services. The council is a substantial landholder and also functions as a social and commercial landlord. The council delivers leisure and cultural facilities, and is supported by back office support and customer care services.
The council has a diverse and substantial supply chain, with procurement carried out both as a central function and devolved within Directorates.
The council has identified a number of areas in its supplier chain where the risk of modern slavery is the highest; these being building repair and maintenance, cleaning and janitorial, commercial construction and entering into commercial tenancies in high-risk industries such as beauty, car washing, distribution, food premises.
Current procurement policy
The council's supplier selection process addresses the risk of modern slavery and the suggested clauses from the Chartered Institute of Public Finance and Accountancy (CIPFA) have been added to its processes.
All tender documents include a statement of the minimum expectations required by contractors, suppliers, and partners that there is 'no use' either directly or by any sub-contractors or within the supply chain of:
- child labour
- slavery, forced, bonded or involuntary labour
- human trafficking or exploitation
All tenders require contractors to provide confirmation that they are compliant with the act, including a declaration stating, "they are not involved in modern slavery or human trafficking and have not been subject to any investigation in connection with any offences involving slavery and human trafficking".
Non-compliance of these requirements will be dealt with, when they arise, with the appropriate remedial action available to the council.
Due diligence, transparency and reporting
In accordance with section 52 of the Modern Slavery Act 2015 (Duty to Notify), the council has a duty to notify the Home Office of any individuals who it believes is a suspected victim of slavery of human trafficking. The council works collaboratively with Essex Police to ensure that identified cases are referred appropriately to the National Referral Mechanism (NRM).
This statement is supported through the following corporate policies and strategies:
- anti-money laundering and terrorism financing policy
- child and adult safeguarding policy
- procurement strategy
- whistleblowing policy
Awareness and training
The council recognise the importance of ensuring all its staff and members understand how modern slavery manifests itself and how to report when it does.
Guidance for all is provided through the internal intranet. Targeted training takes place with key staff and members through face-to-face events and e-learning.
The following activities support the council’s commitment to addressing modern slavery:
- Code of conduct – the council expects all employees and members to demonstrate the highest standards of conduct and ethical behaviour.
- Disclosure - the council has a robust whistleblowing policy in place and is committed to enabling officers who have concerns to report them without repercussions. All new employees have the requisite checks, including identification and right to live and work in the UK.
- Equality - the council is committed to challenging discrimination, harassment and victimisation or any conduct prohibited by the Equality Act 2010. Therefore, the council has a programme of mandatory equality and diversity training for all officers and members to provide better understanding and cultural awareness.
- Fraud and corruption - the council policy for anti-money laundering is supplementary to the council's wider anti-fraud and corruption strategy. The strategy sets out what actions the council will take to continue to develop its resilience to fraud and corruption.
- Safeguarding - the council's child and adult safeguarding policy refers to modern slavery and human trafficking and is aligned to the Southend, Essex, and Thurrock (SET) child protection procedures and SET safeguarding adult guidelines
Organisational declaration
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015. This statement is approved by the council's Monitoring Officer and will be subject to review on an annual basis.