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
Due to the significant impact of coronavirus on the council’s resources and other related pressures, the publication of this statement has been delayed.
This statement is made under section 54(1) of the Modern Slavery Act 2015 and explains the commitment of Harlow Council in its efforts to combat slavery and prevent human trafficking within the organisation, its partners, contractors, and supply chain.
The council recognises that it has a responsibility to take a robust approach to slavery and human trafficking and acknowledges its duty to notify the Secretary of State of suspected victims of slavery or human trafficking in accordance with section 52 of the Modern Slavery Act 2015 (Duty to Notify).
The council seeks to have a positive impact on the fair and safe working conditions of those working directly or indirectly for the organisation and expects its suppliers, contractors, and partners to share this vision.
This statement relates to actions and activities during the financial year 2019 to 2020:
As part of the council’s robust and transparent recruitment processes, all new employees have the requisite checks, including identification and right to live and work in the UK.
The council is an accredited Living Wage employer, and through the procurement process, we encourage all our suppliers and contractors to pay the ‘real’ Living Wage.
The council's 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 our suite of precedent processes.
All tender documents will continue to include a statement of the council’s minimum expectations of our 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 will continue to 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 with these requirements will be dealt with, if and when they arise, with appropriate remedial action. The council’s aim is to only trade with those who comply with the act.
As part of the council procurement process, we will investigate further the Home Office Modern Slavery Assessment Tool (MSAT) as a potential mechanism to assess the risks of modern slavery in the supply base.
Training and awareness
The council's staff intranet currently provides guidance for all staff. Targeted training takes place with key staff through face to face events and e-learning on the initial steps and processes to follow if slavery or human trafficking is suspected.
The following policies 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.
- 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 makes reference to modern slavery and human trafficking and is aligned to the Southend, Essex and Thurrock (SET) child protection procedures and SET safeguarding adult guidelines.
- Harlow Council safeguarding responsibilities
- Essex Safeguarding Adult Board website
- Essex Safeguarding Children Board website
This statement is approved by the council's Monitoring Officer and Head of Governance and will be subject to review on an annual basis. The supply chain elements will form part of the council's procurement strategy.
This statement was signed by Brian Keane, Chief Executive of Harlow Council in November 2020.