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
Harlow District Council is committed to doing what we can to combat slavery and prevent human trafficking within our business and supply chain.
The council's aspiration is to have a positive impact on the fair and safe working conditions of those working directly or indirectly for us and we expect our suppliers, contractors and partners to share our vision.
The council also recognises that we have a responsibility to take a robust approach to slavery and human trafficking and we acknowledge our 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).
Our statement is an organic document that reflects the changing picture of modern slavery. Whilst there are a number of actions listed below, the aims of this statement will be embedded into our business plans with further actions encouraged across all areas of the council.
This statement is made under section 54 (1) of the Modern Slavery Act 2015 for the financial year 2018 to 2019.
Action 1: Recruitment
The council has well-established safer recruitment processes in place, including procedures for vetting new employees to ensure they are eligible to work in the UK.
Action 2: Disclosure
The council has a robust whistleblowing policy in place and is committed to enabling officers who have concerns to report them without repercussions.
Action 3: Training
The council's intranet currently provides guidance for all staff. Targeted training to take place with key staff through face to face events or e-learning on the initial steps and processes to follow if slavery or human trafficking is suspected.
Action 4: Safeguarding
The council has a Child and Adult Safeguarding Policy in place that references modern slavery and human trafficking and is aligned to the Southend, Essex and Thurrock (SET) Child Protection Procedures and SET Safeguarding Adult Guidelines.
Action 5: Procurement
The council's selection process has been updated to address the risk of modern slavery and the suggested clauses from the Chartered Institute of Public Finance and Accountancy have been added to our suite of precedent processes.
All tender documents shall continue to include a statement that our 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".
Any non-compliance with these requirements will be dealt with, if and when they arise, with appropriate remedial action. Our aim is to only trade with those who comply with the Act.
Action 6: Money
The Council is a Living Wage employer. Every Council employee earns at least the Living Wage. The Council's vision is much wider and encourages all its suppliers to pay the Living Wage through the procurement process.
The Anti-Money Laundering and Counter-Terrorism Financing Amendment Act 2017 came into force on the 26 June 2017 and put a greater onus on what authorities should do to prevent the proceeds of criminal activity being laundered through their systems. The council's policy for anti-money laundering is supplementary to the council's wider anti-fraud and corruption strategy, which sets out what actions the council will take to continue to develop its resilience to fraud and corruption.
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 Kean, Chief Executive of Harlow Council in November 2019.