2022/23
Overview
Modern slavery is the removal of personal freedoms in order to exploit human beings for financial or personal gains. It can take many forms including forced labour, human trafficking and sexual exploitation. It is a complex issue with a global reach. There were an estimated 50 million people in modern slavery in 20211 and these numbers are increasing. We recognise that modern slavery will exist in our supply chain, and we are committed to do all we can to identify and manage the risks that our business and purchasing activities pose.
Our Statement
This Modern Slavery and Human Trafficking statement is for the financial year ending 31 March 2023. It outlines the shared commitment and actions that have been carried out by Bristol and Weston NHS Purchasing Consortium (B&WPC), North Bristol NHS Trust (NBT) and University Hospitals Bristol and Weston NHS Foundation Trust (UHBW) over this time period. In the statement, terms such as ‘our’ and ‘we’ refer to all three organisations. This is the first modern slavery statement that we have produced. It covers the following areas of our business activities;
- The recruitment of both temporary and permanent employees.
- The working conditions and practices for our employees.
- The procurement of goods and services.
Organisation Structure and Supply Chains
Bristol and Weston Purchasing Consortium B&WPC provide a comprehensive range of purchasing services to support local Trust and Healthcare Providers.
B&WPC staff are NHS employees, hosted by North Bristol NHS Trust and the services provided include all aspects of clinical and non-clinical purchasing and supply chain management. B&WPC’s main clients include both NBT and UHBW and cover an annual spend of approximately £750m. B&WPC work closely with both Trusts to support compliance with all purchase-to-pay procedures and deliver improved efficiencies.
North Bristol NHS Trust
NBT has over 12,000 staff delivering healthcare across main sites at Southmead Hospital Bristol, Cossham Hospital and Bristol Centre for Enablement and within the local community of Bristol, North Somerset and South Gloucestershire. NBT is a regional centre for neurosciences, plastics, burns, orthopaedics and renal services. NBT’s aim is to deliver an outstanding patient experience and its values of caring, ambitious, respectful and supportive underpin everything that we do.
University Hospitals Bristol and Weston NHS Foundation Trust
UHBW has a workforce of over 13,000 staff, delivering over 100 different clinical services across 10 different sites serving a core population of more than 500,000 people locally and from across the southwest.
With services from the neonatal intensive care unit to care of the elderly, UHBW provides care to the people of Bristol, Weston and the southwest from the very beginning of life to its later stages.
Our Supply Chain
Our supply chain is large, multi-tiered, global and complex. We procure a wide range of clinical and non-clinical goods, services and works. This includes medical equipment, personal protective equipment and uniforms, dressings, mattresses and bed linen, laptops, software, furniture and mechanical and electrical services to name but a few.
Many of our purchases are from sectors that are known to be high risk for modern slavery. Our approach to identifying and managing modern slavery risks must be embedded into any new procurement activity and within our existing contracts to be effective.
We let contracts over a range of timescales from medium to long term relationships to oneoff purchases. As part of our procurement policy, we actively seek to utilise frameworks provided by public sector organisations such as NHS Supply Chain and Crown Commercial Services. We have over 2,500 tier 1 suppliers and over 1,000 active contracts in place.
Policies in relation to slavery and human trafficking A number of national regulations and mandates have been set over the past 12 months that allow for modern slavery to be prioritised as a topic for consideration in the purchases that we make.
The Health and Care Act 2022 allow for regulations to be set to eradicate modern slavery and human trafficking in NHS supply chains. NHS England has also adopted the mandatory inclusion of Net Zero and Social Value criteria in the evaluation of all tenders. This is also mandated for all NHS Trust procurements. Modern slavery can be a topic addressed under social value where it is proportionate and relevant to the contract.
We have created two policies that build on this national level focus to address to this issue. The B&WPC procurement strategy 2022-25 is published online and is publicly available having been signed off and approved by the Trust Boards of both NBT and UHBW.
- B&WPC Procurement Strategy 2022-25. This document sets out our values and outlines the areas of focus for B&WPC to ensure that we are maximising the value obtained from our external spend. There are 4 objectives within the strategy. The Anchor in the Community objective includes a clear commitment to remove modern slavery for our supply chain and to use our market leverage to drive an ethical supply chain. The aim is to ensure that our supply chains and procurement processes are ethical, free from worker abuse and exploitation and provide safe working conditions. An away day was held with all B&WPC staff to engage with and explore the strategy and what its aims mean in the short, medium and long term to the team.
- Joint Ethical Procurement Strategy. This document will reflect our joint vision and aims to support the delivery of exceptional healthcare services in a sustainable manner. Included within the definition of ‘sustainable’ is ethical conduct and social value. We will document a specific commitment to ensure that our supply chain and procurement processes are ethical, free from worker abuse and exploitation and provide safe working conditions. This policy will be approved and be available publicly during 23/24.
Our existing recruitment policies set out the processes that cover the recruitment of both our temporary and permanent employees. The overall approach is governed by compliance with legislative and regulatory requirements and the maintenance and development of good practice in the fields of employment.
Our recruitment processes are robust and adhere to safe recruitment principles. We have a range of policies and procedures to protect staff from poor treatment and/or exploitation which comply with all respective laws and regulations. This includes policies on recruitment, pay and equality, diversity and inclusion.
In addition to this, we have clear systems and polices in place to encourage the reporting of concerns, speaking up and the protection of whistleblowers Our policies such as Safeguarding Adults and Children, Dignity at Work, Grievance procedure and Freedom to Speak Up policy provide additional platforms for our employees to raise concerns about poor and inappropriate working practices. We have a number of dedicated Freedom to Speak Up Guardians and Executive and Non-Executive Director leads for Freedom to Speak Up. Whilst these are not exclusively for the purpose of raising concerns for modern slavery and human trafficking, their remit covers any issues linked to this.
Risk Assessment and Management
A category level environmental, social and governance risk assessment has been carried out for our spend profile. This assessment included the identification of modern slavery risks across the lifecycle of goods and services purchased on criteria including the risk of forced labour, child labour, working conditions and discrimination. The following purchasing categories were identified as high risk:
- Construction.
- Information Technology (IT).
- Food and Catering.
- Medical Equipment.
- Textiles (clothing, bed linen etc).
- Waste Management.
- Temporary Staff and Recruitment Services.
Due Diligence Process
Our robust recruitment processes are in line with relevant employment legislation and adhere to safe recruitment principles. We follow strict pre-employment checks on all directly employed staff, Bank Workers and others undertaking work within our organisation. These include identification, right to work, qualification, registration and reference checks. Our pre- employment checks are in line with the NHS employment check standards and our Resourcing functions oversee fair and equitable recruitment and selection practices.
We align to nationally negotiated NHS pay rates and terms and conditions of employment. We consult and negotiate with recognised Trade Unions on proposed changes to working arrangements, policies and contractual terms and conditions.
Only approved frameworks are used for the recruitment of temporary agency staff. All providers are audited to provide assurance that pre-employment clearance has been obtained in line with the NHS Employment Check Standards.
We also provide access to learning and development opportunities and provide a comprehensive staff benefits and health and wellbeing offer.
As part of our standard checks within our procurement process, bidders are checked (where relevant) for their compliance with the Modern Slavery Act (2015).
We have been engaging with our category leads and main suppliers within our IT category to raise awareness and understand the maturity levels of work across the sector in this area. We aim to replicate this approach for other high-risk categories.
We will use this to inform the due diligence processes we need to implement. We recognise that our current due diligence processes are not adjusted to reflect the risk associated with the purchase involved. We will develop our process over the coming year to ensure that our due diligence processes are proportionate to the risk posed by the purchase in question.
KPIs to measure effectiveness of steps being taken
We have a robust governance mechanism for monitoring the delivery of the commitments set out in our policies. The Sustainable Procurement Workstream as part of the ICS Green Plan Implementation Group is made up of representatives from all three organisations. It is responsible for driving the delivery of the commitments and reporting on their progress to the Green Plan Steering Group that sits above this and feeds into Executive and Board level activities at each organisation.
Training on Modern Slavery and Human Trafficking
We provide advice, training and support about modern slavery and human trafficking to all staff through our safeguarding children and adults mandatory training, our safeguarding policies and procedures and our safeguarding teams.
We also ensure that all staff receive a comprehensive induction programme which includes information on, and guidance regarding modern slavery and human trafficking.
Specifically within our procurement function, B&WPC has been developing a capability framework for all procurement job roles. This framework will be completed in the next financial year and will include modern slavery and social value.
A list of available training resources, including those on modern slavery, has been complied and is available for B&WPC staff to access.
UHBW and NBT plan to develop education resources and make them available to their staff and, over the coming year, map the key stakeholders who are involved in the procurement and contract management process to focus engagement efforts and further drive our shared commitment to eradicate modern slavery and human trafficking from our supply chains.