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Modern slavery transparency statement

Modern slavery is a complex crime that takes a number of different forms. It encompasses slavery, servitude, forced and compulsory labour and human trafficking. Anyone can become a victim of modern slavery and in all types of exploitation, victims can be of any age, sex, gender, nationality, ethnicity or background.

Even though most people think that slavery only exists overseas, modern slavery in the UK is thriving. In Derbyshire, there were 129 reported cases of modern slavery in 2022. Nationally, the Home Office received 16,938 referrals of potential victims of modern slavery in 2022, which represents a 33% increase in referrals compared to the preceding year (12,706). This year saw the highest number of annual referrals since the national referral mechanism began in 2009, highlighting that awareness raising and training are having a positive impact on detection but that perhaps the true scale of modern slavery is yet to be realised. It is estimated that the average cost per modern slavery crime is £328,720 (Home Office 2018 to 2017).

This statement and our commitment

This statement sets out our actions to understand all potential modern slavery risks related to its business and to detail the steps put in place to ensure that there is no slavery or human trafficking in its own business or its supply chains. This statement relates to actions and activities for the financial year ending 31 March 2023 meeting the requirements of Section 54 of the Modern Slavery Act 2015.

We're committed to improving its practices to identify and combat this crime, both externally with our partners and internally through co-operation between services across the organisation. As a public sector organisation, an employer, community leader and a procurer is committed to taking a preventative approach to modern slavery and human trafficking within its corporate responsibilities and activities. As such, this statement covers our direct employees, agency workers, relief staff and services delivered on our behalf by third party organisations and as part of our supply chains. We believe that because it has many suppliers and is an influential purchaser in Derbyshire, it is important to publish a statement that is transparent about the actions it will be taking to respond to the Modern Slavery Act 2015. As well as being published here, this statement will be published on the government’s modern slavery statement registry.

We acknowledge its duty to notify the Secretary of State of suspected victims of slavery or human trafficking as required by section 52 of the Modern Slavery Act 2015. We also note our responsibility under the national referral mechanism as a “first responder” and is committed to training internal and external partners to be best placed to identify potential signs of modern slavery and be confident in the reporting concerns and taking action to safeguard potential victims.

We are a lead member of the Derby and Derbyshire Modern Slavery Partnership (DDMSP), a multi-agency partnership whose focus is to protect the public by identifying and safeguarding victims and potential victims of modern slavery / human trafficking and by relentlessly targeting those who enable or facilitate this criminality.

Organisational structure

We're a principal local authority for the purposes of the Local Government Association (LGA) 1972. We provide a wide range of services to support residents and businesses in Derbyshire to thrive, these services are delivered directly by us and through external organisations. We've identified 4 strategic priorities to direct improvement activity over the coming years, these are:

  • resilient, healthy and safe communities
  • high performing, value for money and resident-focussed services
  • effective early help for individuals and communities
  • a prosperous and green Derbyshire

We're currently split into 4 directorates:

  • adult care
  • children’s services
  • place
  • corporate services and transformation

Derbyshire is a largely rural county with many sparsely populated areas alongside larger built-up urban conurbations and has a county population of 802,694 people. We have responsibility for providing a wide range of statutory and discretionary services for its residents, businesses, visitors and partners. We manage a wide range of services which are delivered directly and through external contractors.

Over 13,000 people work for us (excluding schools), with a budget of over £500 million per annum, making it one of the largest employers in Derbyshire. Many jobs range across a number of services, such as:

  • social care
  • education
  • children's centres and nurseries
  • highways
  • street lighting
  • community safety
  • libraries
  • waste management
  • trading standards
  • economic development
  • tourism
  • countryside parks

We procure goods, services and works from various suppliers and this is governed by its financial regulations and standing orders and also Public Contract Regulations 2015.

Countries of operation and supply

We only operate within the United Kingdom. We would expect all suppliers of goods or services to have their own policy relating to working practices or modern slavery, or for evidence to be available to ensure their standards are in accordance with our expectations. We would request that our suppliers ensure the same of their own supply chains. We have limited contact with overseas sourcing, but does require its suppliers to be aware of their own supply chains, as they can be several layers deep. Due to the nature of our business, the risk of slavery and human trafficking is considered low, however we remain vigilant to any potential risks.

High-risk operations

Typical high-risk sectors for modern slavery include agriculture, leisure, hospitality, catering, cleaning, clothing, construction and manufacturing. We've previously considered that, due to the nature of its business and the policies / processes that are in operation, there are no areas of its business that are at high risk of slavery or human trafficking. However, the current contracts register highlights that we commission a number of labour-reliant companies in the construction sector.

We also contract 62 private, voluntary and independent (PVI) nursing homes, 79 PVI residential homes and 54 PVI home care agencies, with this number set to grow. Modern slavery charity “Unseen” has recognised the care industry as one of the fastest growing emerging-risk industries. For more information on our procurement, see the procurement and supply chains section.

Responsibility and key contacts

Responsibility for our anti-slavery initiatives is as follows.


These are developed by officers employed by us and are then agreed by the relevant board or committee.

Risk assessments

These will be undertaken by officers within the relevant service area with support from human resources and procurement / commissioning support as required.

Our whistleblowing policy also extends to any other individual who wants to raise an allegation of wrongdoing, malpractice or illegality. This could include consultants, contractors, sub-contractors who are engaged in work for us and includes, councillors, volunteers or anyone who uses our services or a member of the public.

Investigations / due diligence

Any concerns regarding modern slavery or human trafficking should be raised with the community safety unit who will involve the Director of Legal and Democratic Services as required. We actively work to ensure the safeguarding of all vulnerable people and recognises at-risk groups including workers in certain roles such as cleaning and care work, and large numbers of adults in multiple occupancy domestic properties. We expect any employee / elected member who may witness or suspect criminality to report their concerns to their manager and / or the police.


These are developed by our officers and are then agreed by the relevant board or committee.

Risk assessments

These will be undertaken by officers within the relevant service area with support from human resources and procurement / commissioning support as required.

Investigations / due diligence

Any concerns regarding modern slavery or human trafficking should be raised with the Director of Legal and Democratic Services in the first instance. We actively work to ensure the safeguarding of all vulnerable people and recognises at-risk groups including workers in certain roles such as cleaning and care work, and large numbers of adults in multiple occupancy domestic properties. We expect any employee / elected member who may witness or suspect criminality to report their concerns to their manager and/or the police. Whistleblowing requirements included in contract for at risk services.

Receiving intelligence and initiating partner response

Our community safety unit has the responsibility for managing incoming intelligence of suspected modern slavery cases relating to victims and offenders. The community safety unit will work with partners in the Derby and Derbyshire Modern Slavery Partnership (DDMSP) to investigate potential cases, pursue offenders and support victims, sharing intelligence where appropriate. The community safety unit will also take a lead role in raising awareness of modern slavery with Derbyshire residents.

Relevant plans and policies

We adhere to the Modern Slavery Act 2015 and aligns its strategic working with the government’s modern slavery strategy, which takes a 4P approach to combating this crime through the actions of pursue, prevent, protect and prepare.

We review our policies and procedures on an ongoing basis to ensure they remain compliant and fit for purpose. The following policies and procedures are considered key in the council meeting the requirements of the Modern Slavery Act 2015 and preventing slavery and human trafficking in its operations.

Council Plan 2021 to 2025

The Council Plan is a key document that describes our priorities, resources and how progress is monitored. The plan shows how we will work together with our partners and communities to be an enterprising council, delivering value for money and enabling local people and places to thrive.

Our strategic approach governs how we work, as a council, with and for communities, and in collaboration with partners. 3 key areas of activity are taking the approach forward:

  • Enterprising Council
  • Thriving Communities
  • Vision Derbyshire

Together these key areas place us in a stronger position to understand, to adapt and respond to future challenges and to bring about the changes needed to ensure future success.

Protecting individuals and responding effectively to modern slavery contributes to our priorities which are detailed in the Council Plan, as well as our outcomes.

Our priorities:

  • resilient, healthy and safe communities
  • effective early help for individuals and communities
  • high performing, value for money and resident focussed services
  • a prosperous and green Derbyshire

Our outcomes:

  • happy, safe and healthy people
  • resilient, thriving and green communities
  • a strong, diverse and clean economy
  • great places to live, work and visit
  • high quality public services

Modern slavery is a multifaceted issue requiring a co-ordinated partnership response and encompassing many aspects. Our plan highlights the importance of working together to address issues such as fraud, financial abuse and ensuring that individuals and communities are supported and protected.


We embrace its responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and adults at risk. We have a comprehensive safeguarding policy and procedure which all staff and elected members are expected to read and work within. We work within multi-agency partnerships namely the Derbyshire Safeguarding Adults Board and the Derby and Derbyshire Safeguarding Children Partnership to protect and safeguard people, this includes complying with the safeguarding policies and procedures for adults and children.

More information about modern slavery is also made available in the practice guidance on the Derby and Derbyshire Safeguarding Adults Board website.

HR / employment policies and practices

We remain highly committed to advancing equality, eradicating unfair treatment, and promoting good relations across and between all our communities. We have clear and rigorous HR policies and procedures and high standards for employees that minimise the risk of any form of modern slavery existing within the organisation.

We have procedures and policies in place on all major employment issues, for example, disciplinary, grievance, harassment and bullying, code of conduct, confidential reporting procedures, as well as other policies that support fair treatment of employees including attendance management and ill health capability, performance capability, staff appraisals and recruitment and selection.

Our management guidance supplements our HR policies and procedures to make sure they are applied consistently and fairly to employees and the service in different circumstances. Policies are constantly reviewed and we endeavour to refresh these at least every 3 years to ensure they are fit for purpose.

Our recruitment policy and processes are transparent and reviewed regularly. This includes robust procedures for vetting new employees, which ensures they are able to confirm their identities and qualification (where necessary) and they are paid directly into an appropriate, personal bank account. To comply with legislation all prospective employees are asked to supply evidence of their eligibility to work in the UK. References are also requested and followed up. We use a job evaluation scheme, thereby ensuring that all employees are paid fairly and equitably. All new and changed jobs are evaluated by a panel of trained evaluators including trade union representatives.

Agency workers

We use only reputable employment agencies to source labour and verifies the practices of any new agency it is using before accepting workers from that agency. For temporary resource requirements which are not related to business services, we have an arrangement with Comensura for the supply of agency staff which simplifies the way agency workers are hired and enables us to manage our use of agency workers more effectively. We have chosen to adopt the national framework procured by the Yorkshire Purchasing Organisation (YPO) for the contract between itself and Comensura. Details of the expectations placed upon Comensura relating to modern slavery transparency are set out in the Yorkshire purchasing organisation template agreement with Comensura.

In addition to this, we expect the agencies that Comensura uses to follow the government code of practice when recruiting international candidates to a role in the UK health and social care sector.

Employee code of conduct

Our code of conduct for employees makes clear the actions and behaviours expected of them when representing us. We strive to maintain the highest standards of employee conduct and ethical behaviour and breaches are investigated. The code also applies to contractors, agency staff, volunteers and those on student / work experience placements and anyone working on our behalf. In addition, all registered social workers must operate in accordance with the codes of conduct in relation to their professional registration.


Our procurement strategy details the steps taken to ensure that our county procurement function is best able to support the Council Plan, the Enterprising Council programme, and all applicable legislative requirements. It is informed by our procurement values and principles. We follow the National Procurement Strategy, which sets out local government’s ambitions and priorities for the next 4 years, focusing on the 3 core themes - leadership, behaving commercially, and achieving community benefits.

The government have also produced a guidance document to help the public sector to tackle modern slavery in government supply chains, which we'll use to inform best practice relating to its supply chains.

Confidential reporting (whistleblowing)

We encourage all our employees, customers and other business partners to report any concerns related to our direct activities or supply chains. Our whistleblowing policy is intended to enable individuals or organisations to disclose information about malpractice internally and to provide them with protection from subsequent victimisation, discrimination or disadvantage. This will assist in detecting and deterring malpractice and, by demonstrating our accountability, maintain public confidence and a good reputation.

Equality and diversity

Our equality and diversity policy is a declaration of its commitment to making equality an integral part of our business. As a major employer and provider of services we are committed to advancing equality of opportunity and providing fair access and treatment in employment and when delivering or procuring services. To support our commitment to equality, we embed equality and diversity into our everyday business. We expect all our councillors, managers, employees and contractors to treat everyone with dignity and respect and provide the best possible standards of service to all our customers.

Our equality, diversity and inclusion strategy (2022 to 2025) makes reference to our modern slavery commitments as an organisation, namely to:

  1. Jointly commission pre-national referral mechanism support provision for victims of modern slavery.
  2. Provide more victims of modern slavery with an understanding of the national referral mechanism.
  3. Provide ongoing awareness raising for staff, partner agencies and voluntary sector on modern slavery.

Procurement and supply chains

We're one of the biggest purchasers of goods and services in Derbyshire, with an annual budget of over £500 million. We face increasing pressure to source goods and services that represent value for money, whilst meeting its own procurement priorities and aligning with the Chartered Institute for Procurement and Supply (CIPS) best practice. Our procurement is also guided by the Cabinet Office Commercial Regulations. Currently, the value of live contracts with us exceeds one billion pounds, such is the reach of the organisation across many different sectors as follows:

  • economy and regeneration £19 million
  • highways £94 million
  • transport £73 million
  • environment £94 million
  • estates, property, facilities and maintenance £56 million
  • ICT £32 million
  • children's services £203 million
  • public health £112 million
  • adult care £287 million

Procurement contractors and service providers

Our procurement strategy sets out a clear vision and the key organisational outcomes that implementation of the strategy is looking to deliver. We expect our providers and suppliers to have safeguarding policies, procedures and training in place. From April 2016, all tender processes require bidders that have an annual turnover of more than £36 million to provide confirmation that they are compliant with the Modern Slavery Act 2015. We're committed to ensuring that its contractors adhere to all relevant legislation and the highest standards of ethics, and requires its suppliers adhere to the suppliers and services terms and conditions.

Risk-assessing and mapping of supply chains

The nature of global supply chains for goods and services is increasingly complex. Modern slavery can be found anywhere in the supply chain, but it tends to be much worse further down the value chain, where there is little visibility and where the poorest and most vulnerable work. In order to help eradicate modern slavery, the government has provided statutory guidance on transparency in supply chains for those organisations with an annual turnover of £36 million or more.

As part of its supplier questionnaire, require contractors to confirm that they comply with the Modern Slavery Act 2015 in relation to its supply chains, putting the emphasis on the contractor to ensure compliance. We will look to put additional measures in place to identify the contracts at greatest risk of facilitating modern slavery, so that proportionate engagement and compliance auditing can occur. As a contract condition, contractors should notify us whenever there are any changes to their supply chains. Therefore, the onboarding checks that we make at the start of the contract lifespan should provide a basic level of reassurance until we're notified otherwise.

Working with suppliers and due diligence

Due diligence is the process of identifying human rights risks in an organisation’s supply chains, preventing them from occurring or mitigating those risks and reducing their impact. It includes planning remedial or corrective action. Human rights due diligence is not about the risk to the organisation, it is about the risk to the people involved in providing services and producing goods in supply chains. (Olga Martin-Ortega and Andy Davies (2017), Protecting Human Rights in the Supply Chain. A Guide for Public Procurement Practitioners, CIPS Knowledge, Page 12.)

As part of our initiatives to identify and mitigate risk, we undertake due diligence when considering taking on new suppliers or contractors, including taking measures such as:

  • a risk-assessment to understand the contractors and sub-contractors that are utilised. All contractors must answer the mandatory part 1 and 2 of the supplier questionnaire
  • specific questions relating to modern slavery on the supplier questionnaire during the tender process, for companies with an annual turnover of more than £36 million

Human rights due diligence is also a key concept in the UN Guiding Principles on Business and Human Rights (UNGPs). The government has set out a clear expectation in the National Action Plan on implementing the UN Guiding Principles on Business and Human Rights. UK organisations should respect internationally recognised human rights wherever they operate and treat the risk of causing or contributing to gross human rights abuses as a legal compliance issue.

Suppliers selection questionnaire

An extract from this document, which relates to modern slavery, can be found in the suppliers selection questionnaire.

Supplier contract management and social audits

Our modern slavery diligence does not end at the offering of a contract. A continuous cycle of risk assessment, supplier engagement and contract management is crucial to keep on top of emerging risk and work with suppliers to mitigate this. Contract reviews are undertaken by departmental contract owners.

County procurement is developing a contract management compliance team who will provide strategic support and development of appropriate contract management procedures, ensuring that key policies and standards are met by suppliers. The team is still recruiting and developing, and once established will work with the community safety unit to develop modern slavery compliance measures that can be adopted across our organisation in a manner that is proportionate for us and the supplier. These contract management procedures should be put in place to ensure that suppliers actions are true to their policies and the commitment they made prior to contract commencement, and to work in partnership to improve practice.


Through our community safety function, we, along with Derby City Council, lead the Derby and Derbyshire Modern Slavery Partnership. Bringing together public, private and voluntary organisations to disrupt perpetrators and support victims of human trafficking and modern-day slavery in Derby and Derbyshire and further afield. We strive for a community wherein awareness of all forms of human trafficking and modern-day slavery is commonplace and that across all sectors people work collectively to eradicate its existence in our community.

Any investigation and / or victim support in relation to modern slavery is conducted through the Derby and Derbyshire Modern Slavery Partnerships Multi Agency Tactical Response Agreement.

We comply with Section 52 of the Modern Slavery Act 2015 - Duty to Notify. Incidents of modern slavery are referred to the police and the designated modern slavery lead within community safety, who is also our direct link to Derbyshire Constabulary’s Modern Slavery Human Trafficking Unit, email and the Serious Organised Crime Exploitation Board (SOCEx).

Senior procurement management attend the East Midlands Head of Procurement Forum, to keep informed of best practice regionally. They also received updates from the Local Government Association.

Derby and Derbyshire modern slavery partnership

The work of the Derby and Derbyshire modern slavery partnership is driven by a vision to protect the public by identifying and safeguarding victims and potential victims of modern slavery / human trafficking and by relentlessly targeting those who enable or facilitate this criminality. This vision is driven by a 3-year Strategy (2020 to 2023), which focuses on the 4 strategic themes - pursue, prevent, protect and prepare and are in line with Government’s Modern Slavery Strategy 2015, whereby reducing the threat and vulnerability to victims in Derbyshire as follows.

Reducing threat

Prosecuting and disrupting individuals and groups responsible for modern slavery (pursue / prevent).

Reducing vulnerability

Protecting vulnerable people from exploitation and reducing the harm caused by modern slavery through enhanced support (protect / prepare).

The partnership manages several subgroups to fulfil these strategic themes.

Pursue / prevent

A tactical and enforcement subgroup which identifies and responds to modern slavery related offences across Derby and Derbyshire. Attendees are made up of first responders (including ourselves) and other organisations with law enforcement powers.

Protect (adults) and protect (children)

Areas of business include working with / for individuals who have entered / exited the national referral mechanism and with those individuals where entering the national referral mechanism is not an option. The subgroup is made up of a range of first responders and those agencies with responsibilities to protect adults and children, for example, local authorities, Police, British Red Cross, Hope for Justice, Barnardo’s, Rebuild.

Awareness raising / training

This subgroup seeks to improve the understanding of the roles and responsibilities within organisations when dealing with instances of slavery and trafficking, improving public understanding of slavery and trafficking (including the signs to look for), and promoting training within organisations particularly around recognising and responding to slavery and trafficking.

We're represented by several officers on the subgroups including officers from community safety, trading standards, emergency planning, adults safeguarding and children's safeguarding. We've been involved in awareness raising around modern slavery through its social media forums such as X, and Facebook for example.

Emergency planning

We have a duty to be part of the multi-agency response to the investigations into modern slavery and trafficking by providing assistance to victims (including facilitating and resourcing a place of safety) when they are taken to such a place during these investigations. We have a significant role to play in the setting up of emergency reception centres. The British Red Cross publication “First Steps to Safety: The role of reception centres in supporting people out of exploitation” is a useful piece of research and advice for professionals in ensuring the safety of victims rescued from exploitation.

Serious organised crime and exploitation (SOCEx)

A multi-agency serious organised crime and exploitation (SOCEx) thematic structure has been implemented by Derbyshire Police. Allowing operational, tactical and strategic oversight of exploitation and serious organised crime. SOCEx is underpinned by information and intelligence sharing and aides the identification, disruption and enforcement against serious organised crime and modern slavery networks in Derbyshire.

Training and awareness raising

We have a programme of training of training for all employees. Safeguarding awareness training (this is role specific), enables officers in community-facing roles to identify and know how to report incidents of abuse and neglect, including modern slavery and human trafficking. Our community safety unit provides a range of free e-learning and webinar training on modern slavery, the training is available to all employees, partner agencies, charities and the third sector.

A substantial amount of training has been delivered to voluntary, statutory and private sector stakeholders. The training helps delegates gain an increased understanding of what modern slavery is, signs to look out for and develop skills in supporting people who may be victims of modern slavery in Derbyshire. Delegates gain an understanding of:

  • what modern slavery is
  • the scale and scope of modern slavery and human trafficking
  • where modern slavery happens
  • signs to look out for
  • how modern slavery affects individuals
  • how to raise concerns and gain help for people affected by modern slavery
  • the national referral mechanism and local procedures

A dedicated section on modern slavery is available on the Safer Derbyshire website.

The Home Office e-learning for modern slavery first responders is also available for all our social care staff (adults and children), the training provides an understanding of what to do when looking to refer a victim into the national referral mechanism.

In the 12 months from 1 April 2022 to 31 March 2023, we've delivered the following awareness raising training to 928 delegates:

  • 234 delegates completed e-learning training, includes 41 delegates completed the first responders (adults and child) e-learning training
  • 606 delegates completed e-learning training for criminal exploitation and county lines
  • 88 delegates from a range of partner agencies have attended a modern slavery webinar

We recognise that certain employees within the organisation should be required to complete training on modern slavery. To date, this has focussed on customer facing roles. We are currently reviewing training and as part of this review; consideration will be given to prioritising training on modern slavery for those staff responsible for supply chain management and those working in our HR and procurement teams. Further awareness raising by us has included:

  • a multi-agency webinar as part of Derbyshire safeguarding adults week 2022
  • co-publishing the Derby and Derbyshire modern slavery partnership annual report
  • supports national initiatives such as the Clewer Car Wash and Farm Work app

Performance indicators

We will measure the effectiveness of the steps that we are taking to ensure that slavery and / or human trafficking is not taking place within our business or supply chains through:

  • communication between all our relevant departments to discuss emerging modern slavery issues and co-ordinate our practice
  • investigating all allegations, complaints, whistleblowing reports received from employees, the public, or law enforcement agencies regarding modern slavery and human trafficking
  • requiring staff including those working in supply chain management, first responders, procurement and HR to have completed training on modern slavery
  • measuring the number of high-risk contracts with specific modern slavery contract management processes in place, and work towards putting additional proportionate engagement practices in place for these
  • working with our statutory partners to further develop the modern slavery problem profile for Derby and Derbyshire

We will know the effectiveness of the steps that we are taking to raise awareness of modern slavery through:

  • the number of internal staff, partners and voluntary sector individuals undertaking the community safety e-learning and webinar training on modern slavery and first responder training
  • monitoring the number of national referral mechanism referrals made from our first responders
  • monitoring the number of duty to notify (MS1) made from our first responders
  • post-training evaluations to measure participants’ confidence in identifying signs of modern slavery and their understanding of the process of reporting and accessing support
  • undertaking community awareness programmes for adults and children

What we've done

The community safety unit has worked closely with the resettlement team to raise awareness with new arrivals about employment rights and responding to exploitation concerns. This has required close partnership working to be proactive in our messaging and to respond quickly to any incidents.

We've commissioned Hope for Justice along with Derby City Council to provide pre-national referral mechanism support provider for potential victims of modern slavery.

As part of the DDMSP, we've worked with Safer Derbyshire Research and information analysts to create a series of exploitation surveys distributed to first-responder partners, in order to refresh the problem profile for modern slavery in Derbyshire.

In light of national priorities and new legislation, the Derbyshire Safer Communities Board and Derby City Safer Board reviewed their partnership arrangements and introduced a new thematic community safety structure. The structure is made up of 8 thematic boards and reflects joint county and city meetings. The Serious Organised Crime and Exploitation Board (SOCEx) also includes modern slavery and county lines. As part of the DDMSP, we've worked with police colleagues to integrate modern slavery into a wider partnership “SOCEx” multi-tier governance structure whilst maintaining the pursue / prevent and protect / prepare subgroups.

The community safety unit has completed the Shiva Foundation modern slavery scorecard and Local Government Association's modern slavery maturity matrix to map progress as an organisation and highlight gaps for future development.

Next steps

We've created an organisational action plan in relation to this statement, to highlight important actions that require driving forward in this coming year, this includes:

  • create and share specific guidance for first responders arising from an increase in care home labour exploitation concerns and embed multi-disciplinary team meetings to respond to this arising issue
  • improve links on our staff website to access immediate guidance and support about modern slavery
  • improve the procurement strategy to include reference to modern slavery responsibilities
  • collaboration between our contract compliance team (once established / resourced) and community safety unit to create additional modern slavery risk-assessments and contract compliance procedures


This statement is made pursuant of Section 54 of the Modern Slavery Act 2015 and constitutes our modern slavery statement for the financial year ending 31 March 2023. This statement will be registered on the UK government modern slavery statement portal and will be updated on an annual basis.

List of appendices

Appendix 1 - modern slavery extract from suppliers selection questionnaire.

Appendix 2 - extract from Yorkshire Purchasing Organisation (YPO) template agreement - utilised for modern slavery purposes between ourselves and Comensura for the supply of temporary workers.

Appendix 3 - summary of our progress and next steps arising from Shiva Foundation’s modern slavery scorecard and LGA modern slavery maturity matrix.

Suppliers selection questionnaire

All forms of supplier selection questionnaire used within county procurement follow the government guidance procurement and policy Note (PPN) 03/23. The PPN 03/23 replaces PPN08/16 and applies to all contracting authorities in England and contracting authorities in Wales and Northern Ireland that exercise wholly or mainly reserved functions. The revised supplier selection questionnaire includes the assessment of supplier awareness and implementation of the Modern Slavery Act 2015.

Question 7.1

You are a relevant commercial organisation subject to Section 54 of the Modern Slavery Act 2015 if you carry on your business, or part of your business in the UK, supplying goods or services and you have an annual turnover of at least £36 million. If you are a relevant commercial organisation, please:

  • confirm that you have published a statement as required by Section 54 of the Modern Slavery Act
  • confirm that the statement complies with the requirements of Section 54 and any guidance issued under Section 54

Question 7.2

Your latest published statement must be available electronically, please provide:

  • the web address, with precise reference to the documents

Question 7.3

If you have answered yes to questions in 7.1 or if you have answered No to question 7.2, please explain what measures have been taken to demonstrate your reliability despite the existence of a relevant ground for exclusion.

All answers are scored on a pass / fail basis.

Where the supplier is a commercial organisation subject to Section 54 of the Modern Slavery Act 2015, contracting authorities should set appropriate selection criteria and methodology by which to assess compliance. As compliance with the Modern Slavery Act is only relevant to UK bidders, criteria can be broadened to relate to non-UK bidders by asking them to provide a link to published modern slavery statements in their own jurisdiction or where these are not required, to a relevant company document containing the same type/level of information. A pass / fail selection criterion may be set that either:

  • The bidder must have complied with the requirements contained within Section 54 of the Modern Slavery Act 2015 and associated guidance including information relating to:
    • the organisation’s structure, its business, and its supply chains
    • its policies in relation to slavery and human trafficking
    • its due diligence processes in relation to slavery and human trafficking in its business and supply chains
    • the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk
    • its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate
    • the training and capacity building about slavery and human trafficking available to its staff


  • Where the bidder is a non-UK supplier, the bidder must have provided a link to an equivalent statement or document which demonstrates information relating to a to f

Alternatively, if neither of the criteria are met, but the bidder provides a satisfactory explanation and assurances that either requirement will be met before contract award, this will be sufficient to pass the selection criterion but will be verified prior to contract award.

The supplier selection questions also include instruction to bidders regarding the applicability of response to consortium members or subcontractors as follows:

“If you are bidding on behalf of a group (consortium) or you intend to use sub-contractors, you should complete all of the selection questions on behalf of the consortium and / or any sub-contractors”.

Modern slavery in the Yorkshire Purchasing Organisation (YPO) Framework Agreement - Comensura

The following is an extract of the YPO framework agreement which sets out Comensura’s expectations of agencies who supply relief staff to us:

The supplier shall:

  • 15.1.1. In performing its obligations under this Agreement, ensure that each of its suppliers and subcontractors shall comply with:
  • all applicable laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015; and
  • the supplier code of conduct contained at Schedule 3
  • 15.1.2. represent and warrant that at the date of this agreement:
    • neither the supplier nor any of its officers, employees or other persons associated with it has been convicted of any offence involving slavery and human trafficking; and
    • having made reasonable enquiries, to the best of its knowledge, has been or is the subject of any investigation, enquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence of or in connection with slavery and human trafficking
  • 15.1.3. implement due diligence procedures for its own suppliers, subcontractors and other participants in its supply chains, to ensure that there is no slavery or human trafficking in its supply chains
  • 15.1.4. notify Comensura as soon as it becomes aware of:
    • any breach, or potential breach, of the supplier code of conduct; or
    • any actual or suspected slavery or human trafficking in a supply chain which has a connection with this agreement
  • 15.1.5. upon request from the supplier shall prepare and deliver to Comensura, a slavery and human trafficking report setting out the steps it has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business
  • 15.1.6. the supplier shall maintain a complete set of records to trace the supply chain of all services provided to Comensura in connection with this agreement and implement steps to monitor its compliance with the supplier code of conduct and provide evidence of the same to Comensura upon request
  • 15.2. The supplier shall, immediately it becomes aware, advise Comensura of any breach by the supplier of clause 15.1 and provide details of the same
  • 15.3. Breach of this clause 15 shall be deemed a material breach of this agreement

Summary of our progress and next steps arising from Shiva Foundation’s modern slavery scorecard and LGA modern slavery maturity matrix

This resource has been created in collaboration by Shiva Foundation, Stop The Traffik and the Mekong Club, with funding from the Home Office. The scorecard allows local authorities to easily assess their modern slavery risk across a number of key thematic areas and provide advice on how they can improve. We've committed to using this framework and accompanying guides as a measurement of the organisation’s competency. In summary, we scored strongly in:

  • collaboration with other agencies to tackle modern slavery and support victims
  • in-depth training of frontline staff
  • having pathways for staff to report concerns
  • having a clause in the procurement process that requires suppliers to tackle modern slavery

Over the next year, some of the next steps for us to take as highlighted by the scorecard, and detailed in our transparency statement are:

  • improve supplier engagement and auditing processes
  • improve accessibility of pathways to support, namely signposting on our staff website

LGA modern slavery maturity matrix

The Local Government Association created this modern slavery maturity matrix to provide a framework for councils to assess their current progress and plan future activity on modern slavery.

The first 2 sections focus on how we manage our modern slavery work by considering the themes of leadership, resources and capacity needed to effectively manage modern slavery work across a council. The subsequent sections focus on identifying, referring and supporting victims, disruption and prevention and mitigating the risk of modern slavery in council supply chains.

For each element within the different themes, councils can assess their current progress. Progress levels are identified as either basic first steps, early progress, substantial progress or mature. Some of the areas that we scored strongly in are:

  • service design and a core cohort of staff up-skilled to lead on modern slavery cases
  • collaborative and proactive work with partner organisations at strategic and operational level
  • jointly commissioning services for victim support
  • specific strategy for council disruption and prevention activity, distinguishing between work with victims, communities and perpetrators

Over the next year, some of the next steps for us to take as highlighted by the scorecard, and detailed in our transparency statement are:

  • strategy and planning - include modern slavery in the “Council Plan” and the procurement strategy
  • utilise a series of surveys and data to create a problem profile of exploitation for the county
  • improve cross-council co-ordination of modern slavery matters, bringing departments together in collaboration

For further information regarding this statement or copies of previous years modern slavery statements, email or