What is modern slavery?
Modern Day Slavery is a violation of a person’s human rights. It can take the form of human trafficking, forced labour, bonded labour, forced or servile marriage, descent-based slavery, and domestic slavery. A person is in modern slavery if they are:
- Forced to work through mental or physical threats.
- Owned or controlled by an “employer,” usually through mental or physical abuse.
- Dehumanised, treated as a commodity, or sold or bought as “property.”
- Physically constrained or has restrictions placed on their freedom of movement.
NHS West Yorkshire Integrated Care Board (ICB) remains sensitive to the risk of modern slavery in our supply chains. We are committed to acting responsibly and with integrity in all our business relationships and continue to take measures to implement and enforce effective systems and processes to ensure that modern slavery and human trafficking are not taking place anywhere within our control or influence.
Our organisation and supply chains
As a local leader in commissioning for health care services (including acute, community, mental health, learning disability and primary care services) in Bradford District and Craven, Calderdale, Kirklees, Leeds, and Wakefield District – covering a population over 2.4 million and as an employer, the West Yorkshire ICB provides the following statement regarding its commitment to and efforts in preventing modern slavery and human trafficking practices in the supply chain and employment practices.
Our approach and commitment
As commissioners of care and partners of Safeguarding Adult Boards and Safeguarding Children Partnerships, West Yorkshire ICB plays a crucial role in supporting the work and strategic priorities in tackling modern slavery and human trafficking.
The ICB fully supports the Government's objective to eradicate modern slavery and human trafficking and recognises the significant role the NHS must play in both combatting it and supporting victims. We are committed to ensuring commissioned services and supply chains comply with relevant legislative requirements.
We acknowledge and accept that we are responsible for lawfully, fairly, and honestly conducting our business.
Our commitment to preventing modern slavery and human trafficking
The ICB aims to address this risk through:
- Being committed to ensuring there is no modern slavery or human trafficking within our commissioned services and/or supply chains in any part of our business.
- Adhering to National NHS Employment Standards includes checks on an employee's address as part of any check, the right to work in the UK and suitable references.
- Have in place systems to encourage the reporting of concerns and the protection of whistle-blowers.
- Continue to build relationships with our providers and clarify our business behaviour expectations. We expect local, national, and international supply chains to have suitable anti-slavery and human trafficking policies and processes in place.
- Include modern slavery and human trafficking within NHS West Yorkshire ICB Safeguarding Policy and associated policies of PREVENT and Mental Capacity Act and Deprivation of Liberty Policy.
- Being an active partner of the West Yorkshire Anti-Slavery Partnership, where joint initiatives are developed and good practices are shared.
- Provide accessible modern slavery and human trafficking information and training for our workforce.
Our arrangements for preventing modern slavery and human trafficking
West Yorkshire ICB aims to be as effective as possible in ensuring modern slavery and human trafficking do not take place in any part of our business by:
- Ensuring the response to Human Trafficking and Modern Slavery is coordinated through membership of the Place-based Safeguarding Partnerships for both children and adults on the appropriate Communities Modern Slavery Partnership meeting and West Yorkshire Network Meetings.
- Ensuring communication with our commissioned Providers in the supply chain and being aware of their understanding of, and compliance with, our expectations about NHS terms and conditions, including modern slavery and human trafficking.
- Deploying robust recruitment processes that adhere to safer recruitment principles, including identity, right-to-work, and criminal record checks, in line with the ICB Recruitment and Selection Policy.
- Having policies in place, including Freedom to Speak Up, grievance, dispute resolution, equality, diversity, and inclusion, to demonstrate our commitment to supporting our employees’ raising concerns about poor working practices.
- Ensuring our procurement policy outlines how we procure goods and services within procurement legislation and regulation requirements. Both NHS Terms and Conditions for non-clinical procurement and NHS Standard Contract for clinical procurement require suppliers to comply with relevant legislation.
- Raising awareness during 2024-25 of the Modern Slavery Act 2015 internally as part of all procurement processes, including requesting all providers to set out their plans and arrangements to prevent modern slavery and human trafficking in all their activity and supply chains.
- Continuously review our internal processes and monitor our actions against modern slavery and human trafficking; and
- Working in partnership with our local Adult Safeguarding Boards and safeguarding Children Partnerships and contributing to and influencing NHS England's work regionally and nationally.
Our Policies
The ICB maintains a comprehensive suite of policies to ensure our compliance with various legal and regulatory obligations. These policies are reviewed regularly, allowing us to review or amend our approach where necessary. In the context of modern slavery, we believe the following ICB-wide policies support us in our compliance:
Procurement Policy
All procurement is in accordance with UK procurement law, and procured services are all subject to standard NHS contract terms and conditions. Suppliers must comply with relevant legislation.
Pay
Our pay structure is based on equal pay principles and rates of pay locally and nationally determined by the National collective agreements.
HR policies
Our recruitment processes are robust and adhere to safe recruitment principles. This includes strict requirements regarding identity, right to work and criminal record checks.
Bullying and Harassment and Grievance Policies
Our policies set out expected standards of behaviour and provide additional platforms for employee to raise and resolve concerns about their employment and poor working practices.
Safeguarding Policy and Freedom to Speak Up Policy
ICB is committed to maintaining a Freedom to Speak Up Policy that allows our employees to report any misconduct or malpractice they witness. We ensure that all issues are investigated fairly and appropriate actions are taken.
Our Safeguarding policy provides guidance on managing safeguarding concerns, including slavery and human trafficking. Safeguarding teams can offer advice and support to the ICB.
Our supply chain and risk assessment
We believe that the risk of modern slavery is low in our business. However, we assess the likelihood of modern slavery in our supply chain based on risk. We understand that hiring staff and procurement decisions may pose a greater risk. Although some third parties operate within different legal and cultural environments, we expect them to uphold the same ethics and values as us. This includes providing a fair and ethical workplace where workers are treated with dignity and respect and always maintaining the highest human rights standards. We expect these third parties to comply with all applicable laws. We will only partner with organisations where we are confident, they do so.
Due diligence and continuous risk management
We partner with suppliers who share our ethical values and standards. To ensure this, we conduct thorough due diligence on all third-party suppliers when they start collaborating with us and periodically afterwards. As part of our standard engagement terms, suppliers must agree to comply with all applicable laws, including the Modern Slavery Act 2015. Our procurement process also mandates that suppliers confirm their compliance with these regulations.
At the ICB, we hold our suppliers to the same high standards we set. Therefore, we require all third-party suppliers and contractors to complete a comprehensive pre-qualification questionnaire before engaging with us. We constantly review and update this questionnaire to ensure its effectiveness.
Action plans and outcome measures are held and managed by the Place-based Modern Partnerships at which the ICB Safeguarding Team will be represented.
Training
Our employees are at the centre of our policies and processes, and we prioritise communication with them to raise awareness and understanding of our efforts to combat modern slavery and various forms of labour exploitation. We believe that increasing awareness and providing training are the most effective ways to identify and combat these issues, and we are dedicated to improving the effectiveness of our communication in this area within the ICB.
Slavery and Human Trafficking is part of the organisation’s Mandatory Safeguarding Policy Training Programme.
Future progress
We will continue to review and develop our processes to mitigate the risk of modern slavery. In 2024, we will continue to review our procurement process and consider any additional measures to ensure that our obligations under the Act are passed through our supply chain. Our modern slavery training will continue to be mandatory for all employees so we can be confident they possess the knowledge to identify any risks of modern slavery.
The West Yorkshire ICB acknowledges that fighting against modern slavery and human trafficking requires a coordinated, collaborative, and long-term approach. We are committed to continuously improving our knowledge and efforts to eradicate modern slavery. We will review and adapt our approach to manage these risks effectively.
This statement is made under Section 54 of the Modern Slavery Act 2015 and is our modern slavery and human trafficking statement for the year ending 31 March 2025.