Modern Day Slavery Statement
As both a local leader in commissioning health care services for the population of Cambridgeshire and Peterborough and as an employer, NHS Cambridgeshire and Peterborough Integrated Care Board (ICB) provides the following statement pursuant to section 54 of the Modern Slavery Act 2015 for the financial year ending 2024 in respect of its commitment to, and efforts in, preventing slavery and human trafficking practices in the supply chain and employment practices.
Definition of Offences
Slavery, servitude and forced or compulsory labour.
A person commits an offence if:
• The person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or;
• The person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.
A person commits an offence if;
• The person arranges or facilitates the travel of another person (victim) with a view to being exploited.
• It is irrelevant whether the victim consents to travel and whether or not the victim is an adult or a child
Exploitation: A person is exploited if one or more of the following issues are identified in relation to the victim:
• Slavery, servitude, forced or compulsory labour
• Sexual exploitation · Removal of organs · Securing services by force, threats and deception
• Securing services from children, young people and vulnerable persons.
As an authorised statutory body, the ICB is the lead commissioner for health care services (including acute, community, mental health and primary care) in Cambridgeshire and Peterborough – covering a population of approximately 950,000.
The aim of this statement is to demonstrate the ICB follows good practice, and all reasonable steps are taken to prevent slavery and human trafficking. All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility for overall compliance.
The position in Cambridgeshire and Peterborough
Locally there have been a few cases involving victims of modern slavery that has resulted in criminal convictions being made for example in 2023 a couple who kept a woman as a slave, forcing her to give up her newborn baby and subjecting her to beatings were convicted of multiple charges including slavery and child abduction after being found guilty following trial. They were jailed for a combined 12 years.
The victim, who had been persuaded to move from Slovakia to Cambridgeshire in October 2013, was subjected to violence and intimidation by relatives who stole thousands from her in wages over a period of four years.
NHS Cambridgeshire and Peterborough Integrated Care Board (ICB) is fully aware of its responsibilities towards patients, employees and the local community and we continue to work in conjunction with our multi-agency partners across the Integrated Care System (ICS) to embed best practice to prevent and respond to modern-day slavery across Cambridgeshire and Peterborough.
Our commitment to prevent slavery and human trafficking.
The Governing Body, Senior Management Team and all employees are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and in so far as is possible to holding our suppliers to account to do likewise. Our overall approach will be governed by compliance with legislative and regulatory requirements and the maintenance and development of best practice in the fields of contracting and employment. Our internal recruitment processes are highly mature and adhere to safe recruitment principles, including the ‘fit and proper persons test’. This includes strict requirements in respect of identity checks, work permits and criminal records for all directly employed staff, and agencies on approved frameworks are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will.
Our pay structure is derived from national collective agreements and is based on equal pay principles with rates of pay that are nationally determined. Contracting with providers is a core function of the ICB. All of our contracting and commissioning staff are suitably qualified and experienced in managing healthcare contracts and training and advice about modern slavery and human trafficking is available to staff through the safeguarding people team.
Our safeguarding policies provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated and we operate a raising concern and whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our commissioned services are being treated, or about practices within our business or supply chain, without fear of reprisals.
NHS Cambridgeshire and Peterborough ICB are continuing to work with NHS funded and partner organisations to ensure modern slavery and human trafficking are appropriately prioritised and feature prominently in safeguarding work plans.
All providers are required to declare they have arrangements in place to prevent slavery in their activities and supply chain.
NHS Cambridgeshire & Peterborough ICB will identify 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 chain if no reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.
Implications for equality and diversity
The ICB has a duty under the Equality Act 2010 to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations between people from different groups. In relation to the issues set out in this paper, consideration has been given to the impact that the recommendations might have on these requirements and on the nine protected groups identified by the Act (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, gender and sexual orientation). It is anticipated that the recommendations of this statement are not likely to have any particular impact upon the requirements of or the protected groups identified by the Equality Act.