Modern Slavery Act
Our Modern Slavery Act Statement
NHS Midlands and Lancashire Commissioning Support Unit (MLCSU) believes there is no room in our society for modern slavery and human trafficking, we have zero tolerance for modern slavery and breaches in human rights and we will ensure this is built into the processes and business practices that we, our partners, and our suppliers use.
We have produced a Supplier Code of Conduct Agreement. This supplier code of conduct is to inform all suppliers who provide goods and services to NHS MLCSU of our ethical standards and assures our clients that our supply chain is robust.
As a supplier of goods or services to NHS MLCSU, any of our suppliers must comply with the code of conduct agreement.
What is modern slavery?
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 considered to be 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 have restrictions placed on their freedom of movement.
The use of slavery in the production of goods and services
Typically, the products bought nowadays have passed through a long chain of producers, manufacturers, distributors, and retailers who have all participated in its production, delivery, and sale. It can therefore be difficult to certify that a product has or has not been produced using slavery. However, the way in which companies operate and manage their supply chain can affect the likelihood of slavery being a part of the final product. The Modern Slavery Act gives responsibility to companies for ensuring that no slavery has occurred, and this applies not only to the products they sell or the services they provide themselves but also to their suppliers, and their Tier 1, 2 and 3 suppliers throughout the entire supply chain.
What we are required to do
Primarily our requirements relate to section 54 of the act “Transparency in the supply chain” under the act, any company with a turnover of more than £36m must produce a statement for each financial year listing the steps it is taking to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business. A statement must be published on company websites and visible to staff, suppliers, customers, and investors.
What we do
- Ensure all UK workers receive minimum wage and robust immigration checks.
- Ensure suppliers adhere to the working time directive 1998.
- Provide Safeguarding training to employees.
- The procurement teams are all Chartered Institute of Purchasing and Supply (CIPS) or working towards this qualification. As such, they all abide by the CIPS code of professional conduct and have completed a CIPS ethical test which specifically covers modern slavery, this is refreshed on an annual basis.
- The NHS standard contracts which NHS England publishes, governs how NHS MLCSU engages with its suppliers and require compliance with relevant legislation, including the Modern Slavery Act 2015. The NHS Standard Contract for 2024 updates to these contracts strengthen our position on Modern Slavery, extending requirements and the option to terminate for breaches of social and labour laws.
We also have internal policies that support our commitment to eradicating Modern Slavery, such as:
- Supplier Code of Conduct
- Freedom to Speak Up / Whistleblowing Policy
- Safeguarding Policy
- Procurement Policy
Each year we will review our approach and publish an annual statement outlining the steps we are taking to tackle modern slavery.
Modern Slavery Act Statement reviewed February 2024
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