Modern Slavery Act Statement
This statement sets out the action of Preston City Council to understand all potential modern slavery risk relating to its business and the steps it has taken that are aimed at ensuring that there is no slavery or human trafficking in its business or supply chains.
As part of the public sector, we recognise our responsibility to take a robust approach to preventing slavery, exploitation and/or human trafficking.
We recognise our responsibilities as an employer and procurer/commissioner of services and acknowledges its duties as a City Council to notify The Secretary of State of suspected victims of slavery or human trafficking as introduced by Section 52 of the GOV.UK - Modern Slavery Act 2015 and to take action and work with other responder agencies under the Legislation.gov - Civil Contingencies Act 2004.
We are committed to doing all that we can to prevent slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and/or human trafficking.
The statement below sets out practices already in place at the Council in 2018 to 2019 following the introduction of the Modern Slavery Act 2015.
We are a District Council, working alongside Lancashire County Council as part of a two-tier local government system. The Council spends more than £100 million a year providing a range of public services from pest control to planning.
It is one of the largest employers in the area with 635 employers.
We have a range of policies and processes which reflect our commitment to acting ethically and with integrity to prevent slavery and human trafficking in all of its operations. We have a robust ongoing policy review programme to ensure that the Councils policies and procedures remain compliant and fit for purpose.
Meeting the requirements of the Modern Slavery Act
The following policies and procedures are considered to be key in meeting the requirements of the Modern Slavery Act.
Employee Code of Conduct
Our Code of Conduct makes it clear to employees the actions and behaviour expected of them when representing the Council. We strive to maintain the highest standards of employee conduct and ethical behaviour, including managing its supply chain.
Our recruitment processes are transparent and are reviewed regularly. This includes having robust procedures in place for the vetting of new employees. Checks are undertaken to confirm identities and qualifications. Salaries are also paid into a personal bank account.
Where agency workers are used, these are procured via a third party company which in turn has its own Modern Slavery statement. The third party company vets employment agencies to ensure they are reputable before accepting workers from that agency.
We encourage all our employees, customers and business partners to report any concerns related to the direct activities, or the supply chains of the Council. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
The Council's Whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can raise these via their manager or the Council's Monitoring Officer (currently the Head of Legal and Democratic Services).
Corporate Complaints System
We operate a complaints procedure to deal with complaints about the Councils services. This can be used to report community concerns, such as overcrowding or issues which might reveal slavery or human trafficking which may merit an investigation or reporting to a partner agency.
Equality and Diversity Performance
We record our performance within the context of the Corporate Plan - Achieving Preston's Priorities. This enables the Council to explicitly evidence that equalities are embedded in its work and that it is, as a minimum, complying with the 'Public Sector' Equality duty in the delivery of all of the Council's services.
We also carry out Equality and Human Rights Impact Assessments (EHRIA) when looking at the effect a policy, project or decision is likely to have on different people. The Council has included human rights as a consideration in the EHRIA process.
We embrace our responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and vulnerable adults and protect them from harm. We work within multi-agency partnerships to protect and safeguard people.
Code of Conduct for Members
Our Code of Conduct for Members expects all our Members to demonstrate the highest standards of conduct and behaviour when representing the City Council.
All Members have undergone training on the Code of Conduct and ethical behaviour.
Due Diligence of suppliers
We understand the important role that procurement plays. It enables and rewards good employment practices and does not encourage the use of modern day slavery practices.
In 2008 the Council resolved to be a Living Wage employer and is actively looking to implement the Living Wage policy in its procurement practices on a case by case basis.
We are committed to undertaking due diligence at all stages of the procurement cycle to mitigate the risk of modern slavery and human trafficking within the supply chain.
The Councils due diligence measures
- Working with partners to develop an understanding of the risks
- Taking appropriate measures in the selection of suppliers to enable the exclusion of suppliers with convictions under the relevant sections of the Modern Slavery Act
- Inclusion of appropriate clauses in contracts to require suppliers to comply with the requirements of the Modern Slavery Act. These will be applicable to sub-contractors in the supply chain
- Monitoring the performance of suppliers against the contract requirements, particularly in areas of identified high risk
- Training and awareness raising for employees dealing with procurement and contracts. Wherever possible, following good practice guidance that is available in relation to modern slavery.
Training and awareness - raising
We recognise that employees within the organisation need to be trained on modern slavery in order to raise awareness and increase compliance with the GOV.UK - Modern Slavery Act 2015.
A training package on modern slavery will be developed over the forthcoming months on Mi-Pod which is the Council's interactive site. This will be compulsory and will ensure that employees will have a general awareness when it comes to identifying slavery.
The package will include the following:
- The basic principles of the Modern Slavery Act 2015
- How employees can identify slavery including warning signs and indicators
- What colleagues can do to raise concerns about potential slavery
- What external help is available and details of the National Referral Mechanism (NRM).
Promoting and Communicating Modern Slavery issues
In the coming months, we will make information available for all employees outlining the Council's duties, potential warning signs and what action to take if they have any concerns. An internal communications campaign will be implemented in order to raise awareness of modern slavery, what it is, and how it might impact on the day to day work of Council employees.
This statement is made pursuant to section 54 (1) of the Modern Slavery Act 2015 and constitutes Preston City Council's modern slavery and human trafficking statement for the financial year ending 31 March 2019.
The full signed declaration can be found in the downloads section on this page.