Modern Slavery Statement

Modern Slavery Act 2015

In accordance with the Modern Slavery Act 2015, the Royal Devon University NHS Foundation Trust fully supports the government’s objectives to eradicate modern slavery and human trafficking and makes the following statement regarding the steps it is taking to ensure that modern slavery i.e. slavery and human trafficking, is not taking place in any part of its own business or any of its supply chains.

The Home Office’s Statutory Guidance on Modern Slavery (2021) (www.gov.uk/government/ publications/modern-slavery-how-to-identify-and-support-victims) is intended for staff in England and Wales within public authorities who may encounter potential victims of modern slavery and/ or who are involved in supporting victims. The Home Office states that these individuals and organisations must have regard to the statutory guidance, with a view to developing a more consistent response to modern slavery victims to ensure they are identified and receive the available and appropriate support.

The process of identification can be very challenging, in particular establishing the means and purpose of activities and differentiating, in terms of the Act, those adults who are subject to poor or illegal work conditions and those who are victims of modern slavery through the use of force, control, deception and threat. Tackling modern slavery and human trafficking requires a collective, co-ordinated and sustained effort from a range of collaborating agencies, both statutory and non-statutory. No single agency or individual can eradicate modern slavery alone and this effective partnership working is essential.

The Trust’s position on modern slavery is to:

• Develop an awareness of human trafficking and modern slavery within our Workforce and provide them with information and support to act appropriately to identify, support and refer victims
• Comply with legislation and regulatory requirements
• We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business and, insofar as is possible, to requiring our suppliers to hold a corresponding ethos and make suppliers and service providers aware that we promote the requirements of the legislation.

Slavery and human trafficking statement for financial year 2022/23

During the last financial year the Trust took, and continues to take, the following:

• The Trust is a key partner in in the development of the Devon and Torbay Modern Slavery Adult Victims Referral/Support Pathway Protocol AntiSlavery Partnership and is a signatory to this document. The Trust has adopted the quick guide to assist and enable staff to act appropriately in support of victims.
• The Trust has a number of controls in place to ensure compliance with employment legislation.
• We confirm the identities of all new employees and their right to work in the United Kingdom.
• All staff are appointed subject to references, health checks, immigration checks and identity checks. This ensures that we can be confident, before staff commence their duties, that they have a legal right to work within our Trust.
• We have a set of values and behaviours that staff are expected to comply with, and all candidates are expected to demonstrate these attributes as part of the selection process.
• By adopting the national pay, terms and conditions of service, we have the assurance that all staff will be treated fairly and will comply with the latest legislation. This includes the assurance that staff received, at least, the national minimum wage from 1 April 2015.
• Our equality and diversity, grievance and prevention of harassment and bullying policies additionally give a platform for our employees to raise concerns about poor working practices.
• Our policies and practices promote and support diversity and inclusion both as an employer and as a service provider; we recognise and acknowledge that diversity and inclusion are key corporate social responsibilities and a Diversity Network for all staff has been in place since 2017.
• Modern slavery is incorporated within our mandatory safeguarding children and adults training from levels one to three, which applies to all staff and safeguarding policies. Our Trust “Safeguarding Adult Policy”, and the Devon Multi-Agency Safeguarding policy, to which our Trust is a partner signatory, also includes modern slavery. Our Trust intranet site includes information and support which sign posts to the modern slavery helpline and website for further information. We also share information via our safeguarding newsletter to raise awareness.
• Our Freedom to Speak: Raising Concerns (Whistleblowing) Policy gives a platform for employees to raise concerns for further investigation, and our Freedom To Speak Up Guardian and Safeguarding teams actively ensure they are accessible to colleagues.

Working with suppliers

• In addition, all other external agencies providing staff to the Trust have been approved through government procurement suppliers (GPS). The Trust will audit and monitor agencies (via GPS) that provide staff once a year to ensure that they are able to provide evidence of identification, qualification and registration.
• Our standard terms and conditions require suppliers to comply with relevant legislation. A large proportion of the goods and services procured are sourced through Government supply frameworks and contracts which also require suppliers to comply with relevant legislation.

Royal Devon University Healthcare NHS Foundation Trust follows best practice guidance and works with multi-agency partnerships to meet the regularity and statutory requirements of the Act and Code of Practice ensuring all reasonable steps are taken to prevent slavery and human trafficking and will continue to support the requirements of the Modern Slavery Act 2015 and any future legislation.

June 2023