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Modern slavery

NHS South West London, in accordance with Section 54, Part 6 of the Modern Slavery Act 2015, fully supports the government’s objective to eradicate modern slavery and human trafficking and has a responsibility to take a robust approach to slavery and human trafficking and is committed to preventing slavery and human trafficking in its corporate activities.

Definition

Modern day slavery, servitude, forced or compulsory labour

Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.

Human trafficking

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 1 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.

NHS South West London structure

As an authorised statutory body, NHS South West London is the lead commissioner for health care services (including acute, community, mental health and primary care) in Croydon, Kingston, Merton, Richmond, Sutton and Wandsworth. 

The membership, executive 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.

The organisational structure, business and supply chain

We have a clear line of accountability for safeguarding. Our accountable officer has ultimate accountability for ensuring that the health contribution to safeguarding and promoting the welfare of children and adults is discharged effectively across the whole health economy through commissioning arrangements. 

The chief nursing officer is the executive lead for safeguarding and has responsibility for providing leadership and gaining assurance in relation to safeguarding issues. 

We employ the expertise of designated professionals for both children and adults. These roles are an integral part of our activity and support the delivery of the safeguarding adult and children’s agenda.

Procurement

We ensure that organisations commissioned to provide services have appropriate systems that safeguard children in line with section 11 of the Children Act (2004) and Working Together to Safeguard Children (2024), and adults in line with The Mental Capacity Act 2005, The Care Act 2014, and The Modern Slavery Act 2015. 

Business and supply chains

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Safe recruitment principles are adhered to which includes strict requirements in respect of identity checks, work permits and criminal records. Systems are in place to encourage the reporting of concerns and the protection of whistle blowers.

With regards to providers and supply chains, we expect these organisations to have suitable anti-slavery and human trafficking policies and processes in place. We use our routine contract management meetings with major providers to hold them to account for compliance with the Act and we implement any relevant clauses contained within the Standard NHS Contract.

Contracting with providers is a core function of NHS South West London

We are committed to social and environmental responsibility and has zero tolerance for modern slavery and human trafficking. Any identified concerns regarding modern slavery and human trafficking would be escalated as part of the organisational safeguarding process and in conjunction with statutory partner agencies, such as the local authority and police.

All our contracting and commissioning staff are suitably qualified and experienced in managing healthcare contracts and receive appropriate briefings on the requirements of the Modern Slavery Act 2015. We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers.

Ensuring that modern slavery and human trafficking is not taking place in our business or supply chains

We aim to be as effective as possible in ensuring that modern slavery and human trafficking is not taking place in any part of our business or supply chains by:

  1. Effective interagency working with local authorities, the police and third sector organisations which includes appropriate arrangements for preventing and responding to modern slavery and Human Trafficking.
  2. Signing up to the multi-agency policy and procedures for the protection of adults with care and support needs.
  3. Undertaking robust NHS employment checks and payroll systems.
  4. Ensuring good communication through contract management meetings, with our commissioned providers in the supply chain and their understanding of, and compliance with, our expectations in relation to the NHS terms and conditions. These conditions relate to issues including bribery, slavery, and other ethical considerations.
  5. Work with NHS funded and partner organisations to ensure modern slavery and human trafficking are appropriately prioritised and feature prominently in safeguarding work plans.

Staff training about modern slavery and human trafficking

Modern slavery and human trafficking is part of the organisation’s mandatory safeguarding children and adults training programme.