Modern Slavery & Human Trafficking Transparency Statement 2024-2025

Rushcliffe Borough Council - Modern Slavery & Human Trafficking Transparency Statement 2024/2025

This statement sets out the controls Rushcliffe Borough Council has in place, the steps taken during 2024/2025 and the steps the Council will be taking to ensure that slavery and human trafficking is not taking place in any of its supply chains and in any part of its own business.

Organisational structure and supply chains

Rushcliffe Borough Council provides a range of services for its residents from council tax collection, waste collection, planning management and environmental health. Other services, such as schools, social care and roads/transport links are provided by Nottinghamshire County Council. Goods and services can be delivered both directly by the Council and through external contractors.

Countries of operation and supply

The Council operates in the United Kingdom. We consider the risk of slavery and human trafficking to be low due to the type of activity that we undertake. However, we will remain vigilant and potential risks will be considered when delivering our services or undertaking procurement exercises.

Responsibility and Council Values

Our core Values commit the Council to:

• Show commitment
• Work in collaboration
• Strive for excellence
• Embrace inclusivity
• Act with integrity

With these principles in mind, we have a range of policies and processes which reflect our commitment to acting ethically and with integrity.

Specific policies that apply:

Council policies are developed by officers employed by the authority and are then agreed on by our senior officers, councillors, and partner organisations where relevant.

Corporate Strategy: One of the Council’s four key priorities is Quality of Life. Residents’ quality of life will always be a priority for the Council. Quality of life is all about how residents feel about living in the Borough, its environment, and the community facilities they can access.

Children and Adults Safeguarding Policy: The Council are a part of Nottinghamshire District and Borough Councils wide approach to Children and Adults Safeguarding policy. This safeguarding site provides all the resources in a central location including procedures for delivery of a safe environment by officers and for effective operation with its partners, to report safeguarding issues. As such the ‘duty to notify’ provision as set out in Section 52 of the Modern Slavery Act 2015, which applies to public authorities, including districts councils, will be supported by this policy.

Whistleblowing Policy: The Council encourages all its workers, customers, and other business partners to report any concerns related to the activities of the Council or its contractors. The Council’s Whistleblowing Policy is designed to make it easy for workers, customers, partners etc. to make disclosures, without fear of retaliation. We encourage employees who have serious concerns to raise these via nominated the persons specified in the Policy.

We want to know if customers have any issues and concerns; these can be reported through the Standards, Feedback and Complaints process. These concerns, if appropriate, will be followed up via the Council’s safeguarding policies and procedures.

Employee Code of Conduct: makes clear to employees the actions and behaviour expected of them when representing the organisation. The Council strives to maintain the highest standards of employee conduct and ethical behaviour including when managing its supply chain.

Member Code of Conduct: makes clear to members the actions and behaviour expected of them when representing the organisation. The Council members must maintain the highest standards of courtesy and respect.

Procurement: The Council is committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains. The Council expects the same standards from its contractors, suppliers and other partners and as part of its procurement processes.

The Council’s constitution requires that procurements above £50k include confirmation of Modern Slavery Act compliance and addition, where deemed to be high risk in terms of modern slavery, additional award questions should be considered. Nottinghamshire County Council provide the Council’s procurement support and ensure that for above threshold contracts, pre-contract questionnaires include questions in relation to the contractor/supplier’s Modern Slavery and Human Trafficking policies, processes and responsibilities, to ensure the Council only enters into contracts with those organisations who are fulfilling their statutory responsibilities.

In addition, the Council has already included anti-slavery clauses in its standard contract terms and conditions and tender documents, to ensure that the Council is only entering into contracts with suppliers who are committed to complying with requirements under the anti-slavery and human trafficking laws, including but not limited to the Modern Slavery Act 2015. The constitution also states that where a supplier is required to comply with the Modern Slavery Act 2015 that compliance should form part of the contract management.

Equality and Diversity: This framework provides the Council’s approach to the wide ranging equality and diversity agenda.

Recruitment: Organisationally the Council takes its responsibilities for safeguarding extremely seriously. The organisation, through its HR practices and employment checks, will ensure that anyone offered work as an employee will be scrutinised to ensure that they are legally entitled to work in the U.K. The Council through its pay policies will adhere to appropriate legislation that determines and prescribes levels of minimum payment for work undertaken as an employee.

The co-ordination of training and disseminating further information to staff in respect of Modern Slavery will be dealt with by the Council’s Corporate Safeguarding Group. Through staff briefings via the intranet and handouts, staff will be advised of the impact of modern slavery both locally and nationally. They will be advised of the potential signs that slavery or human trafficking may be occurring and where to report their concerns. In depth training will be given to staff, in particular those staff working in front facing services who may be more likely to encounter instances of modern slavery, such as Housing and Community Safety.

Training: Safeguarding training is provided through e-learning and face to face sessions for both staff and councillors.

Planned actions to tackle slavery and human trafficking

1. Training and awareness-raising: The Council will implement a new e-learning module on Modern Slavery and Human Trafficking and ensure this is delivered face to face for staff who do not have access to e-learning. This will include considering awareness of the following:

• The basic principles of the Modern Slavery Act 2015
• How employers can identify and prevent slavery and human trafficking
• What employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation
• What external help is available, for example through the Modem Slavery Helpline

2. Policy updates: Relevant policies, procedures and processes will be reviewed and adapted to include the aim of ensuring there is no slavery or human trafficking in the Council’s own business and its supply chains.

3. Employment: Victims of modern slavery and human trafficking within the Council will be tackled through our human resources policies and procedures. This will apply to those already in employment, during recruitment and temporary and /or agency staff. We will ensure a safe environment within the Council for concerns to be raised and reported.

Targeted activity/Partnership working: The Council works very closely with the Nottinghamshire Slavery and Exploitation Team (SET) based at Nottingham City Council. The SET team has dedicated officers who work with partners to identify and tackle exploitation, modern slavery and trafficking and establish pathways to support for survivors. In order to drive a multi-agency approach to identification, prevention and management of cases, the team established a Slavery Exploitation Risk Assessment Conference (SERAC). The SERAC unites agencies to discuss suspected or known cases and plan a joint response to manage risk and intervene, increasing effectiveness and co-operation between agencies, resulting in greater protection and outcomes for victims.

This Modern Anti-Slavery and Human Trafficking Statement is approved by the Council’s Executive Management Team and endorsed by Cabinet. It will be reviewed and updated as necessary and published on an annual basis.