Modern Slavery Statement 2024/2025
Introduction: financial year ending 2024/2025
East Sussex County Council remains committed to ensuring that public money is spent responsibly and our activities and those working on behalf of the authority are conducted in an ethical, responsible and sustainable manner.
Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 requires certain organisations to publish an annual modern slavery statement outlining the actions taken each year to tackle modern slavery risks within their operations and supply chains. While not required by the transparency provision to publish a statement, East Sussex County Council recognises the important role the public sector must play in helping to address this critical issue and has voluntarily chosen to report on our activities. This is the Council’s 2024/2025 statement. The structure and content of the statement remains the same as our previous statement, with sections updated to reflect key activities undertaken during the 2024/2025 financial year.
East Sussex County Council’s 2025/2026 Council Plan outlines the Council’s ambition to achieve our four priority outcomes by 2028: driving sustainable economic growth; keeping vulnerable people safe; helping people help themselves; and making best use of resources now and for the future. We aim for East Sussex to be a county that is an attractive place to live, work and do business. We want East Sussex businesses to have the assistance they need to thrive and grow sustainably, including creating quality jobs, and goods and services for our communities. We want our people and residents to feel safe and have access to support and services to achieve their full potential – whether that be education, training, employment, and health and social care to meet their needs. We want to continue doing our part to help tackle climate change to ensure a healthier planet for future generations.
At the time of writing this statement, local government is undergoing significant changes. The Procurement Act 2023 which came into effect on 24th February 2025, established a new public procurement regime aiming to improve and simplify procurement processes and make it easier for smaller businesses to contract with public sector authorities. Separately, discussions and plans around local government reform are set to transform the structure and responsibilities of local authorities, representing a significant shift in local government in half a century. These developments are a pivotal moment in local governance, impacting how services are procured, delivered and managed across our communities.
Amidst these changes, East Sussex County Council remains committed to tackling modern slavery. With an estimated 50 million victims globally and over 100,000 in the UK, this is a grand challenge that is closely interconnected with broader global issues such as those highlighted in the United Nations’ sustainable development agenda. The Council is dedicated to doing our part to help foster a just transition to ensure that vulnerable populations, including residents, communities and workers at risk of exploitative practices, are not overlooked as we pursue our net-zero future.
As a local authority, we recognise that we have several roles to play to help address the problem of modern slavery. This includes safeguarding vulnerable adults and children from exploitation and harm, identifying potential victims in our role as first responders, and working to implement measures that protect workers in our operations and supply chains from modern slavery and other unethical labour practices.
Our 2024/2025 modern slavery statement provides an update on all six areas recommended by Section 54 of the Modern Slavery Act 2015:
- our organisation structure and supply chains
- policies in relation to modern slavery
- risk assessment
- due diligence measures
- how we measure our performance, and
- training available to our staff
The Council recognises the important role the public can play in shining a light on modern slavery practices. As Section 54 of the Modern Slavery Act 2015 encourages public scrutiny of modern slavery statements, we have included information for reporting suspected or actual cases to the relevant authorities.
Due to the complex and ubiquitous nature of modern slavery, there are different people, teams and local partnerships working to address it and related concerns such as issues around vulnerability and safeguarding. Consequently, it is challenging to document all activities including training, support and correspondence. Therefore, this statement may not fully reflect all actions taken by the authority, but it provides insight into key activities with certain sections of the document updated as necessary.
This statement has been updated to reflect the authority’s current approach and activities undertaken in the 2024/2025 financial year. It relates to key steps taken by the Council between 1 April 2024 and 31 March 2025.
Our organisation structure and supply chains
East Sussex County Council provides a range of services to over 500,000 residents in East Sussex, including providing social care to children and the elderly, maintaining roads and providing libraries and waste management services. The Council employs approximately 5,000 staff corporately.
Our Corporate Management Team provides strategic direction to the whole council which is organised into the following directorates:
- Adult Social Care and Health
- Governance Services
- Children’s Services
- Business Services
- Communities, Economy and Transport
East Sussex County Council have a shared procurement service with Surrey County Council and Brighton & Hove City Council. Our partnership helps to deliver lean procurement support, shared learning to achieve excellent outcomes and shared resource for the delivery of achieving value for money for our residents. Collectively, we comprise of one of the largest public procurement spends in local government, with an expenditure circa £2 billion a year with external suppliers across the three local authorities. As we deliver a significant amount of our projects annually via our shared procurement service, its contribution to our anti-slavery in supply chain activities is vital. Accordingly, this work is driven by our procurement service for the benefit of the three authorities and our supply chains.
Beyond work undertaken in our procurement service to mitigate modern slavery risks in our supply chains, the Council also has people and teams across the authorities working on addressing related concerns such as issues connected to abuse, vulnerability, safeguarding, and community and partnership.
During the 2024 to 2025 financial year the Council spent approximately £644m with 2,011 suppliers.
| Spending area | Total |
|---|---|
| Education, health and social care | £402 million |
| Assets and infrastructure | £186 million |
| Corporate and Business | £56 million |
Policies in relation to slavery and human trafficking
East Sussex County Council recognises the importance of policies to communicate our commitments and expectations of our staff, suppliers, and those who we do business with, to effectively address modern slavery. We also recognise that modern slavery sits on the extreme end of the labour exploitation continuum. Therefore, we have several policies, procedures, and codes of conduct with respect to abuse, fair labour and employment conditions that work to prevent and respond to a range of issues, including modern slavery, in our operations and supply chains. This includes whistleblowing, recruitment, health and safety, and grievance policies. Details of key policies and their relevance to modern slavery can be found in the Annex.
In July 2024, our procurement service published a revised Supplier Code of Conduct. The Code of Conduct outlines the Council’s expectations of suppliers with regards to ethical conduct when bidding for and delivering contracts. Our Code is centred around three key principles: people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly and maintain high standards of integrity and professionalism in their business dealings. Under our “People” principle, we affirm our commitment and expectation for supply chain partners to respect and uphold labour and human rights. We expect all suppliers to adhere to the principles outlined in the Code and where specific risks or opportunities are identified, we elaborate on relevant aspects of the Code in procurement and contract management activity. In June 2024, a training session on the Code was delivered to the procurement team to increase their awareness of it and its implementation.
In our last statement, we set a performance measurement to review a sample of projects to ensure that the Code was being implemented to tackle modern slavery in high-risk projects. However, this has been removed as the Code is communicated in all procurements, regardless of modern slavery risk. However, in cases where specific risks and opportunities related to modern slavery are identified in a project, further due diligence measures are implemented in addition to the general application of the Code (see section on due diligence). As part of our broader procurement policy efforts, our procurement policy team will routinely review projects to ensure that the Code is communicated to all suppliers and that they are committed to adhering to its principles.
Risk assessment
As a public sector body, we recognise the risk of modern slavery facing vulnerable people and service-users in our community, as well as workers in the supply chains supporting our activities. We also acknowledge that modern slavery is an issue that is prevalent in the UK. While we have an ambition to work with local supply chains, the risk of slavery still exists as the unfortunate reality is that no supply chain is entirely free of modern slavery or unethical labour practices.
Modern slavery can take place at any stage of a supply chain, from the extraction of raw materials to the delivery and use of a final product while people delivering and receiving services can be subjected to exploitative practices by perpetrators internal and/or external to an organisation.
To aid our understanding of risks and inform our due diligence approach, we regularly consult and communicate up-to-date information on high-risk goods and services within the UK and beyond. Regarding modern slavery concerns in services we provide and the communities we serve, we recognise vulnerable service-users including children, young people, and vulnerable adults. Within our supply chains, we recognise risks in our third party spend in high-risk areas such as adults social care, construction, and facilities management but acknowledge that the Council's exposure to modern slavery issues is likely much greater due to the extent and nature of our activities.
The risk of modern slavery in our procurement activity and supply chains is reviewed at a category and project level. Procurement officers are encouraged to flag projects that fall within our prioritised categories with regular guidance issued by our Senior Policy Lead on Modern Slavery (SPL-MS), based in the procurement team on mitigating potential risks. Our SPL-MS also has visibility of projects and directly supports the embedding of modern slavery requirements in those where policy-related risks or opportunities have been identified. This means that we can ensure that modern slavery and unethical labour considerations are built into our tendering activity, identify areas to improve, and assess other key projects that fall outside our prioritised categories but nevertheless carry an element of risk in the supply chain. In our procurement activity, we often prioritise our due diligence on projects based on risk characteristics such as industry type, the nature of the workforce (such as reliance on low skilled or agency workers), and complexity of business model and supply chain (such as sub-contracting arrangements) and opportunities to manage risks.
Due to the activities and services we undertake and deliver as a local authority, we expect the type of risks we are likely to encounter to remain consistent and unlikely to vary significantly.
Due diligence
This section of our statement reports on activities aimed at understanding and managing risks within our operations and communities and our supply chains.
Our operations and communities
The Council has numerous legal responsibilities to protect and safeguard vulnerable adults, children and young people. Under the Care Act 2014 we have a duty to safeguard adults with care and support needs. We also have a duty under child protection legislation, notably the Children Act 1989, the Children Act 2004 and the Children and Social Work Act 2017 to safeguard children and young people in need in our local area.
East Sussex County Council is also a first responder organisation. This means we have a responsibility to refer potential victims into the National Referral Mechanism (NRM). This is the government's framework for identifying and supporting potential victims of modern slavery. Under section 52 of the Modern Slavery Act 2015, we have a statutory duty to notify the Home Office of potential victims of modern slavery that we come across.
Adults who give their consent and child victims can be referred into the NRM. Where a potential adult victim has not consented to a referral, the Council still has a duty to notify (DtN) the Home Office to support intelligence gathering.
In 2024, 19,125 potential victims of modern slavery were referred to the Home Office.
Of these, East Sussex County Council referred 23 potential victims into the NRM. Of the 23 potential victims, 21 were children (aged 17 and under). Five DtN referals were also made.
In the last year, East Sussex County Council continued to take part in a national pilot to develop approaches on decision-making concerning children who have been identified as victims of modern slavery and exploitation.
With regards to adult safeguarding, Section 42 of the Care Act requires local authorities to make enquiries, or ask others to do so, if they believe an adult with care and support needs is at risk of abuse or neglect in their area and to find out what, if any, action may be needed to protect them. The Care Act 2014 includes modern slavery as a type of abuse, as well as being a serious crime, therefore, managing cases of modern slavery is closely linked to safeguarding adults procedures.
A section 42 duty is triggered when three requirements of the Care Act have been met. This is when an adult: has care and support needs, is experiencing or is at risk of abuse or neglect and as a result of those care and support needs is unable to protect themselves from the risk or experience of abuse or neglect.
During the 2024 to 2025 financial year, 3 safeguarding cases reported as a modern slavery concern progressed to a section 42 safeguarding enquiry. This figure only reflects the cases that have been enquired upon and is not indicative of all safeguarding concerns received by the Local Authority.
In addition to the above, we have continued to review our internal training offers and refresh our understanding of our statutory duties in key services and delivered training for services in partnership with Sussex Police. We have worked in partnership to prevent and disrupt exploitation by identifying places where it occurs and commercial sectors of known risk. In response to modern slavery concerns in the care sector, we have worked to ensure that Council provided care is free from exploitation and address reports from elsewhere in the sector.
Our supply chains
During the 2024/2025 financial year, our shared procurement service continued to maintain the Councils’ collective efforts to combat modern slavery in our supply chains. Key due diligence work undertaken across our procurement partnership in the 2024/2025 financial year included:
- Reviewed new and updated guidance published by central government to help shape our approach. This includes Transparency in Supply Chain Guidance and Procurement Policy Note 009 on tackling modern slavery in government supply chains.
- Reviewed the Procurement Act 2023 and the National Procurement Policy Statement and requirements pertaining to modern slavery and labour market regulations, encouraging staff to complete transforming public procurement training, and review anti-slavery approach to ensure alignment.
- Kept informed of anticipated legislative changes such as the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2024 and measures needed to support the regulations’ requirements.
- Amended guidance to procurement team on managing modern slavery risks in tendering activity to ensure it aligns with relevant legislation and statutory guidance.
- Attended events to keep informed of modern slavery and unethical labour practices. Examples of this include: a stakeholder webinar held by the Gangmasters and Labour Abuse Authority in January 2025; care sector training held by the Modern Slavery & Organised Immigration Crime Unit in October 2024; a procurement roundtable on tackling modern slavery & ESG (Environmental, Social and Governance) in supply chains hosted by risk management experts in September 2024; and a case study webinar of construction companies experience tackling modern slavery in their supply chains hosted by the Supply Chain Sustainability School in May 2024. These sessions, along with our participation in networks such as the Local Government Association’s Modern Slavery Network, kept us informed about modern slavery issues, approaches to tackling them, and insights to help shape our training, guidance and engagement with different stakeholders.
- Revised our Procurement Report template to include modern slavery to ensure that policy considerations, where relevant, are taken into account in procurement activity and strategy.
- Monitored procurement activity to identify and prioritise projects that are at-risk of modern slavery and unethical labour practices and putting measures in place to mitigate these. This includes incorporating relevant considerations in specification requirements, award criteria, and contract terms and conditions. With the authority procuring hundreds of projects, different methods have been used to identify potential high-risk projects. This includes having procurement officers complete an initial triage of projects and also having our policy lead monitor and prioritise projects in our procurement forward plan.
- Included in our new Procurement Specific Questionnaire a question for relevant suppliers to submit compliant modern slavery statements.
- Elaborated our commitment to addressing modern slavery and promoting decent working practices, as outlined in our Supplier Code of Conduct which was revised and launched 1st July 2024. We have included commitments to the Supplier Code of Conduct in our tender materials, including in Request for Quotations for below threshold procurements.
- Reviewed spending outside procurement such as purchase cards and ad hoc spends to understand where risks may lie and whether practical due diligence measures could be adopted.
- Given the risks of modern slavery and labour exploitation in the care sector, we published guidance for care providers on overseas recruitment on our website.
- Updated modern slavery requirements in our Procurement and Contract Standing Orders. This is particularly important for purchases that are made outside the formal procurement process such as purchase card spend.
- Issued reminder to contract managers of suppliers' obligations in relation to Section 54 Transparency in Supply Chains of the Modern Slavery Act 2015 and to encourage suppliers to go above minimum requirements and report on the suggested areas outlined in the legislation to ensure a level playing field.
- Reviewed sample of projects to understand if and how modern slavery considerations were embedded and areas for improvement in future projects across the partnership.
- Worked more closely with consultants supporting procurement activity to ensure they understand our due diligence requirements and are embedding these in projects to manage risks.
- Delivered training to staff on tackling modern slavery (see section on training).
- Paid closer attention to framework agreements to understand if and how modern slavery was covered when the framework was established, how the framework monitors requirements and obligations and considered ways to strengthen due diligence measures in call-off contracts.
- Published a modern slavery statement outlining activities undertaken to tackle modern slavery during the 2023/2024 financial year on our website and on the Government’s modern slavery registry.
Key performance indicators to measure effectiveness of steps being taken
Our general approach to tackling modern slavery, particularly within our supply chains, is heavily informed by existing research, best practices, and statutory guidance. Research on modern slavery statements often report that one of the areas organisations tend not to report on are indicators to measure effectiveness of anti-slavery efforts. The Council therefore recognises this as an area for improvement and is working to strengthen how we measure our overall approach. As aforementioned, a challenge the Council faces with tracking actions to tackle modern slavery and consequently their effectiveness, is the number of activities and correspondence undertaken in this area by different people, teams and services across the authority, particularly those that handle concerns such as safeguarding whose work captures modern slavery issues alongside others.
The indicators below have been drawn from and inspired by external guidance and demonstrate what our organisation believes is feasible for us to monitor at this stage in our journey to managing modern slavery risks. These indicators support our anti-slavery efforts by i) helping us to understand potential risks ii) ensure that we are taking action iii) understand the effectiveness of our approach and iv) identify areas that require improvement. We will monitor and report on our indicators on an annual basis in our modern slavery statements.
Key performance indicators 2024/2025
Potential cases of modern slavery
Challenges/limitations
Reports of potential cases of modern slavery can be made through various channels within the local authority and the process for addressing different types of concerns may differ. As a result, the number of cases that have been reported in this statement may not reflect all potential cases or concerns received by the local authority.
Why we are measuring it
Identifying cases not only ensures that potential victims have access to necessary support but also gives us insight into the risks we may encounter as an authority, vulnerabilities within our community, operations, and supply chains, and our overall response to these challenges.
How we are measuring it
Number of reports made through the following channels:
- Our whistleblowing helpline.
- Adult safeguarding enquiries.
- NRM (end of year summary 2023 statistics).
2024/2025
- Whistleblowing: 0.
- Adult Safeguarding (s42 enquiry): 3.
- NRM: 23 referrals and 5 DtN.
Training of key supply chain management staff
Challenges/limitations
Despite the availability of Council-wide training on our e-learning platform, the authority recognises the importance of providing regular and targeted training for our staff. However, it can be challenging to require this type of training due to the large number of staff members who have various roles and responsibilities. Additionally, staff may have access to training (both internal and external) provided by their teams or services. As a result, the training reported may not accurately reflect all staff members who have accessed modern slavery training.
Why we are measuring it
Targeted training ensures that staff responsible for key aspects of service delivery are equipped with the necessary knowledge and skills to address modern slavery within their specific roles.
How we are measuring it
Number of training sessions delivered to staff and attendance.
2024/2025
Procurement
- Number of sessions: 1
- Number of attendees: 54
Review active high-risk projects to understand how modern slavery considerations were embedded
Challenges/limitations
Due to capacity limitations, it is not feasible to assess tender materials for all projects previously awarded that may present a high-risk of modern slavery.
Why we are measuring it
To leverage insights from current contracts to inform our handling of future high-risk projects and our overall approach to managing risks in procurement and contract management activity.
How we are measuring it
Project sampling across the partnership.
2024/2025
During the 2024/2025 financial year, 20 active projects across the Orbis Partnership with a total contract value of approximately £595m were reviewed by our SPL-MS.
Identification of projects across the partnership that may be at high-risk for modern slavery practices
Challenges/limitations
This assessment is not a confirmation of risk or the appropriate approach needed to respond. In most cases, projects may require further assessment, taking into account various factors such as the complexity of the procurement, the route to market, nature and characteristics of potential risks, and opportunities and challenges to managing these. Additionally, some projects may experience delays or changes before the procurement process even begins and anti-slavery measures may need to be considered at a later stage. Further there is also a risk that some projects may go unflagged. Procurement officers regularly receive reminders to flag projects.
Why we are measuring it
To understand Orbis partner authorities’ exposure to potential modern slavery risks and opportunities to manage these.
How we are measuring it
Number of projects across the partnership that have been flagged as potentially high-risk by procurement officers.
2024/2025
At the time of drafting this statement, there are 348 projects in total that have been flagged.
Please Note: As projects are at various stages of the tendering process, this figure represents the total number of projects presently in our project management system rather than by financial year.
Training on modern slavery available to staff
The Council continue to have the following training available to all staff on our e-learning platform.
Modern Slavery and Human Trafficking
- This is a 40-minute e-learning course designed to raise awareness of modern slavery and human trafficking and offer guidance to staff on recognising their role in identifying and reporting concerns. It provides information on areas such as understanding modern slavery and its various forms, the scale of slavery in the UK, vulnerabilities that lead to victimisation, spotting signs of potential victims, and information on referring potential victims into the NRM.
Introduction to Modern Slavery in Supply Chains
- This is a 60-minute e-learning course designed by the Council’s Senior Policy Lead on Modern Slavery in the procurement service to help staff in supply chain management roles understand the unique issue of modern slavery in supply chains. It includes information on key findings of the Global Slavery Index 2022 in relation to forced labour in supply chains, the current legislative landscape, the International Labour Organization’s Indicators of Forced Labour, high-risk sectors for forced labour, examples of cases within the UK and public sector responsibility for addressing modern slavery risks within our supply chains. This training was developed to ensure consistency in training received for staff working across Orbis Procurement partnership as well as others in operational roles.
Adult Social Care training
- The Council also facilitates a multi -agency modern slavery awareness workshop for Adult Social Care (ASC) staff and professionals that support ASC. During the 2024/2025 financial year, Council staff delivered three 3-hour sessions throughout the year. These sessions provided information on the prevalence of modern slavery, different types of modern slavery practices, guidance on spotting the signs and indicators of exploitation and considered relevant legislation and legal responsibilities. All professionals are requested to complete the Council’s modern slavery eLearning course before attending.
Additionally, Modern Slavery Single Point of Contact (SPOCS) Training was delivered to ASC staff who are their nominated SPOCS within their operational teams. The content mainly focussed on Modern Slavery Act (2015) Duty to Notify responsibilities, which included how to complete the NRM and Duty to Notify DtN forms. Following this a Community of Practice for SPOCs was facilitated, which provided an opportunity for the SPOCs to meet, share their learning experiences and discuss relevant topics. The aim is for these sessions to be facilitated 3 times a year.
In addition to the training available above, during the 2024/2025 financial year, a 1-hour training session on responsible contracting was delivered to 54 procurement and contracting staff on developing appropriate contract terms and conditions – including drafting contract KPIs and quality requirements, and lessons learned from current projects that can help inform our broader due diligence approach to managing modern slavery risks. This session was delivered by the Council’s SPL-MS. The procurement policy team also delivered a 1-hour training session to procurement staff to launch the revised Supplier Code of Conduct. The session aimed to improve staff’s understanding of the purpose of the Code of Conduct, how it should be used and what it is aiming to achieve.
Reporting concerns of modern slavery
For further information on modern slavery and how to spot the signs that someone may be a victim, please see: Unseen and GLAA.
Reports of suspected or actual cases of modern slavery can be made via the following channels.
Non-emergency concerns: call the Modern Slavery Helpline – 08000 121 700 or local police on 101 (ask for their Modern Slavery Team)
Emergency, immediate danger, or threat to life situation: call 999
East Sussex County Council Whistleblowing: Whistleblowing, fraud and corruption – strategy and policy documents | East Sussex County Council
Concerns for an adult with care needs: Adult Social Care and Health: 0345 608 0191
Concerns for a child with care needs: Single Point of Advice: 0132 346 4222
Approval of statement
This statement has been approved by the Corporate Management Team on 6 August 2025. It will be reviewed and updated on an annual basis.
Signed by: Becky Shaw, Chief Executive, and Councillor Nick Bennett, Deputy Leader/Lead Member for Resources and Climate Change
Date: 14 August 2025
Annex – Organisation policies
Council Constitution
Relevance to tackling modern slavery:
East Sussex County Council’s Constitution sets out the political decision-making arrangements used by the Council. It explains the responsibilities of the Council, the Members, and staff. The “Procurement and Contracts Standing Order” in the Constitution sets out how the Council authorises and manages spending and contracts with other organisations. This ensures that prior to any significant expenditure there is proper consideration of the need first of whether to buy at all and service the need internally, or if external expenditure is required that it is made in a fair, open and transparent way. The Standing Order covers issues pertinent to the anti-slavery agenda such as ensuring that supply chain partners operate fair and ethical working practices when purchasing goods, works and services. It also includes a specific section on modern slavery which requires Council officers to have regard to the risk of unethical labour practices in the supply chains of goods, services and works that being procured.
Whistleblowing Policy
Relevance to tackling modern slavery:
This policy provides a clear framework which is intended to give people the confidence to raise workplace concerns without fear of reprisal or victimisation. This policy applies to all Council employees. In addition, the policy applies to Members, all contractors and their staff working for the Council e.g., agency staff, consultants, and builders; also, providers of works, services, and supplies, including the Council’s external contractors and those providing services under a contract with the Council in their own premises. This policy is important for individuals wanting to raise concerns about modern slavery and/or related issues.
Code of Conduct and Conflict of Interest Policy
Relevance to tackling modern slavery:
This Code sets out the minimum standards of conduct that employees will be expected to observe when carrying out their duties. This includes encouraging and expecting employees, through agreed procedures and without fear of recrimination, to raise workplace concerns about risk, malpractice, or wrongdoing. Employees are expected to conduct themselves at all times (inside and outside of work) in a manner which will maintain public confidence in both their integrity and the services provided by the Council. This is relevant to the anti-slavery agenda as the Code expects employees to behave ethically and maintain high standards of personal conduct and be aware of and act in accordance with the Council’s values and behaviours.
Health and Safety
Relevance to tackling modern slavery:
The Council has various policies which aim to promote high standards and good practices in relation to health, safety, and welfare. This includes policies on: Personal Protective Equipment; Health and Safety; Stress Management and Risk Assessment; and Occupational Health and Wellbeing. These policies are important to tackling modern slavery as victims of forced labour and modern slavery may be at increased risk of work-related injuries due to inadequate protective equipment and health and safety measures, including appropriate training. Our Stress Management policy is also relevant to modern slavery as the Council recognises that while exploitation may not be present in the workplace, individuals could be controlled and exploited outside of the working environment. Consequently, identifying poor physical and mental health in the workplace linked to a worker’s personal life may uncover potential modern slavery practices.
Working Time Policy Statement
Relevance to tackling modern slavery:
The Council recognises that excessive overtime beyond permitted national legal limits can contribute to forced labour practices when coupled with forms of threat. The Working Time Policy Statement aims to ensure that managers know the legal limits on working hours and the minimum breaks required at work and between days of work. This policy explains the Working Time Regulations 1998, which places legal limits to working hours for most workers and provides a legal entitlement to rest breaks. This Policy applies to all “workers” (as defined in the Regulations) and the definition includes all contracted employees and temporary and casual workers engaged by the Council. Agency workers are covered by the Regulations but in most cases the agency will be the employer and will therefore retain responsibility for ensuring compliance with the Regulations. However, managers using agency workers are expected to ensure that the limits to working time and rest break requirements are applied to these workers when they are working for the Council.
Recruitment
Relevance to tackling modern slavery:
The Council recognises the importance of recruitment processes in identifying and responding to potential modern slavery cases. We have several recruitment policies in place that are relevant to the anti-slavery agenda.
In addition to policies such as the promoting diversity and equality of opportunity in employment (see below) we have a Recruitment and Selection Policy which sets out the procedure for recruiting and selecting staff at the Council. The policy is designed to ensure the recruitment and selection process is fair, open, and transparent and promotes equal opportunities to all groups throughout the local community. We also maintain a pre-employment checks policy, which provides information on checks that should be carried out to verify recruitment decisions.
The policy also provides guidance on the use of agency staff. The Council aims to fill all vacant posts with directly employed staff. However, where required the Council has an appointed managed service provider for temporary agency workers. The Council’s Human Resources team support hiring managers in the recruitment process, including handling issues about the service provider and safeguarding alerts involving an agency worker.
The Council also has several policies on Disclosure and Barring Service (DBS) checks, which enable checks to be used for assessing the suitability of candidates in relevant roles. The policies provide guidance on the effective use of the DBS Disclosure process to safeguard the children and adults who access our services. Agency workers, contractors, sub-contractors, and volunteers are assessed against the same criteria as those working directly for the Council if a DBS is required.
The Council recognises that victims of modern slavery can be exploited in legitimate jobs with legal terms of employment but exploited by others unrelated to the Council. Therefore, the above policies are important to ensure that potential victims and vulnerabilities are identified during the resource and recruitment process, including the use of temporary workers employed via an agency. Additionally, the policies are relevant to the anti-slavery agenda as they cover aspects of work where vulnerable people accessing our services could be taken advantage of and exploited.
Grievances, Workplace Conflict and Mediation
Relevance to tackling modern slavery:
We have several policies and procedures on grievance, workplace conflict and mediation. This includes:
Grievance and Workplace Conflict Policy: This policy sets out the Council’s approach to handling grievances, including its expectations that complainants are not discriminated against or victimised for having brought a complaint, and ensuring that confidentiality is maintained at all times, including after any procedures have concluded.
Promoting Diversity and Equality of Opportunity in Employment:
This policy ensures equal access to opportunities in employment and promotes diversity in our workforce.
Dignity at Work: This document provides guidance on ensuring that colleagues are treated with respect and dignity in the working environment.
Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns.
The Council also recognises that certain vulnerable, marginalised, and underrepresented groups are at a higher risk of poor labour and employment practices and therefore the above policies ensure that every member, manager, and employee have a duty to be aware of equality issues in their daily activities.
Domestic and Sexual Abuse Policy
Relevance to tackling modern slavery:
This policy sets out the principles and standards that the Council will apply in supporting employees who have experienced, or are experiencing, domestic abuse and where there are concerns that an employee may be the perpetrator of domestic abuse. This includes types of abuses such as psychological, physical, sexual, financial, and emotional. The principles and standards apply to all employees, agency workers, contractors and their staff whilst working for, or on behalf of, the Council. While this policy focuses specifically on domestic and sexual abuse, it is important for tackling modern slavery as cases may share similar indicators of abuse.
Trade Unions
Relevance to tackling modern slavery:
East Sussex County Council has agreements with unions to provide facilities to help them to represent members at all levels. Relevant policies include:
Trade Union Facilities Policy: This policy sets out the principles to underpin good working relationships between the Council and recognised trade unions by affording the trade unions the necessary time and appropriate access to facilities to discharge their duties.
Employee Relations Policy: This policy sets out areas of responsibility regarding employee relations. It also sets out the Council’s position on trade union recognition, collective bargaining, and joint consultation, as well as disputes, discipline, and grievance.
The Council recognises that trade union representation in the workplace can help reduce the risk of modern slavery by representing the interest of workers, ensuring fair working practices, supporting workers in negotiating their terms and conditions, and the resolving of grievances.
Sussex Safeguarding Adults Policy and Procedures
Relevance to tackling modern slavery:
The Policy sets out the approach taken to adult safeguarding across Sussex. The Procedures explain how agencies and individuals should work together to put the Sussex Safeguarding Adults Policy into practice. They have been updated in accordance with the Care Act 2014 and the Care and Support Statutory Guidance and should be read in conjunction with these. This policy and procedures provide an overarching framework to ensure a proportionate, timely and professional approach is taken, and that adult safeguarding is co-ordinated across all relevant agencies and organisations. This is essential for the prevention of harm and abuse.
Sussex Child Protection & Safeguarding Policy and Procedures
Relevance to tackling modern slavery:
Brighton and Hove, East Sussex and West Sussex Local Safeguarding Partners have commissioned the policies and procedures in this manual, which reflects a significant consensus about best practice across the three areas, and all those agencies in Sussex that contribute to the prevention, detection and investigation of abuse or neglect, risk management of offenders and the support and treatment of those affected. The development of the procedures manual is one of the core functions of the safeguarding partners in their role to coordinate local work to safeguard and promote the welfare of children. The procedures encourage close working between agencies to facilitate early intervention in a supportive way to meet the needs of children and their families.
Supplier Code of Conduct
Relevance to tackling modern slavery:
The Council believes that its supply chain plays a vital role in making a positive contribution to its communities and society. Procuring in an ethical, fair, responsible and sustainable way which allows us to work with successful bidders to align with our policy objectives is a priority. The Council's Supplier Code of Conduct embeds these policy objectives and provides a detailed expectation of our supply chain. We expect our suppliers and their supply chains to follow three key principles which focus on people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly, maintaining high standards of integrity and professionalism in their business dealings.