Slavery and human trafficking statement (2018-19)
This statement explains how Durham County Council aims to understand and address all potential modern slavery and human trafficking risks related to its business. It outlines the steps in place to ensure modern slavery or human trafficking does not occur in the Council's own business, and the preventative measures to ensure this extends to any of its supply chains. This statement is subject to continual annual review and will be published on the Council's website.
Durham County Council as a public sector organisation as an employer, community leader and a procurer is committed to undertaking a preventative approach to modern slavery and human trafficking within its corporate responsibilities and activities. This also includes co-operating with partners and internal services, such as, adult care, human resources and corporate procurement to work towards the disruption of such activities.
Organisational Structure and Supply Chains
County Durham is the largest local authority in the North East of England with over half a million residents. The population size has risen consecutively over the last 14 years. Durham County Council provides a range of services, including Children's Services, Adult and Health Services, Public Health, and Environmental Services. The Council directly delivers some services but also works in partnership with other organisations and commissions and procures services externally, in 2017-2018 the total third party spend was £450.11 million. Specific services covered by this statement illustrated in the structure below.
Durham County Council agreed with stakeholders in 2016 that the mechanism to seek assurance of a commitment to improving practice, and preventing slavery and human trafficking sits with the Local Safeguarding Adults Board governance arrangements.
Slavery and human trafficking also spans wider partnerships, such as, the Durham Safeguarding Children Partnership and Safe Durham Partnership.
There is a clear expectation that external services or goods procured by the Council be undertaken in conjunction with organisations operating their own policy and practice in relation to modern slavery.
All suppliers bidding in Durham County Council's procurement processes must state whether they are a relevant commercial organisation as defined by section 54 ("Transparency in supply chains etc.") of the Modern Slavery Act 2015 ("the Act"). If they are, they are required to confirm their compliance with the annual reporting requirements contained within Section 54 of the Act. Failure to meet these requirements are treated as a ground for Mandatory Exclusion. The above approach adopted by Durham County Council is in line with that developed by Crown Commercial Services, the executive agency and trading fund of the Cabinet Office of the UK Government, and is utilised nationally across the public sector.
In addition to addressing its obligations during the procurement process, the Council undertook an assurance activity (with 250 of its key suppliers) to ensure that relevant organisations/suppliers produce and publish an annual slavery and human trafficking statement each year. The statement summarises the steps organisations have taken to ensure that slavery is absent from their supply chains in line with the Modern Slavery Act.
Durham County Council has an expectation that any organisation with which we work, commission a service or procure a service from, operates appropriate policy and practice in relation to modern slavery.
In line with requirements placed upon Durham County Council, there is commitment to ensuring there is no modern slavery and/or human trafficking in our supply chains.
Durham County Council has a corporate crosscutting role as an employer, community leader and procurer with responsibility to safeguard people within our communities. This extends responsibilities to Adult Social Care, Children's Social Care, Housing, Corporate Procurement, Human Resources as well as Community Safety. Durham County Council works closely with Durham Constabulary and other enforcement agencies as appropriate to share intelligence and work collaboratively to address issues relating to modern slavery or human trafficking. In 2017-2018 and working with partners, guidance and clear pathways to support and signpost victims for appropriate support has taken place.
As a Council, there are a wide range of policies and processes in place that reflect our commitment to prevent modern slavery and human trafficking in everything that we do.
All policies are subject to a robust assurance process, and agreed by the relevant board or committee. This can include councillors, senior officers and/or partner organisations.
Employee Code of Conduct (August 2017) - Durham County Council expects high standards of conduct from its employees. This code sets out the minimum standards expected of all employees, including treating others with dignity and respect and in fair and impartial manner in line with the Council Equality policy. Employees will adhere to all standards set out it in the code inclusive of procurement activity.
Confidential Reporting Code (August 2017) - Durham County Council confidential reporting (whistleblowing) code reiterates a commitment to the highest possible standards of openness, honesty and accountability. 'Whistleblowing' is the term used when an employee passes on information concerning wrongdoing. Often referred to as 'making a disclosure' or 'blowing the whistle'. The code applies to employees, former employees, job applicants, and agency staff working for the council, contractors and suppliers. All individuals to whom the code applies can utilise it to report any concerns that may infer a heightened risk of modern slavery or human trafficking in relation to Council activities and/or its supply chains.
Equality & Diversity Policy (2016 and 2017) - The Council as a major employer and provider of services is committed to advancing equality of opportunity and providing fair access and treatment in employment and when delivering or procuring services, or working in partnership. The Council in its two Equality and Diversity Policies for both its citizens and employees makes clear its responsibility under the public sector equality duty under the Equality Act 2010. Effective procurement can drive progress in equality and embed real improvement. Equality is therefore considered and embedded in the Corporate Procurement Strategy, and ensures commissioned services are appropriate and responsive to different groups.
Corporate Procurement Strategy (2016 - 2018) - Thecovers the period up to the financial year of 2018 and is in line with the Altogether Better vision of the Council. The Council aims to ensure that all commissioning and procurement activities carried out in collaboration do so in an economically, environmentally and socially responsible manner. This includes ensuring high-risk works and services are subject to effective evaluation, and contributing to community cohesion by addressing equalities issues in the supply chain.
Recruitment and Selection Policy (2017) - The Council undertakes its own recruitment activity through in-house functions. Robust processes are in place to ensure that the policy is adhered to and all employees with a responsibility for recruitment and selection must be aware of their legal obligations under existing employment legislation. Agency appointments are subject to the same rigour as Council appointed employees, for example, DBS checks (where applicable); proof of eligibility to work in the UK; any gaps in employment history. The Council through its corporate procurement seeks assurance that its Agency supplier is complying with its duties under the Act.
Domestic Abuse and Sexual Violence - The Safe Durham Partnership (SDP) has 'protecting vulnerable people from harm' as a key priority of its overarching plan for 2016-2019. Its vision is to ensure every adult and child will be, and will feel safe. This includes working with partners to prevent domestic abuse and sexual violence and reducing the associated harm. Access to help and support through services is available to address needs. It includes improving the criminal justice response to tackling domestic abuse, sexual violence and sexual exploitation. Adult Care and Children Services are active members of the local Domestic Abuse and Sexual Violence Executive Group.
Safeguarding People in our Communities - The Council has a duty to safeguard people in our communities and for ensuring policies are in place to protect vulnerable groups from harm and abuse. The Care Act 2014 sets out duties in relation to safeguarding adults and for children the duty comes from the Children Act 1989. Working Together to Safeguard Children 2018 sets out the expectations of all agencies involved in the safeguarding function. All Children and Adult Care teams of the Council hold responsibilities to meet these duties on a daily basis.
A wide range of information is accessible to staff across both service groupings and wider service areas. This extends to modern slavery and human trafficking.
The Local Safeguarding Adults Board in line with statutory requirements set out within the Care Act 2014 have an agreed multi-agency safeguarding policy and procedure in place. A full review of policies and procedures will take place during 2018-2019.
In addition, work has taken place over the last year, to develop modern slavery and sexual exploitation referral pathways that work in correlation to the Safe Durham Partnership multi-agency domestic abuse referral pathway and local safeguarding children arrangements and will be incorporated into revision work.
The Durham Safeguarding Children Partnership have up to date on-line procedures in relation to domestic abuse, child sexual exploitation and modern slavery.
The Council has responsibilities to its workforce, this includes employee health, safety and welfare.
As part of the Council commitment to the welfare of its workforce, any employee can raise concerns and have assurance from the Council that their concerns will be taken seriously.
Managers regularly undertake supervision or 1-1 sessions with staff during which health and safety or health and wellbeing concerns that an employee may have can be discussed.
The Council also offers work related and personal advice and support to its employees covering a broad range of issues from better health at work, to victims of crime. Employees have access to 24-hour confidential support, 365 days per year and to contacts for external support.
Training & Awareness Raising
To meet its statutory safeguarding responsibilities, the Council offers a wide and extensive training programme to staff across all services.
In 2016-2017 the Council led on Safeguarding, the Care Act and You training. This training introduced the subject of modern slavery to Council staff and the wider workforce and follows modern slavery as a recognised category of abuse for safeguarding adults. A total of 586 staff including the wider workforce accessed the Safeguarding, Care Act and You training.
During 2017, briefings started aimed at raising awareness of modern slavery and human trafficking, led by the Local Safeguarding Adults Board and Police. The briefings include key messages of the signs and indicators of modern slavery and human trafficking, sharing of intelligence and the relevant referral pathway for potential victims, including the National Referral Mechanism and accessible support for victims.
Partner agencies and providers including the voluntary sector can access the briefings for cascade within their own organisation. To date there have been 10 briefings to over 198 employees, inclusive of partner agencies, providers and the voluntary sector.
There is a planned continuation of key communications, briefing sessions and training accessible to all Council employees across all service groupings and the wider workforce for 2018-2019.
Training numbers captured throughout the year will support gaining an accurate picture of the wider workforce trained. It also offers further assurance of the delivery of a standardised message across the wider workforce.
If any staff, witness or suspect modern slavery or human trafficking is taking place, they can seek advice or report their concerns to the police on 101. In line with statutory responsibilities and related guidance for local authorities, the police and others, may need to make a notification where a potential victim of modern slavery is identified to the National Referral Mechanism.
Further information is available from the Safeguarding Adults Inter-Agency Partnership: Training and Local Safeguarding Children Board: Training pages.
As a partner of the Local Safeguarding Adults Board and Durham Safeguarding Children Partnership the Council is committed to raising the profile of modern slavery and human trafficking. The Local Safeguarding Adults Board on behalf of its partners and in
line with its awareness raising priority have shared key messages through its quarterly newsletter.
Council intranet pages are a vital platform to share information with employees; Council Directors of Service Groupings are committed to connecting with employees and cascading relevant updates on legislation and guidance.
Durham County Council is committed to and understands the vital role procurement plays in its functions. This includes the consideration and recognition when sourcing any provision that effective employment practice takes place and all modern slavery and human trafficking practices is discouraged.
Due diligence actions must be carried out at all times in collaboration, between Contract Managers and Corporate Procurement Officers, to ensure before awarding any contracts to prospective bidders the Council meets its legal obligations under the new Modern Slavery Act 2015.
Where suppliers fail to meet their appropriate obligations under the Modern Slavery Act 2015, the issue should be raised by the assigned Contract Manager, in order to protect the Council's reputation and remain compliant under the new regulations going forward.
Regular monitoring and assurance activities take place to ensure compliance of suppliers' obligations under the Modern Slavery Act by all Local Authorities.
Durham County Council submits a Safeguarding Adults Collection (SAC) on an annual basis to NHS Digital. The return currently includes voluntary data for modern slavery reported concerns for adults with care and support needs. In 2017-2018, there were less than six* reported concerns to Social Care Direct for suspected Modern Slavery. To ensure the safety of potential victims, each report is actioned in line with requirements upon the Council. Following review of each case, and if applicable, a duty to notify in line with Section 52 of the Modern Slavery Act 2015 is completed and any support requirements for potential victims is addressed.
This statement is made pursuant to Section 54 (1) of the Modern Slavery Act 2015 and constitutes Durham County Council's slavery and human trafficking statement for the term of the financial period of 1 April 2018 to 31 March 2019.
* number suppressed for confidentiality reasons