Modern slavery

Last updated: 27 January 2025

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.

Gloucestershire Hospitals NHS Foundation Trust (“The Trust”) fully supports the Government’s objective to eradicate modern slavery and human trafficking and recognises the significant role the NHS has to play. We are strongly committed to ensuring our supply chains and operational activities are free from ethical and labour standards abuses.

Slavery and human trafficking statement for financial year ending 31 March 2025

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Trust’s Slavery and Human Trafficking statement for the financial year ending 31 March 2025.

The Trust’s Commitments

The Trust supports and respects the protection of human rights for all its employees and workers within its supply chain. We believe in treating individuals with respect and dignity, and do not condone the use of our products or services which infringe the basic human rights of others. We expect our suppliers and business partners to adhere to the same high standards and to take all reasonable steps to combat slavery and human trafficking. The Trust has in place due diligence procurement and tendering processes to ensure all its selected suppliers and any third parties are compliant with the Modern Slavery Act (2023)

The procurement of goods and services

• Procurement ensures all procurement activates are undertaken in line with UK legislation, industry best practice and national policy on tackling modern slavery in government supply chains. The embedding of social value and associated modern slavery elements into all procurements and contracts.
• All procurement staff have completed eLearning on the Government Commercial College (GCC) with the Chartered Institute of Procurement and Supply (CIPS) qualified members also completing the annual CIPS Ethical Procurement and Supply e-learning.
• A large proportion of the goods and services are procured through national Government supply frameworks and contracts also require suppliers to comply with relevant legislation. We continue to work with our suppliers directly and via partners, such as NHS Supply Chain and Crown Commercial Services, to support initiatives related to modern slavery.

The recruitment of staff

Our robust recruitment processes are in line with relevant employment legislation and adhere to safe recruitment principles:

• 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 in line with NHS employment check standards. This ensures that we can be confident, before staff commence duties, that they have a legal right to work within our Trust.
• Only approved frameworks are used for the recruitment of temporary agency staff.
• 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.

The working conditions and practices for our employees

The Trust is committed to ensure that:

• Employment with the Trust and our suppliers is voluntary;
• Our workplace and those of our suppliers are free from discrimination or harassment based on race, colour, religion, gender (including pregnancy), sexual orientation, marital status, gender identity, national origin, age, disability, or any other characteristic protected by applicable law;
• Our workplaces are safe and healthy;
• We have various employment policies and procedures in place designed to provide guidance and advice to staff and managers but also to comply with employment legislation.
• Our Equality, Diversity and Inclusion policies, together with our Grievance, Dignity at Work and Raising Concerns policies additionally give a platform for our employees to raise concerns about poor working practices.
• Our policies and practices promote and support equality, diversity and inclusion both as an employer and service provider; we recognise and acknowledge that diversity and inclusion are key corporate social responsibilities.
• 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 staff.
• We provide advice, training and support about modern slavery and human trafficking to all staff through our safeguarding children and adults mandatory training, our safeguarding policies and procedures and our safeguarding teams.
• Our Trust “Safeguarding Adults at Risk Policy”, and the countywide multi-agency safeguarding policy, to which our Trust is a partner signatory, also includes modern slavery and we have produced communications materials to raise awareness amongst staff and anyone working on or otherwise attending our sites.

Review of effectiveness

The Trust will continue to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly within supply chains. We aim to:

• raise awareness and support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working at our Trust can have in keeping present and potential future victims of modern slavery and human trafficking safe
• ensure that all staff continue to have access to training on modern slavery and human trafficking which will provide the latest information and the skills to deal with it
• embed social value best practice into commercial processes which will achieve improved social value awareness and compliance across all our commercial activities
• impact assess all new or reviewed policies for diversity and inclusion compliance.

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Trust’s Slavery and Human Trafficking statement for the financial year ending 31 March 2025