Modern slavery and human trafficking
As commissioners of care and statutory partners of Safeguarding Adult Boards and Safeguarding Children Partnerships, NHS Greater Manchester [NHS GM] plays a key role in supporting the work and strategic priorities in tackling modern slavery and human trafficking.
NHS GM fully supports the Government objective to eradicate modern slavery and human trafficking and recognises the significant role the NHS must play in both combatting it and supporting victims. We are strongly committed to ensuring commissioned services and supply chains are compliant with relevant legislative requirements.
NHS GM acknowledge the provisions set out in the Modern Slavery Act 2015 and will ensure it is open and transparent and effectively utilise its own due diligence to ensure that there is no evidence of acts of modern slavery or human trafficking within the organisation.
As both a local leader in commissioning healthcare for the population of Greater Manchester and as an employer, NHS GM provides the following statement in respect of its commitment to, and efforts in preventing modern slavery and human trafficking practices in the supply chain and employment practices.
Our commitment to preventing modern slavery and human trafficking
NHS GM aims to address this risk through:
- Being committed to ensuring there is no modern slavery or human trafficking within our commissioned services and/or supply chains in any part of our business
- Adhering to National NHS Employment Standards which includes employees UK address, right to work in the UK and suitable references.
- Have in place systems to encourage the reporting of concerns and the protection of staff via Freedom to Speak Up
- Continue to build relationships with our Providers and make clear our expectations of business behaviour. We expect local, national, and international supply chains to have suitable anti-slavery and human trafficking policies and processes in place.
- Include modern slavery and human trafficking within NHS Greater Manchester ICB Safeguarding Children and Adults at Risk Policy.
- Provision of a multi-agency approach to raising awareness of modern slavery and human trafficking coordinated by the Greater Manchester Challenger Executive Board.
- Provide accessible modern slavery and human trafficking information and training for our workforce.
Our arrangements for preventing modern slavery and human trafficking
NHS GM aims to be as effective as possible in ensuring modern slavery and human trafficking do not take place in any part of our business by:
Maintaining strong relationships with safeguarding leads in our Provider organisations to ensure:
- Adherence to the Working Time Directive 1998
- There are safe and fair working conditions for staff
- The risks within their own supply chain are understood
- There is responsible management and compliance with all legal requirements, reflected in policies, procedures and in contracts with suppliers.
- Working with partners across Greater Manchester to identify safeguarding referrals relating to modern slavery and human trafficking and subsequent outcomes of investigations.
- Continuing NHS employment checks and payroll systems [e.g., People brought into the country illegally will not have National Insurance numbers and adhering to the minimum wage requirements]
- Ensuring communication with our commissioned Providers in the supply chain and being aware of their understanding of, and compliance with, our expectations in relation to NHS terms and conditions including modern slavery and human trafficking.
- Our recruitment processes being robust and adhering to safer recruitment principles including identity checks, work permits and criminal records in line with Recruitment and Selection Policy.
- Having policies in place including Freedom to Speak Up and Raising Concerns, Dispute Resolution and Equality and Diversity to demonstrate our commitment to support our employees’ raising concerns about poor working practices.
- Ensuring our Procurement Policy sets out how we will procure goods and services within the requirements of procurement legislation and regulation. Both NHS Terms and Conditions for non-clinical procurement and NHS Standard Contract for clinical procurement requires suppliers to comply with relevant legislation.
- Raising awareness during 2024-25 of the Modern Slavery Act 2015 internally as part of all procurement processes including requesting all providers to set out their plans and arrangements to prevent modern slavery and human trafficking in all their activity and supply chains.
- Continuously review of our internal processes and monitor our actions against modern slavery and human trafficking.
- Working in partnership with our local Adult Safeguarding Boards, Safeguarding Children Partnerships and Community Safety Partnerships, Greater Manchester Challenger Executive Board and contribute too and influence the work of NHS England regionally and nationally.
NHS GM fully recognises that combatting modern slavery and human trafficking requires a coordinated, collaborative, and long-term approach.
This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our modern slavery and human trafficking statement for the financial year ending 31st March 2025.
