1. Introduction
This is Plymouth City Council’s Modern Slavery Statement for the financial year ending March 31, 2023. This Statement meets the voluntary requirements of Section 54 of the Modern Slavery Act (2015). It explains the steps that the Council took in the past year to identify, prevent and mitigate modern slavery in its operations and supply chains as set out in the Co-operative Party Charter Against Modern Slavery which the Council first signed up to on 17 September 2018.
Plymouth City Council and its group of companies acknowledge the risk that modern slavery poses to individuals and communities. It supports implementation of the Modern Slavery Act (2015), and the strengthening of the legislation as set out in the Queen’s Speech in May 2022. It also acknowledges the forthcoming changes to the Government’s approach to modern slavery following the introduction of the Immigration Migration Bill to the House of Commons in March 2023.
Plymouth City Council is committed to eliminating the practices and conditions which may allow modern slavery to occur. The Council is part of the Anti-Slavery Partnership and works with partners and agencies across the South-West Peninsula and takes a collaborative approach to tackling the issue of modern slavery.
Progress has been made in addressing the content required within this Statement. We have made several commitments within this statement to ensure that we continue to monitor and take steps to tackle modern slavery within the city and our supply chains.
2. Our policies and procedures
Our commitment and overarching approach to tackling modern slavery is set out in our Modern Slavery Policy. The Council also has several policies and processes which promote transparency and accountability when combatting modern slavery, such as our safeguarding and whistleblowing policies.We encourage our staff to blow the whistle on any suspected examples of modern slavery.
During the financial year 22/23 we have:
- Undertaken an annual review of our Modern Slavery Policy and checked alignment to our new Corporate Plan.
- Continued to monitor legislation passing through parliament to identify any impacts on how we work with communities.
3. Our procurement activity and supply chains
Plymouth City Council is an organisation with over 2,000 employees with an annual contracted spend of approximately £350m across both a local and national supply chain of over 3,500 different organisations. The Council, alongside its family of companies, delivers a range of services and support to Plymouth residents, communities and businesses.
The Council works in partnership with Destination Plymouth, Plymouth Waterfront Partnership, Plymouth City Centre Company and Plymouth Science Park, amongst others to bring investment into the city and to support our visitor economy.
During the financial year 22/23, to minimise the risk of modern slavery within our supply chains we have:
- Required contractors to comply fully with the Modern Slavery Act (2015), wherever it applies – this is set out within Plymouth City Council (PCC) terms and conditions, which cover the large majority of our procurement and commissioning activity.
- Required our contractors to adopt a whistle-blowing policy so that they can blow the whistle on any suspected examples of modern slavery.
- Challenged abnormally low tenders as part of our standard procurement approach.
- Worked with Catered to develop and publish a Corporate Social Responsibility Policy including considerations on Modern Slavery
- Managed our illicit activity risk log for the Plymouth and South Hams Freeport to identify the risk of modern slavery from the initiative.
- Highlighted to our suppliers that contracted workers are free to join a trade union and are not to be treated unfairly for belonging to one.
- Registered for the Modern Slavery Assessment Tool and have begun exploring how it can be used within the Council.
To further combat the risk of modern slavery within our supply chains in the financial year 23/24 we will:
- Fully understand the Modern Slavery Assessment Tool and its potential impacts to the supplier base and explore rolling it out across Council contracts.
- Report by exception on tender submissions which have been omitted due to the tenderer failing on modern slavery exclusion grounds within our standard procurement documentation.
- Continue to work with our family of companies to ensure compliance with the Modern Slavery Act (2015).
- Continue to carry out robust checks on providers prior to using them in high risk areas such as adult social care.
- Develop a bespoke modern slavery dashboard in high risk areas such as adult social care to allow information to be easily accessible and scrutinised.
4. Employees and members
Our belief in democracy, responsibility, fairness and co-operation alongside our commitment to the Nolan Principles of Public Life minimises the likelihood of modern slavery occurring within the Council. We have rigorous procurement and commissioning procedures and HR policies in place and expect high standards and behaviour from all our employees. We acknowledge the important role that our employees and members have in tackling modern slavery.
Our People Strategy 2020 - 2024 sets out our vision for how we will work successfully, both with those who currently work for us and our future colleagues and partner organisations. We are committed to ensuring an equitable, transparent and fair approach to rewarding our employees and are proud of our adoption of the principles of the Foundation Living Wage, which sit alongside our job evaluation and grading system.
During the financial year 22/23, to minimise the risk of modern slavery within our organisation we have:
- Ensured the effective implementation and monitoring of our HR policies.
- Provided an employee assistance programme (EAP) to help support employees to deal with difficult and distressing situations including modern slavery.
- Required employees and members to conduct themselves in accordance with the ‘Officers Code of Conduct’ and ‘Councillor’s Code of Conduct’ respectively.
- Provided specific training and awareness for staff and partners in high-risk areas to address and highlight the requirements of the Modern Slavery Act.
- Required commissioning and procurement colleagues to complete the CIPS Ethical Procurement and Supply training module.
- Followed our safeguarding policy and processes when appropriate.
- Refreshed the Council’s modern slavery webpages and shared communications to staff on our internal network to raise awareness
- Provided training to members on how they can identify and report suspected modern slavery.
To further reduce the risk of modern slavery within our organisation in the financial year 23/24 we will:
- Continue to raise awareness of modern slavery and promote the referral mechanisms (and any changes arising from the Immigration Bill) for employees, suppliers and those in our communities, for reporting any concerns around modern slavery.
- Continue to promote our modern slavery e-learning course to all employees.
- Refresh the Modern Slavery Tool Kit and share it with employees and partners.
- Publish a modern slavery procurement guide to help officers understand modern slavery risks during their procurement activities.
5. Undertaking due diligence and managing risk and performance
This statement recommits us to continue to tackle modern slavery within our organisation and supply chains. This can be found on our website. We will ensure that progress against this statement is tracked and that the take up of any learning and development opportunities is closely monitored.
The Council is prioritising steps to achieve greater supply chain visibility. By increasing the visibility of our supply chains, the council will gain a better understanding of how and where to target our due diligence activity and what measures and goals we will need to set for ourselves in the future.
From an operational perspective, the Council has collaborated extensively with partners to identify and address modern slavery in the city - supporting the identification of victims and working to disrupt offenders.
6. Reporting concerns
If you suspect that someone is in immediate danger, always contact Devon and Cornwall Police on telephone 999.
If a Council employee suspects modern slavery they should contact their line manager at the earliest opportunity and report their concerns.
Managers should ensure that Community Connections are aware of any suspected modern slavery cases and should contact the Community Connections Strategic Manager with responsibility for modern slavery (Tracey Naismith, tracey.naismith@plymouth.gov.uk).
Further information, help and assistance in combatting modern slavery can be found on our website.
Information about the Modern Slavery Act can be found on GOV.UK.
7. Approvals
This Statement was agreed by Plymouth City Council’s Cabinet on: 14.08.2023
Cllr Tudor Evans, Leader Plymouth City Council
This statement was approved by Plymouth City Council’s Corporate Management Team on:
Tracey Lee, Chief Executive