LGA Transparency Statement on Modern Slavery and Human Trafficking

Introduction 

1.    This statement sets out the Local Government Association’s (LGA) actions in working to understand all potential modern slavery risks and to put in place steps that are aimed at ensuring that there is no modern slavery or human trafficking in its own business and its supply chains.

2.    The LGA recognises its responsibility to take a robust approach to modern slavery and human trafficking. The organisation supports the Modern Slavery Act 2015 and opposes modern slavery and human trafficking. It is committed to ensuring that such practices have no place within its supply chain or other activities. The LGA has adopted a risk-based approach to tackling modern slavery in our supply chain and focuses our efforts on those areas where it will have the greatest impact albeit this is rare due to the nature of what we procure.

3.    In addition to the LGA’s responsibility as an employer, it also acknowledges its duty to notify the Secretary of State of suspected victims of modern slavery or human trafficking as introduced by section 52 of the Modern Slavery Act 2015.

4.    For the purposes of this document we have followed the Government’s six areas of activity set out in; Transparency in supply chains: a practical guide and the LGA’s Modern Slavery: Transparency in supply chains statements. We additionally adhere, as far as possible, as best practice, with the Procurement Policy Note (PPN) on Tackling Modern Slavery in Government Supply Chains, and refer to this as a point of continuous improvement. 

Definition of Modern Slavery 

5.    The term ‘Modern Slavery' captures a range of types of exploitation, many of which occur together. These are defined by  Unseen UK to include but are not limited to: 

• Sexual exploitation: this includes sexual abuse, forced prostitution and the abuse of children for the production of child abuse images/videos. 
• Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties. 
• Forced labour: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars). 
• Criminal exploitation: This can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker. 
• Human trafficking: this requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. 
• Other forms of exploitation: organ removal; forced begging; forced benefit fraud; forced marriage and illegal adoption.

The LGA and anti-Modern Slavery and Human Trafficking

For our members

6.    The LGA has produced comprehensive guidance for councils on modern slavery. Alongside an overview of modern slavery and the UK framework for tackling it, there are targeted sections for officers working in different council services such as children’s services, adult social care, housing, community and regulatory services, as well as a section on supply chains. The guidance is supported by a maturity matrix providing a framework for councils to assess their current progress and plan future activity on modern slavery. Additionally, our modern slavery webpage has a number of other resources, including case studies, a councillor guide and some more specific guidance on hand car washes. 

7.    We have also produced guidance to help councils produce their own transparency statements: Modern Slavery: Transparency in supply chains statements. The LGA also hosts a portal of council transparency statements.

8.    The LGA has established a modern slavery network  for council officers leading on work to tackle modern slavery. The network is a council officer only space, meets quarterly via teams and aims to share good practice, discuss current issues, and provide help and support.

9.    With respect to international recruitment into Adult Social Care where there may be some links to modern slavery, Partners in Care and Health have been working with government to support the sector. With regard to support for councils we have developed a guide on international recruitment to adult social care. In particular it examines:

• What does good international recruitment look like
• Key elements in ethical international recruitment 
• Responsibilities of Directors of Adult Social Services

Within our own business 

10.    We have a number of policies and procedures in place which are reviewed and updated annually that contribute to ensuring modern slavery does not occur in our business. These include: 

• Whistleblowing policy: The organisation encourages all its employees and those employed on a contract for service or through an agency to report any concerns related to the direct activities, or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of modern slavery or human trafficking.
  The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. 
• Recruitment/Agency workers guidance documents: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
• Robust recruitment procedure: For both substantive staff and agency workers. This process is compliant with UK employment legislation and includes a number of pre-employment checks, for example “right to work” document checks, obtaining references and understanding any employment gaps. Banking information is verified by Payroll to ensure salary payment is going to an individual’s account and not a business account.  DBS checks are undertaken for relevant posts. 
• Awareness-raising: The organisation has raised awareness of modern slavery issues within the organisation by requiring all LGA employees to complete the mandatory e-Learning module on Modern Slavery, covering the basic principles of the Modern Slavery Act 2015. 
• Internal Expertise: We now have 2 Chartered Institute of Procurement and Supply (CIPS) qualified members of staff who completed modules in ethics and modern slavery

Training/Awareness 

11.    The LGA raises awareness of modern slavery issues on an annual basis by circulating informative internal communications and requiring all LGA employees to complete a mandatory e-Learning module on Modern Slavery. This module covers the basic principles of the Modern Slavery Act 2015 and provides an overview on:

• the legislation and reference to Section 54 of the act (transparency in supply chains) 
• how employers can identify and prevent slavery and human trafficking;  
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation;  
• what external help is available, for example through the Modern Slavery Helpline. 
• recognise how modern slavery can manifest in supply chains.
• spot modern slavery risks in procurement 
• drive improvements in modern slavery due diligence to create better  outcomes for workers

For our supply chain 

12.    The risk of modern slavery in a contract is not linked to its value, as even when a contract is below threshold/low value, the modern slavery risk can be high. We ask questions about modern slavery risks if they are relevant to the contract and are proportionate. The mitigation of modern slavery risks is considered throughout the procurement process.

13.    Given the type of services that the LGA procures these risks are extremely low in the majority of cases. We do not adopt a blanket approach to managing modern slavery risks and our approach is proportionate based on the risks identified. However, we often use the self-declaration, due diligence and self-cleaning processes as set out in the aforementioned PPN.

Assessing and managing risk

14.    Whilst the LGA has produced guidance on Modern Slavery in the supply chain for councils, our own spend categories and supply chains are much smaller and distinctly different to the councils we advise.

15.    As an organisation a large portion of our non-core staff expenditure goes on bought in services from small to medium sized companies (SME) and professional organisations. None of these services are flagged as high-risk categories in relation to modern slavery and are often sole traders

16.    Having said this we have identified some contracts and supply chains that are potentially high risk in relation to modern slavery. These include facilities management, catering, security and cleaning as they may include:

•  Complex employment relationships; a reliance on agency, outsourced or subcontracted workers  
•  Reliance upon low-skilled or unskilled labour;  
•  High numbers of temporary, seasonal, or agency workers;  
•  Dangerous or physically demanding work  

17.    The below sets out some of the ways that we mitigate against modern slavery:

• Procurement policy: The policy sets out the LGA’s overarching approach to its procurement of goods and services including modern slavery concerns. Accompanying documents include a Suitability Assessment Questionnaire for suppliers to complete in high value/ above threshold procurements which covers modern slavery.  
• We review and revise our standard terms and conditions, and our purchase order terms and conditions templates for the procurement of consultancy, goods and services to ensure appropriate contractual provisions are in place in relation to modern slavery on a regular basis. These provisions include the need for suppliers to take all necessary measures to ensure that nothing relating to dealings in respect of the LGA, or otherwise within a supplier’s business and supply chain, involves slavery or human trafficking.
• Supplier Assessment: In the recent review of our procurement related policies, procedures and templates we considered whether to embed anti-modern slavery and human trafficking criteria into the evaluation of potential suppliers but decided not to include modern slavery compliance as an independent evaluation point for low value or individual’s contracts due to the low-risk nature of the services.

This decision remains under review and will be addressed again as we produce and embed the new procurement processes and templates for compliance with the Procurement Act 2015.

Aims for our continuous improvement   

18.    The LGA’s focus for the next 12 months with regards to the Modern Slavery Act 2015 are as follows:

For our members

19.    The LGA’s Safer and Stronger Communities policy team will continue to support councils’ work to tackle modern slavery by continuing to run the LGA’s modern slavery policy network.

20.    We will also be creating a knowledge hub page to enable councils to share modern slavery awareness training materials, ensuring all councils can learn from and access best practice.

21.    Additionally, officers will be updating the LGA’s councillor guide on tackling modern slavery to support elected members to effectively scrutinise local work to prevent modern slavery.

Within our own business and for our supply chain

22.    As a means of carrying out due diligence on the key suppliers identified in the higher risk categories the LGA will review and evaluate high risk supply chains, periodically (and where required)  using the Modern Slavery Assessment Tool which supports public bodies to assess their own supply base for modern slavery risks.

23.    Additionally, we are developing an LGA Modern Slavery Action Plan which proposes to include:

•  carrying out our own self-assessment via Unseen UK
•  appointing a senior leader accountable for Modern Slavery
•  producing a 6 monthly report on Modern Slavery activity (supply chain and internal actions)
•  drafting a Supplier Code of conduct which covers modern slavery practices 
•  setting up a remedial action plan

24.    With the introduction of the new Procurement Legislation, we will take the opportunity to review all procurement templates and contracts to ensure our commitment to best practice in relation to modern slavery continues

• we are committed to procurement specific e-Learning/training
• to engage and work with suppliers to mitigate any issues 
• make staff aware of the Modern Slavery Helpline as their first port of call 
• adopt an approach that would produce the safest outcome for the potential victims, using any leverage we may have as a public sector membership organisation.

This statement was approved on 19 July 2024 by the LGA Board. The Board will review and update it annually. 
 

Joanna Killian
Chief Executive