The Modern Slavery Act 2015
Our hospitals have zero tolerance to slavery and human trafficking and we are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our service. We are fully aware of the responsibilities it bears towards patients, employees and the local community and as such, we have a strict set of ethical values that we use as guidance with regard to our commercial activities. We therefore expect that all of our suppliers to adhere to the same ethical principles.
The summary below sets out the steps the we are taking to ensure that slavery and human trafficking is not taking place in our supply chains or in any part of our service:
• Assessing risk related to human trafficking and forced labour associated with our supply base: we do this by supply chain mapping and developing risk-ratings on labour practices of our suppliers to understand which markets are most vulnerable to slavery risk.
• Developing a ‘Supplier Code of Conduct’: we will issue our Supplier Code of Conduct to our existing key suppliers as well as those that are in a market perceived to be of a higher risk (for example, Catering, Cleaning, Clothing and Construction). The Supplier Code of Conduct will also be included within our tendering process.
• Monitoring supplier compliance with the Code of Conduct: we will request confirmation from all our existing and new suppliers that they are compliant with our Supplier Code of Conduct.
• Monitoring supplier compliance with the Act: we will request confirmation from our key suppliers that they are compliant with the Act.
• Training and provision of advice and support for our staff: we are further developing our advice and training about slavery and human trafficking for Trust staff through our Safeguarding Team to increase awareness of the issues and how staff should tackle them.
• Monitoring contracts: we continually review the employment or human rights contract clauses in supplier contracts.
• Addressing non-compliance: we will assess any instances of non-compliance with the Act on a case-by-case basis and will then tailor remedial action appropriately.
Although the Lancashire Teaching Hospitals are not formally subject to the disclosure obligations under the Act, it recognises the importance of these issues for all its stakeholders.
All directors have confirmed that, so far as they are aware, there is no relevant audit information of which the auditor is not aware and that they have taken all steps that they ought to have taken as a director in order to make themselves aware of any relevant audit information and to establish that the NHS foundation trust’s auditor is aware of that information.
All directors understand that it is their responsibility to prepare the annual report and accounts, and that they consider the annual report and accounts, taken as a whole, to be fair, balanced and understandable, and to provide the information necessary for patients, regulators and other stakeholders to assess the performance of Lancashire Teaching Hospitals NHS Foundation Trust, including our business model and strategy.