Modern Slavery Act statement

Our organisation

We are one of the largest NHS community health providers in England, serving a population of about 1.4 million. We employ 5,000 staff, including doctors, community nurses, physiotherapists, dietitians and many other healthcare professionals. We became a foundation trust on 1 March 2015.

We were formed on 1 April 2011 from the merger of Eastern and Coastal Kent Community Services NHS Trust and West Kent Community Health.

Our budget is around £234millon. We procure goods and services from a range of providers. Contracts vary from small one-off purchases to large service contracts.

Arrangements to prevent slavery and human trafficking

We are committed to ensuring there is no modern slavery or human trafficking in our supply chains or any part of our business activity.

Our commitment to social and environmental responsibility is covered by our approach to modern slavery and human trafficking, which is part of our safeguarding strategy and arrangements.

Our arrangements

Safeguarding

Our commitment to ensure no modern slavery is reflected in a number of our policies and procedures. These include our adults and children Safeguarding Operational Strategy and Safeguarding Operational Manual, which have been developed and maintained within the national and local safeguarding children governance and accountabilities frameworks. It includes guidance on initial contact with a suspected human trafficking victim and the National Referral Mechanism.

Training and promotion

Our safeguarding training includes role relevant modern slavery awareness and understanding to reflect the Department of Health’s project around Provider Responses, Treatment and Care for Trafficked People (PROTECT).

Suppliers/tenders

The trust complies with the Public Contracts Regulations 2015 and uses the mandatory Crown Commercial Services (CCS) Pre-Qualification Questionnaire on procurements, which exceed the prescribed threshold. Bidders are required to confirm their compliance with the Modern Slavery Act.

Sub-contracts

Our procurement and contracting team is qualified and experienced in managing healthcare contracts and have receive appropriate briefing on the requirements of the Modern Slavery Act 2015, which includes:

  • requesting evidence of their plans and arrangements to prevent slavery in their activities and supply chain
  • using our routine contract management meetings with our providers, to address any issues around modern slavery
  • implementing any relevant clauses contained within the Standard NHS Contract.

Modern slavery act – Section 54

Section 54 of the modern slavery act details the following:

  • (4) A slavery and human trafficking statement for a financial year is—
    • (a) a statement of the steps the organisation has taken during the financial year to ensure that slavery and human trafficking is not taking place—
    • (i) in any of its supply chains, and
    • (ii) in any part of its own business, or
    • (b) a statement that the organisation has taken no such steps.
  • (5) An organisation’s slavery and human trafficking statement may include information about—
    • (a) the organisation’s structure, its business and its supply chains;
    • (b) its policies in relation to slavery and human trafficking;
    • (c) its due diligence processes in relation to slavery and human trafficking in its business and supply chains;
    • (d) the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk;
    • (e) its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate;
    • (f) the training about slavery and human trafficking available to its staff.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the last financial year.

Paul Bentley
Chief Executive