Modern Slavery Act 2015

Modern Slavery Statement


This statement sets out East Northamptonshire Council's actions to understand all potential modern slavery risks related to its business and to put in place steps aimed at ensuring there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2017 to 31 March 2018.

As part of the public sector, East Northamptonshire Council recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The council is committed to improving its practices to combat and prevent slavery and human trafficking in its corporate activities, and to ensure that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

East Northamptonshire Council is a district council providing a range of services for its 93,000 residents, from Council Tax collection, waste collection, planning management, business support and environmental protection.  Other services, such as schools, social care and roads/transport links are provided by Northamptonshire County Council. Services are delivered both directly by the council and through external contractors.

Countries of operation and supply

The council operates in the United Kingdom.

We expect and request assurance that the practices of companies and organisations in our supply chain operating within the EU adhere to Article 4 of the European Convention on Human Rights, concerning the prohibition of slavery and forced labour.

Should the council look to procure or import products or services from outside the EU which could pose an increased risk of slavery or human trafficking, it would undertake further consideration of supply chains in order to take account of potential risks.

East Northamptonshire Council expects all suppliers of goods or services to the council who meet the requirements of the Modern Slavery Act 2015 to have their own policy relating to working practices or modern slavery, or for equivalent and sufficient evidence to be available to ensure their standards are in accordance with the council’s expectations. We request that our suppliers ensure the same of their own supply chains.

These provisions are formalised through our Procurement Strategy.


The council has a range of policies and processes which reflect our commitment to acting ethically and with integrity to prevent slavery and human trafficking in its operations.

Policies: Council policies are developed by officers employed by the authority and are then agreed by a relevant committee, which would include councillors, senior officers, and partner organisations where relevant.

Risk assessments: The responsible officer for human rights is the Chief Executive but all staff have a responsibility in identifying potential issues. Modern slavery risk analysis is provided by our staff in the Community Partnerships Team and nominated Safeguarding Officers who are actively developing strategies and safeguards around this.

Investigations/due diligence: We will refer any suspected or known incidents of slavery of trafficking to the relevant police authority via our Community Partnerships Team, which is our direct link with the police and the local Serious and Organised Crime Board, which has a responsibility for modern slavery.

As part of its safeguarding responsibility the council has previously commissioned safeguarding training for officers to help identify any signs of potential safeguarding  incidents and to advise staff of the relevant referral pathways.. Equivalent training for councillors is planned for the year 2017-18.  We expect any colleague who may witness or suspect any wrongdoing to report their concerns to their manager, the police and the relevant safeguarding board.

Any investigations in relation to suspected or confirmed modern slavery will be conducted through partners such as the police.

Specific policies which apply (copies are available on request or via the council's website

Whistleblowing Policy: The council encourages all its staff, customers and other business partners to report any concerns related to the activities of the council or its contractors. This would include any circumstances that indicate potential slavery or human trafficking. The council's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Staff, customers or others who have concerns can raise these via either their manager or other nominated persons specified in the policy.

Employee Code of Conduct: The organisation's code makes clear tostaff. the actions and behaviour expected of them when representing the organisation. The council strives to maintain the highest standards of employee conduct and ethical behaviour, including when managing its supply chain.

Procurement: The council's Procurement Strategy and procurement procedures are laid out in Part 4.6 of the Constitution. The strategy identifies the role played by procurement in minimising the risk of social exploitation within the supply chain by ensuring the council's ethical standards are met.

Safeguarding Children and Young People Policy and Safeguarding Adults Policy: The council has two safeguarding policies, which are declarations of the council's commitment to safeguarding its residents, irrespective of age.  These policies include procedures for delivery of a safe environment by officers of the council and for effective operation of its partnerships with other bodies, as the council is not an investigative or intervention agency.

Action Plan

  • Performance indicators: The council will keep under review  its key performance indicators (KPls)· in light of the introduction of the Modern Slavery Act 2015.

    Training and awareness-raising: The council already delivers training to staff and councillors and this programme will continue to include references and examples of modern slavery whenever appropriate.  The council recognises that certain staff within the organisation may require more specific or in-depth training, depending on their job role, in order to raise awareness further and ensure compliance with the Modern Slavery Act 2015. The council will take steps to review this position and put appropriate training in place specific to modern slavery as an addition to training already provided in its existing policies.  This will include considering awareness of the following;

  1. the basic principles of the Modern Slavery Act 2015
  2. how staff can identify and prevent slavery and human trafficking
  3. what staff can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation, and
  4. what external help is available, for example through the Modern Slavery Helpline.

 We will also make available information for all staff outlining our duties, potential warning signs and what to do if they have any concerns.  This will be made available on the council’s staff intranet and links will be made available for customers and members of the public to relevant websites relating to the Modern Slavery Act 2015.

  • Policy updates:  As part of ongoing policy monitoring, relevant policies will be adapted to include specific references to the Modern Slavery Act. Detailed procedures and processes will be also be reviewed to reflect the requirement to prevent  slavery and human trafficking  in our corporate activities and  ensure that the council’s supply chains are free from slavery and human trafficking  This will include the council's Equalities Statement and its processes on employing Agency Workers.
  • Links with Businesses. The council will use its contacts with businesses  as an opportunity to provide community leadership by promoting awareness of the Act and encouraging compliance with its principles by businesses across the district.

    This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes East Northamptonshire Council's Modern Slavery and Human Trafficking Statement for the financial year ending 31 March 2017.


Cllr Steven North

Leader of East Northamptonshire Council


David Oliver

Chief Executive of East Northamptonshire Council