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Modern Slavery Act 2015

Modern Slavery Statement

Modern Slavery Act 2015

Modern Slavery Statement


The Modern Slavery Act 2015 requires any commercial organisation in any sector, which supplies goods or services and carries on a business or part of a business in the UK and is above a specified total turnover of £36m or more, to produce a slavery and human trafficking statement for each financial year of the organisation. Although this is not mandatory for those businesses falling outside the definition contained in Section 54 of the Act, the government does encourage all businesses to develop an appropriate and effective response to modern slavery.

Modern Slavery is an horrific crime and East Northamptonshire Council is committed to preventing it wherever and however it occurs. It is not acceptable that the people and businesses producing the products and services we use and provide, however directly or indirectly, could be exploiting vulnerable individuals.

As councillors and leaders of local places, we all need to be aware that the UK is a source, transit and destination country for modern slavery.

The issues of Modern Slavery can intersect with many different areas that the council is involved with and a number of different officers may come across it whilst going about their every day duties:

  • In housing and homelessness services
  • Community safety officers involved in issues around serious and organised crime, gangs, drug selling and other crimes committed within their area – like cannabis cultivation and begging.
  • Trading Standards, licensing and environmental health and other regulatory services whilst inspecting premises and regulating other businesses, such as taxis and private hire vehicles.
  • Councillors may hear concerns from residents about particular businesses or houses in their areas
  • Customer services through their ordinary dealings with the public

This list is not exhaustive and there could be many other places where council staff and councillors may come across modern slavery or trafficking. Given the different services which may come in to contact with Modern Slavery, local government is central to ensuring compliance.


Organisation 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. These services are delivered both directly by the Council and through external contractors.


Countries of operation and supply

The council operates within 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 ever look to procure or import products or services from outside of the EU which could potentially increase the risk of slavery or human trafficking, it would carry out further consideration and due diligence of supply chains to ensure they are taking account of and mitigating against any potential risks.

East Northamptonshire Council expects all of its suppliers to have due regard towards the Modern Slavery Act and for those governed by it to have their own policy relating to working practices of Modern Slavery, or provide sufficient evidence that 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.



As councillors and leaders of local places, we all need to be aware that the UK is a source, transit and destination country for Modern Slavery.  The Home Office estimated that in 2013 there were between 10,000 and 13,000 potential victims of modern slavery in the UK. This means that there is a good chance modern slavery is taking place in the towns, cities and villages where we live and work.

Modern Slavery can be hidden, often in plain sight; on our high streets, in local businesses and even suburban streets. Unwittingly, our communities may be using victims of Modern Slavery to wash their cars, paint their nails and lay their drives. They may even be living next door.

The help which councils are able to give, bolstered by the passing of the Modern Slavery Act 2015, is crucial. The Act provides victims with greater protections and the police with greater powers. It also requires some businesses to report on the actions they are taking to identify and address slavery within their supply chains.

Local government is central to every facet of the slavery fight; from the identification, referral and support of victims, community safety services and disruption activities , providing shelter, to safeguarding and ensuring its own supply chains are slavery free.

East Northamptonshire Council is passionate about taking a robust approach to abolish slavery and human trafficking. The council is committed to improving its practices to identify and prevent slavery and human trafficking within the entirety of its activities.

The council has a range of policies and processes which confirm its commitment to acting with integrity to prevent slavery and human trafficking within its operations.


Risk assessments

The Chief Executive is the responsible officer for human rights; however, all staff are aware of their responsibility in identifying and escalating any potential issues. Modern Slavery risk analysis is delivered by our staff in the Community Partnerships Team and nominated Safeguarding Officers who are collectively developing strategies and safeguards around this. The council recognise the risks associated with Modern Slavery which is why it is recorded and monitored as a very high risk at corporate level.


Investigations/due diligence

We refer any suspected or known incidents of slavery or trafficking to the relevant police authority via our Community Partnerships Team who our direct link with the police and the local Serious and Organised Crime Board.

The Council’s Safeguarding Awareness training package has been updated and it now features greater information in relation to Modern Slavery.

The council set up a Cuckooing and Exploitation Forum in March of last year. This is for organisations to refer vulnerable adults who may be being exploited.  This now constitutes the main referral pathway for modern slavery cases.



Council policies are developed by competent officers employed by the authority and are then agreed by the relevant committee. Committee membership includes councillors, senior officers, and partner organisations where appropriate.

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

Whistleblowing Policy: The Whistleblowing policy exists to encourage and enable employees, councillors, contractors, partners or members of the public to raise serious concerns with the Council, which includes any concerns in relation to potential slavery or human trafficking. The purpose of this policy is to make clear that such concerns can be reported without fear of victimisation, discrimination or disadvantage.

Employee Code of Conduct: The organisation's Code of Conduct makes it clear to staff that they are expected to provide the highest possible standard of Service to the public, within the best traditions of local government and in accordance with the seven principles of public life. The council strives to maintain the highest quality of employee conduct and ethical behaviour, including when managing its supply chain.

Councillors Code Of Conduct: This Code applies to all Councillors when they act in their role as Councillors of the Council. This Code is a requirement of the Localism Act 2011 and forms part of the Constitution of ENC which all Councillors will follow. This code is based on the seven principles of public life; selflessness, integrity, objectivity, accountability, openness, honesty and leadership. The council strives to maintain the highest quality of councillor conduct and ethical behaviour.

Procurement: The council's Procurement 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. This is detailed specifically under 3.2 of the strategy where it states ‘Mandatory compliance with UK and European Procurement Legislation including compliance and procedures to support Modern Slavery Act 2015 and Criminal Finances Act 2017’. Procurement procedures are laid out in Part 4.6 of the Constitution, specifically under 10.6 where it states that Officers should ensure that advertised tenders contain the Standard Selection Questionnaire questions regarding the Modern Slavery Act requirements.

Safeguarding Children and Young People Policy and Safeguarding Adults Policy: The council has two safeguarding policies, which are declarations of the council's assurance to safeguard its residents.  Although the Council is not an investigative or intervention agency for safeguarding adults, through this policy it highlights their commitment to understand the potential signs and report cases of abuse or suspected abuse to the statutory responsible authority.

Shared Services Strategy: This strategy sets out the council’s approach to shared services, including the governance arrangements that need to be in place and the processes we will apply to ensure that we get best value out of each service. The strategy also highlights the importance of having processes and/or protocols for safeguarding, specifically in relation to our compliance with legislation such as the Equality Act 2010 and Modern Slavery Act 2015.



As part of its safeguarding responsibility the council delivers mandatory safeguarding training to all new staff and every 3 years thereafter as refresher training. The training is provided to help staff identify safeguarding concerns and to advise them of the relevant referral pathways.

Equivalent training is also delivered to all of our councillors.

The council rolled out more in-depth modern slavery training to members of staff who work in housing and homelessness, environmental health, heath protection and procurement. This has now been incorporated into the safeguarding training delivered to all staff.

Modern Slavery was included as an agenda item at the countywide Social Housing Landlord’s Forum and was featured as a topic in the council’s housing newsletter which goes out to all the statutory and voluntary agencies working in housing within the district.

The safeguarding lead for the council attended online Trafficking, Exploitation and Modern Slavery training delivered by Northamptonshire Safeguarding Children’s Partnership.

The Community Partnership team attended an online Police briefing about Serious Organised Crime which covered aspects of Modern Slavery.

The council recognises the key role customer services can play in tackling Modern Slavery. Customer service’s officers often come in to contact with victims through their ordinary dealings with the public. For this reason tailored training has been rolled out to customer service’s staff so they feel confident in recognising the signs of Modern Slavery and human trafficking and are able to effectively manage the safeguarding referral process if necessary.

The council’s housing options contractor provide training to their staff on how to recognise and safeguard customers who are potential victims of Modern Slavery.  The housing options team are following the Code of Guidance advice on Modern Slavery.


Action Plan

Performance indicators:  The council will continue to review its key performance indicators (KPl’s) in light of the Modern Slavery Act 2015. The council recognises that the direction and focus of particular performance incentives may influence and create a modern slavery risk if not managed carefully. This should be considered when improving internal management performance indicators and should be linked to the organisation’s risk assessment. The council will therefore look to provide information on their existing KPIs and set out whether they have considered whether they make their business and supply chain vulnerable to Modern Slavery.


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.  The training will now include a short film launched in September 2020 by the Northamptonshire Office of the Police, Fire and Crime Commissioner and Northamptonshire Police, to raise awareness of modern slavery and exploitation, encouraging frontline professionals and the public to take a closer look at where modern slavery is not immediately obvious.

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 will include links to statutory guidance and support services.


Policy updates:  As part of ongoing policy monitoring, relevant policies will be reviewed to include specific references to the Modern Slavery Act, including but not limited to, County Statement of Licencing Policy, Empty Homes Strategy, Environmental Services, Community Safety Enforcement Policy, Food Safety and Health and Safety Service Plan, Anti Money Laundering Policy, Customer Services Strategy, Sex Establishment Policy, Homelessness and Rough Sleeping Strategy and the Housing Strategy.

All formal procedures and processes will be reviewed to ensure we are preventing Modern Slavery to the best of our ability.

Detailed procurement and contract management guidance in relation to Modern Slavery and human trafficking will be produced to support staff in managing and eliminating the risk within our supply chains.


Links with Businesses: The council will take advantage of the positive and collaborative relationship they have with businesses across the district to promote awareness of the Act and encourage compliance with its principles.

This voluntary 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 2020.



Cllr Steven North

Leader of East Northamptonshire Council




David Oliver

Chief Executive of East Northamptonshire Council