Gloucestershire Clinical Commissioning Group’s Statement on Modern Slavery Act 2015

According to the Global Slavery Index, in 2016, at any given time, an estimated 40.3 million people worldwide were in modern slavery, including 136,000 in the UK. In the UK alone during the year 2016 approximately 6,993 potential victims of modern slavery and human trafficking were identified, including 61 in Gloucestershire.

Modern Slavery is the illegal exploitation of people for personal or commercial gain. Victims are trapped in servitude; they are often deceived or coerced into working in exploitative conditions and feel they cannot leave. Children, young people, women and men are forced through coercion, abuse of vulnerability and / or deception for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK and may be trafficked for a number of different reasons including forced labour, domestic servitude, sexual exploitation and for organ harvesting.

Public sector organisations all hold responsibilities to report when and where they see signs of slavery or human trafficking, and take steps to prevent slavery and human trafficking practices in their supply chain and employment practices.


Our Commitment

As both a local leader in commissioning health care services for the population of Gloucestershire and as an employer, Gloucestershire Clinical Commissioning Group (CCG) is committed to preventing modern slavery practices by proactively reviewing our system, policies and process to prevent the exploitation and trafficking of people.
The Governing Body, Executive Team and all employees are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and holding our suppliers to account to do likewise, through our commissioning, procurement and contract arrangements, as well as employment policies and procedures.
Our approach

The CCG’s approach to preventing modern slavery practices in our supply chain and employment practices is governed by compliance with legislative and regulatory requirements. We will also take proactive measures to learn from best practice and encourage relevant staff to attend specific training seminars and courses. For example the Home Office’s Employment Checks seminar held in Gloucestershire in the early part of 2020.
All of our contracting and commissioning staff have mandatory safeguarding training which includes awareness on Modern Slavery. As part of our of our Corporate Induction Programme the Safeguarding session includes training on recognising and reporting vulnerable adults trapped in exploitative conditions who may well be trafficked.


Our policies and procedures

Our recruitment processes are robust and adhere to safe recruitment principles. This includes strict requirements in respect of identity checks, work permits and criminal records.
Our policies such as Safeguarding Adults and Children policies, Bullying and Harassment policy, Grievance procedure and Whistleblowing policy provide an additional platform for our employees to raise concerns about poor and inappropriate working practices.
Our procurement approach follows the Crown Commercial Service standard. When procuring goods and services, we apply NHS Terms and Conditions (for non-clinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.


Further work to be undertaken

The CCG is committed to playing its part in raising awareness of the trafficking and exploitation of vulnerable people and we will build on the work already underway with our local authority partners, Victim Support and local Abolition Groups to raise awareness of this often hidden crime. The National Anti-Slavery Day is on 18 October each year and provides an opportunity for all members of the Gloucestershire Anti-Slavery Partnership (GASP) to hear the stories of survivors and work collaboratively to stamp out slavery in our county. This coming October we will play our full part in the coordination of activities that raises awareness of modern slavery in the country and the collaborative measures needed to combat it.
More information about GASP and the signs of modern slavery can be found online here.

If you see someone you think might be a victim please contact the Modern Slavery Helpline 0800 0121 700, Crimestoppers on 0800 555 111 or the police on 101.


Mary Hutton
Accountable Officer
Gloucestershire CCG

April 2021