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Modern Slavery Partnership Action Plan

To deliver on our commitment to identify Modern Slavery in the 5-year Strategy, the Modern Slavery Working Group have produced the following Action Plan for 2023/24.

Priority 1 - Prepare

Outcome 1: All frontline staff are aware of the Modern Slavery and Exploitation Strategy and Toolkit and have completed required training

Actions

  • Encourage management to ensure 100% of current staff completed online Evolve module.
  • Ensure managers across Bexley understand the context and implications of Modern Slavery.
  • Level 2 training to be updated and published.
  • Bexley strategy documents to be maintained, updated, and published.
  • Advertisement of strategy documents and training.
  • Invite all Councillors to training.

Outcome 2: All SNTs, School Officers and LFB have attended training sessions

Actions

  • Invite all partners to Modern Slavery Working Group.
  • Invite Safter Neighbourhood Teams to Level 2 Modern Slavery Training. 
  • Invite London Fire Brigade to Level 2 Modern Slavery Training. 
  • Consider creation/delivery of joint training.
  • Identify any resources/materials to safely provide potential victims so they understand help available to them.

Outcome 3: To improve London and regional network partnerships and actions

Actions

  • Consider funding opportunities and commissioning opportunities
  • Join the Stop the Traffik pan-London data project to have returns of reports on Bexley’s trends. Create campaigns on the back of findings
  • Maintain up-to-date list of SPOCs
  • To attend networks for data and info sharing. Consider joining new networks of partners and increasing presence
  • Identify any new opportunities and notify partners
  • Create online network of partners by linking Partner webpages
  • Action plan to target voluntary sector

Outcome 4: Modern Slavery is understood and the response overseen by statutory Boards

Actions

  • BCSP Board has overall governance to ensure that statutory obligations are met
  • BCSP Board monitors the current context and implications of Modern Slavery in Bexley
  • BSAB, SHIELD and Health and Wellbeing Board engage in sharing information with the Community Safety Partnership
  • Bexley Safeguarding Adults Board is responsible for identified Adult safeguarding actions
  • SHIELD Partnership Board is responsible for safeguarding Children's actions
  • To ensure different disruption powers are clear - what is available and who can enforce them
  • Provide written guidance to partners on how to interview potential victims and make a good NRM referral or a DtN into the NRM system

Priority 2 - Prevent

Outcome 1: To raise awareness of the issues of Modern Slavery across the Borough including through an annual awareness campaign to combine with the national anti-slavery day

Actions

  • Create a communications calendar/events diary
  • Annual partnership message to go out
  • Deliver partnership outreach events
  • To organise involvement of Education
  • Anti-Slavery Day events
  • Have regular internal and external communications
  • To link in with SHIELD and BSAB learning and work with the Multi-Agency Learning Forum to promote and coordinate learning in partnership

Outcome 2: Our procurement systems and processes identify and challenge exploitation in our supply chains and commissioned services

Actions

  • Procurement team to work with suppliers and contract managers to ensure that processes are reviewed annually
  • Staff complete the Chartered Institute of Procurement and Supply’s (CIPS) online course on Ethical Procurement and Supply
  • Standard terms and conditions include provision for suppliers and contractors to comply with all modern slavery legislation
  • Low-cost tenders are challenged as part of due process
  • Risk Assessment tool completed and procurement action plan amended to address any needs, annually
  • Transparency in supply chains statement to be published annually

Outcome 3: To engage our community and raise awareness of what Modern Slavery looks like and how concerns can be reported

Actions

  • To recruit 3-year Hate Crime/Modern Slavery Officer to engage with key community leaders and groups on this agenda and provide them with relevant awareness training
  • Explore expanding the Modern Slavery Response Group to include business and voluntary sector groups as appropriate, to enable targeted approach to addressing potential Modern Slavery in relevant community settings
  • Promoting and training existing community champions and groups to bring awareness of modern slavery and signposting to services, and recruitment of further champions in community-based safeguarding and support services
  • Consistent community outreach and messaging re modern slavery awareness, training invitations, and referral/reporting mechanisms and processes
  • Partnership events on landmark days, e.g., Anti-Slavery Day and Remembrance Day
  • To work with businesses around identifying exploitation, and reporting processes, in particular, at-risk industries
  • To raise awareness with those consider vulnerable or at risk of exploitation in our community

Priority 3. Protect and Support

Outcome 1: Recording of Modern Slavery is clear on Council systems

Actions

  • Adult Social Care recording information dispersed down
  • Children Social Care recording information dispersed down
  • Community Safety Team to be advised of NRM referrals made by Council departments, via email with Name, DOB, referral date, referral dept, and type of exploitation
  • To continuously review our decision-making, referral and recording processes and structures to ensure they remain fit for purpose
  • To ensure non-First Responders, such as Healthcare, are aware of referral and reporting processes for that information is captured

Outcome 2: Existing referral pathways are clearly defined

Actions

  • Adult Social Care pathway clear and published
  • Children Social Care pathway clear and published
  • Out of Hours information clear and published
  • Include Community Safety Team as second point of contact in NRM referrals
  • Create a multi-agency Housing Pathway for victim referrals

Outcome 3: To ensure victim’s voices are heard

Actions

  • To ensure the victims is aware of the referral processes and next steps at all times
  • To ensure adult victims are consenting to each stage of the process
  • To understand individual’s needs and concerns
  • To ensure individual feels they trust services and are receiving trauma-informed, specific support
  • To give victims the opportunity to feedback on support offered
  • To ensure families and relevant persons in a victim’s life are involved in the process, as relevant

Outcome 4: To ensure each relevant partner is leading on the delivery of their duties

Actions

  • To ensure Procurement lead on tackling modern slavery in supply chains
  • To ensure Housing lead on delivering against housing duties for priority need victims of modern slavery
  • To ensure police lead on pursuing perpetrators
  • To ensure a whole partnership approach to disrupting exploitation
  • To ensure social care lead on safeguarding victims and meeting survivor needs
  • To ensure community safety lead on strategy and coordination of the partnership

Outcome 5: To pilot child NRM Devolved Decision- Making and learn from practice

Actions

  • To pilot NRM Devolved decision making pilot for children Jan 23 to March 24
  • To ensure that key partners of Health, Police and LA representative for the pilot are committed to the attendance of panel meetings and sharing of information
  • To ensure panel members are SCA trained are confident decision makers and adhere to the guidance
  • To promote the pilot and any relevant training opportunities in relation to exploitation and best practice for completing a quality NRM referral
  • To provide an all staff briefing on the Pilot project and how to make a referral
  • To set up a dedicated NRM email inbox to collect the receipts of LA NRM referrals
  • To undertake learning from the panels, themes and best practice

Priority 4 - Pursue

Outcome 1: The data and analysis of Modern Slavery in Bexley is shared and understood by partners

Actions

  • Creation of a dashboard to show local data. Performance Team staff to be linked into sources of information to analyse patterns and trends
  • All NRM referrals made by the Council, and the outcome of these referrals, are shared with Community Safety as set out in Bexley’s Modern Slavery Strategy
  • Community Safety Team collate information and share these with the Modern Slavery Working Group
  • Hold necessary Case Reviews to improve partner working
  • BCSP Board biannual report /updated action plan copied to BSAB, SHIELD and Health and Well Being Board
  • Police to provide borough-specific data around NRM referrals to help give an improved picture of Modern Slavery activity and for this profile to be shared with BSAB, SHIELD and Health and Wellbeing Boards for their understanding

Outcome 2: To work in partnership to carry out enforcement activities

Actions

  • Pilot multi-agency visits alongside them to key-risk sites
  • Run multi-agency enforcement operations where concerns raised and shared by relevant partners, including LA, Met, LFB, GLAA, Immigration, etc
  • Have exploitation in mind when carrying out existing visits by relevant teams, such as Housing, Environmental Health, Trading Standards, etc
  • To share information relating to concerns with partners so that information does not get lost or to ensure it is considered from all angles

Outcome 3: To ensure all partners are trained on best practice engaging victims and perpetrators

Actions

  • Training on how to interview victims and survivors
  • Training on disruption powers and roles of partners
  • Understanding of the standard of proof and type of evidence required for prosecution
  • Awareness of the Section 45 defence for criminal exploitation
  • To maintain understanding of duties of all and share legislative updates

Procurement Action Plan

The below table outlines the London Borough of Bexley’s Procurement Action Plan for 2021/22, aimed at reducing and mitigating the risk of modern slavery and human trafficking in our supply chains. This will be reviewed and updated annually.

Procurement Action Plan

TaskAction
1. Train its corporate procurement team to understand modern slavery through the Chartered Institute of Procurement and Supply’s (CIPS) online course on Ethical Procurement and Supply.All appropriate staff now trained and applying learning as appropriate.
2. Require its contractors to comply fully with the Modern Slavery Act 2015, wherever it applies, with contract termination as a potential sanction for non-compliance.Part of due process for every order/contract.
3. Challenge any abnormally low-cost tenders to ensure they do not rely upon the potential contractor practising modern slaveryWe challenge abnormally low-cost tenders as part of our current process.
4. Highlight to its suppliers that contracted workers are free to join a trade union and are not to be treated unfairly for belonging to one.This has now been added as a clause on the declaration for tenders and to our standard purchase order.
5. Publicise its whistle-blowing system for staff to blow the whistle on any suspected examples of modern slavery.

Our Corporate Modern Slavery Strategy and toolkit, mandatory training courses and training offer will ensure staff are informed on the issue of Modern Slavery and know who to contact if they want to report an issue, within the council or externally.

The Gangmaster Labour Abuse Authority are a named first responder in the Modern Slavery Act and its role is to protect vulnerable workers. Further information is available on the Gangmasters and Labour Abuse Authority website.

Prospective contractors to the Council are urged to adopt a similar whistleblowing system to that of the Council via a ‘Declaration’ document provided to all bidders on tender exercises.

6. Require its tendered contractors to adopt a whistle-blowing policy which enables their staff to blow the whistle on any suspected examples of modern slaverySee above. Procurement to ensure contract managers are trained and share the information above with contactors.
7. Review its contractual spending regularly to identify any potential issues with modern slaveryThis is part of the current process, the training under item 1 and understanding the Corporate Strategy and attending the Modern Slavery training will enhance staff understanding - this is increased and staff are confident when reviewing spending to understand what to look for in terms of sign of Modern Slavery.
8. Highlight for its suppliers any risks identified concerning modern slavery and refer them to the relevant agencies to be addressed.

The procurement team continually work with Contract Managers to ensure they understand the issues, attend the training sessions and have seen the Corporate Strategy and toolkit.

Further information is available on the Gangmasters and Labour Abuse Authority website.

9. Refer for investigation via the Home Office’s National Referral Mechanism (NRM) any of its contractors identified as a cause for concern regarding modern slaveryGuidance on the NRM is available in the Corporate Strategy. Corporate staff training will provide further clarity over the coming year.
10. Report publicly on the implementation of this policy annually.The Bexley Modern Slavery Strategy and toolkit includes an action plan. This includes an action to comply with the 10 points set out in this charter. The procurement team will provide an update on progress each year, when the strategy is reviewed beginning in April 2024. The strategy and any review information will be published on the Council's website.