NCA Modern Slavery and Human Trafficking Statement
In accordance with the Modern Slavery Act 2015 and as per page 46 of our 2020/21 Annual Report and Accounts, the NCA fully supports the government’s objectives to eradicate modern slavery and human trafficking, and recognises the significant role the NHS has to play in both combatting it and supporting victims. In particular, we're strongly committed to ensuring our supply chains and business activities are free from ethical and labour standards abuses.
Organisation's Structure and Business
The NCA was created by bringing together two NHS Trusts: Salford Royal NHS Foundation Trust and The Pennine Acute Hospitals NHS Trust. The NCA was formally established on 1 October 2021 and has been working together as a group since 2016.
The NCA serves our communities through four ‘Care Organisations’: Salford, Oldham, Bury and Rochdale.
Our Care Organisations are responsible for delivering safe, high quality and reliable care to the local communities they serve. Each has a leadership team consisting of a Director of Operations, Medical Director, Director of Nursing and Finance Director, one of which is appointed as Chief Officer to lead the team. The local arrangements place the emphasis for operational management where it matters - in each hospital and locality. This enables Care Organisations to deliver tailored local plans, while working together to achieve the common NCA vision, shared objectives and deployment of standard operating models. All Care Organisations continue to be supported by group-wide corporate shared services and diagnostics and pharmacy services.
The NCA position on modern slavery is to:
- Comply with legislation and regulatory requirements
- Make suppliers and service providers aware that we promote the requirements of the legislation
- Develop an awareness of human trafficking and modern slavery within our workforce
- Consider human trafficking and modern slavery issues when making procurement decisions
Policies on Modern Slavery
We're committed to ensuring there's no modern slavery or human trafficking in any part of our business and, in so far as is possible, to requiring our suppliers hold a corresponding ethos.
To identify and mitigate the risks of modern slavery and human trafficking in our own business, the NCA has established robust recruitment procedures, details of which are found in its Management of Employment Checks Policy. The policy supports compliance with national NHS Employment Checks and CQC standards.
In addition, all other external agencies providing staff have been approved through Government Procurement Suppliers (GPS). The Trust will audit and monitor agencies (via GPS) who provide staffing for the Trust once a year to ensure they're able to provide evidence of identification, qualification and registration.
Training on Modern Slavery and Trafficking
Modern slavery is incorporated within NCA Safeguarding Children and Safeguarding Adults policies. In addition, modern slavery is referenced within the Safeguarding Children and Adult mandatory training from Levels 1-3, which applies to all staff employed by the NCA across the four care organisations. The NCA Safeguarding Training and Competency Framework (2019) clearly articulates the level of training appropriate to our people.
The NCA's people must:
- Undertake safeguarding training appropriate to their roles and responsibilities
- Work with the Procurement Department when looking to work with new suppliers so appropriate checks relating to modern slavery can be undertaken
Procurement and Supply Chain
The Procurement Department’s senior team are all Chartered Institute of Purchasing and Supply (CIPS) qualified and uphold the CIPS’s code of professional conduct and practice relating to procurement and supply. Many of the CIPS-qualified members of the team have recently upgraded to chartered status which involves holding a current CIPS Ethical Procurement and Supply Certificate. All members of the Procurement Department are required to undertake safeguarding training at a level appropriate to their roles and responsibilities.
As part of the Cabinet Office/Crown Commercial Services Standard Selection Questionnaire (PPN 8/16), it's clear that the NCA expects any potential supplier to be fully compliant with the provisions of the Modern Day Slavery Act and to be able to evidence this compliance if required.
Any area of a supply chain can be vulnerable to the risks of modern slavery which is why the Procurement Department have introduced a supplier relationship management policy and conduct regular contract/supplier meetings where appropriate. These meetings are also conducted by central framework contract providers which the NCA Procurement Department use and which also help to further promote the awareness of modern day slavery in the supply chain.
The procurement department follows good practice, ensuring all reasonable steps are taken to prevent slavery and human trafficking and will continue to support the requirements of the Modern Slavery Act 2015 and any future legislation.