Modern Slavery Act (2015) Statement 2022/21 As both a local leader in commissioning health care services for the population of Lincolnshire and as an employer, Lincolnshire Clinical Commissioning Group (LCCG) provides the following statement in respect of its commitment to, and efforts in, preventing slavery and human trafficking practices in the supply chain and employment practices.
Definition of Offences
Slavery, servitude and forced or compulsory labour
A person commits an offence if;
- The person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or;
- The person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour
A person commits an offence if;
- The person arranges or facilitates the travel of another person (victim) with a view to being exploited.
- It is irrelevant whether the victim consents to travel and whether or not the victim is an adult or a child
Exploitation A person is exploited if one or more of the following issues are identified in relation to the victim;
- Slavery, servitude, forced or compulsory labour.
- Sexual exploitation · Removal of organs · Securing services by force, threats and deception
- Securing services from children, young people and vulnerable persons
As an authorised statutory body, the CCG is the lead commissioner for health care services (including acute, community, mental health and primary care) in Lincolnshire – covering a population in excess of just under 800,000.
The aim of this statement is to demonstrate the trust follows good practice and all reasonable steps are taken to prevent slavery and human trafficking. All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility lead for overall compliance.
The position in Lincolnshire
In 2017 nine members of a traveller family were jailed for a combined total of over 79 years for running a modern-day slave camp in Lincolnshire. Almost all of the 18 victims had problems with alcohol and drugs or mental health issues. The victims were forced to live in squalid caravans or stable blocks often with no toilet or running water. Use of violence was a common feature and one of the men was held by the family for 26 years.
LCCG is fully aware of its responsibilities towards patients, employees and the local community and we work in conjunction with our multi-agency partners to embed best practice in respect of modern day slavery across Lincolnshire
Our commitment to prevent slavery and human trafficking The Governing Body, Senior Management 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 in so far as is possible to holding our suppliers to account to do likewise. Our overall approach will be governed by compliance with legislative and regulatory requirements and the maintenance and development of best practice in the fields of contracting and employment. Our internal recruitment processes are highly mature and adhere to safe recruitment principles. This includes strict requirements in respect of identity checks, work permits and criminal records. Our pay structure is derived from national collective agreements and is based on equal pay principles with rates of pay that are nationally determined. Contracting with providers is a core function of the CCG. All of our contracting and commissioning staff are suitably qualified and experienced in managing healthcare contracts and will receive appropriate briefing on the requirements of the Modern Slavery Act 2015 (the Act).
During 2017/18 we wrote to all providers requesting evidence of their plans and arrangements to prevent slavery in their activities and supply chain. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st March 2022.
Implications for equality and diversity
The CCG has a duty under the Equality Act 2010 to have due regard to the need to eliminate unlawful discrimination, advance equality of opportunity and foster good relations between people from different groups. In relation to the issues set out in this paper, consideration has been given to the impact that the recommendations might have on these requirements and on the nine protected groups identified by the Act (age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion and belief, gender and sexual orientation). It is anticipated that the recommendations of this paper are not likely to have any particular impact upon the requirements of or the protected groups identified by the Equality Act.