Modern Slavery Statement - 2021 - 2022
PART A: Introduction
1. South Tyneside Council is committed to understanding and mitigating the risks of slavery and human trafficking in our corporate activities and supply chains.
2. By publishing an annual transparency statement, detailing activities undertaken over the latest financial year relating to Modern Slavery mitigation, the Council can keep stakeholders up to date and ensure continued compliance with the obligations arising from section 54 of the Modern Slavery Act 2015.
Organisational Structure and Supply Chains:
3. This statement covers the activities and supply chains of South Tyneside Council, including direct employees of the Council and services delivered on behalf of the Council by third party organisations, and our arms-length management organisation, South Tyneside Homes. More information about the Council structure and governance is available in the Council Constitution.
Areas of operation and supply and high-risk activities:
4. South Tyneside Council operates within the United Kingdom, which is considered at low risk of slavery and human trafficking, relative to other parts of the world. While the Council has a high level of confidence that policies and processes are in place to protect against risks of slavery in the supply chains with regards to Tier 1 suppliers, it is more difficult to be confident about links further up the supply chain. Higher risk categories identified by the procurement team include: cleaning, events catering, construction (particularly demolition, asbestos removal, groundworks, clearance/stripping work), clothing manufacture (particularly involving imported textiles), security (manned guards), domestic furniture supply and manufacture, environmental (waste management, recycling), horticultural (grounds maintenance and plant nurseries), some social care/personal services (including taxis), recruitment (agency staff provision, particularly into some of the other areas on this list), and dry imported foods (rice, cocoa, etc).
5. Intelligence indicates that a number of Modern Slavery incidents have taken place within South Tyneside and the wider North East area over the last year. Referrals into the National Referral Mechanism have increased over the last year, both nationally and regionally. The Council remains vigilant to the ongoing threat of Modern Slavery and to the potential that Modern Slavery could be taking place undetected in South Tyneside.
6. South Tyneside Council engages in a wide range of business activities, from refuse collection to the delivery of social care. None of these sectors are classified as high risk for labour exploitation. However, certain frontline workers, such as those in housing, environment health or public health, particularly those working with vulnerable populations and undertaking checks on private premises, may be more likely to encounter victims or perpetrators. The South Tyneside Modern Slavery Strategy approved by full Council on 29th September sets out ways to raise awareness amongst these service areas and engage staff to help us tackle modern slavery.
7. Each Head of Service is responsible for ensuring risks of Modern Slavery are understood and mitigated against in their service area, and for using appropriate resources to prevent and disrupt slavery and to support and protect victims. A cross-service Modern Slavery Coordination Group meets on a quarterly basis to identify opportunities for and progress improvements relating to combating modern slavery in the South Tyneside area and in the Council's business and supply lines.
8. Any concerns regarding modern slavery or human trafficking in the organisation or supply chains should be raised with the Director of Business and Resources.
PART B: Modern slavery policies and initiatives implemented to date
9. South Tyneside Council has a number of policies in place which protect employees and supply lines against the risk of modern slavery within the organisation. These include:
- Employee Code of Conduct - Enshrined within the Council Constitution, this code sets out actions and behaviours expected of employees when representing the organisation.
- 'Speak Out' Whistleblowing Policy - This policy supports employees, contractors and partners with concerns about any aspect of the Council's work to come forward and voice these concerns.
- Equality and Diversity Policies - The Council has two Equality and Diversity Policies, one for employees and one for residents, which outline a commitment to achieving equality of opportunity and a respect for diversity in all areas of council business. These policies aim to: eliminate unlawful discrimination; promote equality of opportunity; promote equality of access; and promote good relations between diverse communities. As part of the Our Council Change programme further work is being carried out to assess against the Local Government Association's Equality Framework to inform future action on equality and diversity
- Recruitment Policies - The Council has a range of robust, transparent and regularly-reviewed procedures in place for the recruitment and vetting of new employees, ensuring they are able to confirm their identities and qualifications, and that they are paid directly into an appropriate, personal bank account.
- Living Wage - Following an Independent Wage Commission, in 2015 South Tyneside Council became one of the first councils in the North East of England to commit to paying all employees the National Living Wage which is in excess of the National Minimum Wage .
- Responsible Procurement - responsible procurement, as set out in the South Tyneside Council Procurement Strategy 2021-24, is an integral duty in the Council's and South Tyneside Home's procurement process, ensuring ethical, honest and fair procurement. The Procurement Strategy sets out commitments comply with UK, EU and international sourcing standards, promoting fair trade, fair pricing policies and good employment practices, and committing to regularly review contracted spending to identify any potential issues with modern slavery, and to consider termination of a contract with a supplier awarded a contract who is later found to be in breach of the Modern Slavery Act.
- Safeguarding Policies and Procedures - The South Tyneside Safeguarding Children and Adults Partnership (STSCAP) maintains and adheres to a library of policies, procedures and best practice (https://www.southtynesidesafeguardingappp.co.uk/ and https://www.proceduresonline.com/nesubregion/)
10. South Tyneside Council was one of the first in the region to establish a comprehensive Modern Slavery Strategy which sets out actions to be taken to reduce the risks of slavery within our services, businesses, supply chains and communities. Over the last year, work has been undertaken by the Modern Slavery Coordination Group to refresh the Strategy in light of improvements undertaken to date and changes in the context in which the Council works and ensure an up to date, targeted action plan which will continue to strengthen the Council's capacity to contribute to tackling modern slavery.
11.The Strategy goes beyond the minimum statutory requirements of setting out actions taken to mitigate internal business and supply chain risks, by also setting out plans to strengthen the Council's First Responder and community safety roles, as well as setting out ambitions to leverage the Council's influence and networks to increase community and local business awareness of risks and signs of exploitation
12. This transparency statement provides an annual opportunity to set out progress made against the ambitions presented in the South Tyneside Modern Slavery Strategy and the associated work programme of the Modern Slavery Coordination Group.
Progress to date Against Modern Slavery Strategy Objectives and Action Areas:
Objective: Equip employees to recognise and report signs of modern day slavery.
What we have delivered:
- In recent years, the Council has taken a number of steps to improve staff awareness of Modern Slavery and increase employees' ability and confidence in recognising and reporting concerns, including:
- Making an engaging Modern Slavery e-learning module available to all employees and elected members through the online e-learning platform, and communicating the availability and importance of this module via All-Staff communications
- Supporting social workers and other professionals working with vulnerable children and adults to access a comprehensive, in-depth training programme on recognising and safeguarding against different types of exploitation, including Modern Slavery and closely-related activities such as County Lines.
- Sharing function-specific information and resources on modern slavery with managers in service areas with a role to play in identifying Slavery.
Objective: Ensure services respond confidently and effectively where slavery or potential slavery is identified.
What we have achieved:
- Over recent years, the Council has worked to ensure it is well-positioned to respond in the event incidences of slavery are identified locally. This has included contributing to the South Tyneside Children and Adults Safeguarding Partnership-led comprehensive multi-agency Modern Slavery Trafficking and Exploitation response plan and ensuring this plan is reviewed and updated as necessary to ensure it remains fit for purpose.
- The Safeguarding Partnership have, over recent years, also honed multi-agency intelligence-sharing and partnership working subgroups, including the 'MSET' (Missing, Slavery, Exploitation and Trafficked) and 'Pre-MSET' forums, which are the key local processes for sharing concerns relating to children and vulnerable adults across relevant agencies and coordinating appropriate responses.
- Social workers and other officers from services working with vulnerable children or adults are also well-connected into regional and national partnership forums, including the Northumbria Police Multi Agency Exploitation Hub. Within Children's Social Care, a Complex Abuse Senior Practitioner is able to lead on cases involving complex abuse and is able to support colleagues and social workers who are working with young people where there are worries/risks associated to exploitation or modern day slavery.
- Within Children's Social Care, an Exploitation Champions network has been established to ensure champions for this work in each children's social care team. Over the last year, this network has also been expanded to include Children's Social Care-adjacent teams including Early Help.
- New services and offers have been established to respond to changing social and policy context and ensure appropriate support and protection is in place for new populations who may be particularly vulnerable to exploitation, including with the establishment of an Asylum and Resettlement Task and Finish Group and the establishment of a multi-agency Poverty Group
Objective: Ensure relevant services, when called upon, are able to confidently support police with investigation and disruption activities.
What we have achieved:
- Officers in services with special regulatory and inspection powers (ranging from planning to trading standards to environmental health) are trained and experienced in how to contribute to police investigations and disruption operations
- Routine inspections of businesses across the borough are conducted on a risk-assessed basis, with officers trained to recognise and report modern slavery and other exploitation concerns
- During the Covid-19 response period, when heightened public health regulations were in place, Council services developed new and stronger relationships with a range of businesses
- Representatives from a range of services with a regulatory role are involved with and exchange intelligence with a range of regional groups working on tackling slavery and exploitation
- Work has been taking place over the last year to review and strengthen the Council's Whistleblowing Policy and associated arrangements
Objective: Strengthen internal processes to better identify and reduce risks of modern slavery in the business and supply chain.
What we have achieved:
- The refreshed Procurement Strategy (2021 - 24) places a particular focus upon Modern Slavery prevention.
- The Council and South Tyneside Homes have ensured Modern Slavery Act compliance is a routine part of all procurement due diligence, including by requiring suppliers to confirm annual modern slavery reporting requirements and declare any trafficking offences as part of the Supplier Selection Questionnaire.
- Contract terms and conditions have been tightened to include for potential termination of contract for any supplier found to be in breach of the Modern Slavery Act.
Objective: Leverage influencing functions to raise awareness of modern slavery in the community.
What we have achieved:
- The Council and South Tyneside Homes contribute to national awareness raising campaigns about modern slavery and trafficking and regularly (such as sharing press releases and social media messages on World Day Against Trafficking), and include information on modern slavery in public facing communications such as the Residents Newsletter
The Modern Slavery Strategy 2022 - 24 outlines planned next steps around these five objectives, including a number of detailed actions planned for the coming years.
Part C: Practical Guidance on Slavery and Trafficking:
Recognising modern day slavery and trafficking:
The true extent of modern slavery is unknown, but the latest Global Slavery Index (2016) estimated there were 136,000 victims of modern slavery in the UK and the latest available annual Home Office data shows that were 12,727 potential victims of human trafficking and modern slavery identified through the National Referral Mechanism in 2021.
Victims are forced against their will to work for little or no pay for the benefit of others. They are often abused or threatened and stripped of their rights.
There is no typical victim of slavery. Victims can be men, women or children of all ages and nationalities. Many victims are foreign nationals who are brought into the UK specifically so that they can be exploited for the benefit of others. However, a high number of victims are UK nationals, including children. Particular circumstances may make individuals being more vulnerable to slavery or trafficking, for example there might be increased risks for those with a lack of knowledge of understanding of the law or of their rights, or those lacking an established network of people they can look to for support - for example, people who have recently migrated to the local area, or individuals who are socially isolated and face barriers such as language barriers or learning disabilities.
Modern slavery crimes take place in many different sectors and workplaces, including factories, fields, retail or service units, within private homes, and within criminal enterprises. The most common types of exploitation for those referred in the National Referral Mechanism in the last year were labour exploitation for adults, and criminal exploitation for children and young people.
Crimes of modern slavery have taken place all over the country. Intelligence suggests that includes within South Tyneside.
The coronavirus pandemic and associated lockdowns have served both to increase health risks for victims and make detection of the crime harder for authorities.
Key indicators of potential trafficking include:
- Is the person in possession of their own passport, identification or travel documents or are these documents in possession of someone else?
- Does the person act if they were instructed or coached by someone else? Do they allow others to speak for them when spoken to directly?
- Was the person recruited for one purpose and forced to engage in some other job? Have transport costs been paid for by facilitators, whom they must pay back through working or providing services?
- Does the person receive little or no payment for their work? Is someone else in control of their earnings?
- Does the victim have freedom of movement? Are they dropped off and collected from work?
- Is the person withdrawn or do they appear frightened?
- Has the person or their family been threatened with harm if they attempt to escape?
- Is the person under the impression they are bonded by debt, or in a situation of dependence?
- Has the person been physically or emotionally harmed or deprived of food, water, sleep, medical care or other life necessities?
- Can the person freely contact friends or family? Do they have limited social interaction or contact with people outside their immediate environment?
What to do if you encounter or suspect modern day slavery or trafficking?
In the first instance the point of contact for all modern slavery crimes should be the local police force. If you have information about a potential modern slavery crime that requires an immediate response (such as where victims are at risk) dial 999.
If you hold information that could lead to the identification, discovery and recovery of victims in the UK, you can contact the Modern Slavery Helpline on 0800 0121 700. Alternatively, you can make calls anonymously to Crimestoppers on 0800 555 111.
If you have concerns or suspect that an adult is at risk of harm or abuse, you can contact Adult Social Care at:
- 0191 424 6000 (Monday to Thursday, 8.30am until 5pm and Friday 8:30am until 4:30pm)
- 0191 456 2093 (outside of the above office hours)
If you have concerns or suspect that a child is at risk of harm or abuse, is being trafficked or enslaved, you can contact Children's Social Care at:
- 0191 424 5010 (Monday to Thursday, 8.30am until 5pm and Friday 8.30am until 4:30pm)
- 0191 456 2093 (outside of the above office hours)