Modern slavery and human trafficking statement

This is our modern slavery statement made with reference to Section 54(1) of the Modern Slavery Act 2015.

Modern slavery is a widely recognised term to describe human trafficking, slavery, forced labour and servitude. It also describes practices such as debt bondage, sale or exploitation of children and forced marriage. Whilst varied in nature, all involve one person depriving another person of their liberty in order to exploit them for personal or commercial gain.

Councils are uniquely placed to take action against modern slavery and can demonstrate good practice and ethical leadership by voluntarily publishing a modern slavery statement. At Leeds city council, we are committed to preventing modern slavery and human trafficking from existing in our own business, our supply chains and in the wider community of Leeds. We recognise that we have a responsibility to take a robust approach to modern slavery and human trafficking as an employer, commissioner, contractor and service provider.

This statement describes the measures we have in place to reduce the risk of modern slavery taking place in our supply chains. It has been approved by the Director of Communities, Housing and Environment and the Deputy Chief Executive and Director of Strategy and Resources, and endorsed by the Chief Executive and Corporate Leadership Team.

Organisational structure, business and supply chains

Leeds city council provides a wide range of vital public services. We keep children safe; support older and vulnerable people; lead emergency responses and build resilience; prevent and tackle homelessness; help people live in good quality, affordable housing; work with the police to prevent and tackle crime and antisocial behaviour; encourage our residents to live healthier, more active lifestyles; provide sport and leisure facilities and green spaces; support people into jobs, training and apprenticeships and help them earn enough to support themselves and their families; clean streets and deal with the city’s waste; make roads safe and reduce congestion; improve air quality; secure investment in the city and promote cultural and community events all across Leeds.  

We take our responsibility to safeguard the most vulnerable in society very seriously and this involves protecting people from the heinous crime of modern slavery. The council acknowledges its duty under the Modern Slavery Act 2015 to notify the Secretary of State of suspected victims of slavery or human trafficking. 19,125 potential victims of modern slavery in the UK were referred to the National Referral Mechanism in 2024. Locally, West Yorkshire Police completed 572 NRM referrals and Leeds city council completed 55 NRM referrals in 2024.

Modern slavery policies

We have a number of organisational policies which help to prevent, detect and respond to modern slavery, and the risk of modern slavery, in our business and supply chains.

Our cross council Safeguarding People Policy and Procedure explains how employees should respond if they suspect modern slavery. This could be because they have come into contact somebody who they think is a potential victim, or if they see something else during the course of their duties which concerns them.

A range of employment policies and practices ensure that employees of Leeds city council are not exploited at work, our organisational values and behaviours are also central to ensuring colleagues are valued and supported. 

All council employees receive a contract and Statement of Main Terms and Conditions of Employment, in line with all legal requirements as a minimum. This is supplemented by additional terms and conditions prescribed by the National Joint Council for Local Government or equivalent. This document includes details of salary, hours of work and leave entitlement. It also provides the notice periods that employees are required to give to terminate employment or are entitled to receive if their employment is terminated. All council employees, regardless of age, are paid at least the Living Wage as determined by the Living Wage Foundation.

Contracts of Employment also state that employees have the right to join a trade union and take part in its activities. The Framework for engagement in employee relations sets out how the council consults and negotiates with trade unions. Employees are also free to associate with staff networks which are a source of information, support and advice.

The council does not employ anyone under the minimum school leaving age but does offer work experience placements for compulsory school aged pupils. When a person under the age of 18 is employed, or hosted on a work experience placement, the Performance Standard for Managing Risks to Young People protects their health, safety and wellbeing.

When available, overtime is offered but is not compulsory. If a service requires employees to work a different working pattern or in a different location, the Flexibility Protocol ensures that this well communicated to the employee and takes account of their individual circumstances.

During the recruitment process, the council must request original identification documents from candidates. These documents are photocopied and immediately returned to the candidate. When sourcing agency staff, the council has one procured provider which must be used for all general agency requirements. Bespoke arrangements apply for specialist technical roles and international recruitment. In these cases, agency staff are sourced via alternative suppliers. All agencies used are contracted to comply with anti-slavery and human trafficking laws and policies. 

The council holds a sponsorship licence to support international recruits who can fulfil skills where these are difficult to secure nationally. Licence rules provide additional protection to ensure fairness and transparency for these candidates. 

Our Dignity at Work Policy promotes dignity and respect in the workplace and prohibits violence, harassment and discrimination. It applies to all employees, including those on temporary contracts, and extends to contractors working on behalf of the council.

There is more information about the policies and procedures which relate to the goods and services we procure in the ‘due diligence’ section below. 

Risk assessment

As a council, we ourselves provide a wide range of services to the people of Leeds. We also commission many external businesses and organisations to provide goods and services. This means there is a risk of modern slavery in our supply chains, but also that we have a real opportunity to influence good employment practices and transparency in supply chains. 

The majority of our suppliers and contractors are UK companies. Between April 2024 and March 2025, Leeds City Council procured goods and services from 8358 external suppliers to the total value of £1.20bn.

This includes significant spend in some industries which are at high risk of modern slavery, including:

• construction
• manufacturing and electronics
• food processing
• services, including hospitality, security services, cleaning and catering
• logistics, including warehousing and transport
• healthcare and social care

Due diligence

The council takes a number of steps to reduce the risk of modern slavery and human trafficking in our supply chains when we buy goods and services from external businesses and organisations. 

Procurement stage – all bidders

Where required, all bidders must complete a Conditions of Participation. Bidders will be mandatorily excluded from the selection process if within the past five years, anywhere in the world, the bidder or any person:

• is a member of the supplier’s administrative, management or supervisory body; or
• has powers of representation, decision or control in the supplier; and
• has been convicted of child labour and/or other forms of trafficking in human beings

The Conditions of Participation also sets out grounds for discretionary exclusion which include a failure to publish a modern slavery statement if required to do so under Section 54 of the Modern Slavery Act 2015.

Additionally, bidders are required to complete a Social Value Response. This includes:

• a Real Living Wage Survey which asks bidders if they commit to paying the Living Wage Foundation recommended UK hourly rate to all employees, as well as setting out that in the event of evaluation scores being tied, the council will award the contract to the supplier committing to pay the Real Living Wage; and
• an Anti-Slavery and Human Trafficking Questionnaire which asks bidders to confirm their compliance with s54 Modern Slavery Act 2015 and to provide details of their Anti-Slavery and Human Trafficking Policies, remediation programmes and employee training on mitigating the risk of slavery and trafficking in their supply chains

Procurement stage – bidding for a contract in the construction industry

Construction is an industry that is identified as one of Leeds City Council’s highest spend areas, and also an industry at high risk of modern slavery in it’s supply chain. Therefore, potential suppliers in this area that meet the required thresholds, must submit an additional selection questionnaire. If bidders are required by s54 Modern Slavery Act 2015 to publish a modern slavery statement, failure to do so will automatically disqualify them from the selection process.

Contract management stage

Contractors are bound by the council’s terms and conditions, which include requirements in relation to anti-slavery and human trafficking. In summary, these clauses require contractors to:

• comply with the Modern Slavery Act 2015;
• exercise due diligence in relation to the risk of slavery and trafficking in their supply chains;
• report to the council any breaches or suspected slavery or human trafficking in a supply chain in relation to the contract;
• resubmit a completed Anti-Slavery and Human Trafficking Questionnaire annually;
• maintain records to trace their supply chain; and
• implement employee training to ensure compliance with applicable anti-slavery and human trafficking laws

(Please note: contractors should consult terms and conditions for a comprehensive understanding of these clauses).

Training and awareness

General training and awareness for council employees on modern slavery signs and indicators, and what to do if they have a concern, is available through: 

• the council’s safeguarding awareness course for all staff; and
• a specific Modern Slavery Act e-learning course. 

Additional in-house and externally provided training is often available and widely promoted. For example, employees who work with children and young people access training on child criminal and sexual exploitation, and employees working with adults have accessed training on cuckooing and domestic servitude. 

Staff in our Procurement service who complete courses from the Chartered Institute of Procurement and Supply (CIPS) undertake modules in Ethical Procurement and Supply, which includes anti-slavery and human trafficking content.

We are also committed to raising public and professional awareness of modern slavery in Leeds and we work closely with partners and communities to raise awareness, increase reporting of concerns and inform people of the help that is available for victims. In 2024, we relaunched the Leeds Anti-Slavery Partnership (formerly the Leeds Modern Slavery Board) and set new priorities for the year ahead which include continued workforce development.

Leeds pledge to tackle modern slavery

Actions

To launch the Leeds Pledge to Tackle Modern Slavery. As part of this pledge, we are seeking to engage more businesses in the city around how they can help statutory organisations to combat modern slavery in Leeds.

Progress

The Leeds Pledge to Tackle Modern Slavery was launched at an event in Leeds Civic Hall on Anti-Slavery Day 2022 and was supported by statutory partners across the city. Guidance for pledge supporters has been published on the West Yorkshire Police website. It provides individuals, businesses and organisations with information and resources to help them recognise the signs of modern slavery, report concerns, support victims and survivors, prevent slavery in supply chains and raise awareness of the issue across workforces and communities. 

Address training needs and gaps

Actions

To address training needs and gaps and continue to ensure staff within the council and partner organisations have the appropriate level of awareness and/or training to contribute to tackling modern slavery in Leeds including knowing where and how to report their concerns.

Progress

Modern slavery general awareness training has been delivered to front line customer services staff working across community hubs, libraries and community safety to help them recognise and respond to modern slavery.

Cuckooing training has been delivered to staff working across a number of teams such as Leeds Anti-Social Behaviour teams, as well as other internal and external partners.

Members of the Leeds Anti-Slavery Partnership have received inputs on labour exploitation in the care industry and exploitation linked to witchcraft and spiritual abuse.  

The procurement team has recently started a Yorkshire & Humber modern slavery task and finish group, bringing together key colleagues across the region to develop an action plan to identify key areas to work on collaboratively.

Best practice and guidance

Actions

To stay up to date with best practice and guidance about prevention of modern slavery in the supply chain and share this with our partners.

Progress

A task and finish group has been initiated across the Yorkshire & Humber region. At present key colleagues have been identified from across the region, and key sectors have been reviewed where modern slavery is a risk.

Future activities will include reviewing where there are gaps to collectively support in reducing modern slavery risk across the supply chain.

Review and republish guidance for contract managers

Actions

To review and republish our guidance for contract managers to support them with their annual reviews of the Anti-Slavery and Human Trafficking questionnaire.

Progress

As part of our contract manager training that all contract managers attend, we highlight the requirement for them to continually monitor key areas including modern slavery.

As part of the quarterly scorecard exercise to contract managers, they are able to identify and report on any good and/or bad practices identified with the contract which may include modern slavery. 

Ambitions for 2025 - 26

• To develop a partnership plan for preventing and raising awareness of labour exploitation in the care industry.
• To continue developing our modern slavery workforce development offer. 

This statement was approved by James Rogers, Director of Communities, Housing and Environment, and Assistant Chief Executives Victoria Bradshaw and Andy Dodman on 13 June 2025.