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's important that we build on this work year-on-year so the statement includes the specific actions taken during the financial year 2021-22. It also sets out the additional work we are doing during the financial year 2022-23 to continue to reduce this risk.
It has been approved by the Director of Communities, Housing and Environment and the Director of 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. 12,727 potential victims of modern slavery in the UK were referred to the National Referral Mechanism (NRM) in 2021 (compared to 10,601 in 2020). Locally, West Yorkshire Police completed 196 NRM referrals and Leeds City Council completed 32 NRM referrals in 2021.
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 with 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.
All council employees receive a contract of employment that sets out their terms and conditions of employment which they receive on or before their first day of employment in line with legislation. The contract of employment is written in accordance with the appropriate national terms and conditions that apply to local authorities. An example and most common is those agreed by the National Joint Council for Local Government. The contract 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 rate as determined by the Living Wage Foundation.
The Council approach to employee relations is collective bargaining and we have a local framework agreed with our three recognised trade unions (Unison, UNITE and GMB). The Framework for engagement in employee relations sets out how the council consults and negotiates with our local trade unions. Employees have the opportunity to become a trade union member and we also have a number of staff networks which are a source of information and support. Information on how to get in touch with our unions or staff networks is available on our staff intranet.
When available, overtime is offered but is not compulsory. Depending on the nature of the role, the Council offers a flexitime scheme and where this isn't available there is a set working pattern that is determined by the manager.
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.
During the recruitment process, the council requests original identification documents from candidates. These documents are photocopied for checking eligibility to work in the UK. Originals are returned to the candidate immediately and once checks are completed the photocopies are disposed of as confidential waste. We also ask for National Insurance numbers to ensure National Insurance contributions and tax are recorded against the employee's name only.
When sourcing agency staff, the council has one procured provider which must be used for all general agency requirements. The one exception to using this agency is when temporary ICT staff are needed. In this case, 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 has appointed a Freedom to Speak Up Guardian who provides support to employees. This is an independent role and is a route for employees to raise any concerns confidentially. This role is open for contact from 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 2021 and March 2022, Leeds City Council procured goods and services from 737 external suppliers and spent over £10m+ with 18 different suppliers.
In 2021-22, we looked at our spending in the industries which are at most risk of modern slavery. We identified that we have significant spend in some high-risk areas including buildings (construction, maintenance and repairs), recycling and waste disposal, horticultural and landscape, catering and events.
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.
In 2021-22, we updated the modern slavery clause in our corporate tender specification document. This means that when bidding for a contract, bidders who have statutory obligations under the Modern Slavery Act 2015 commit to fulfilling them and to supporting the council's modern slavery ambitions by minimising risks of modern slavery within their supply chains. They also commit to raising their concerns with the appropriate safeguarding agency if they suspect modern slavery or are concerned that somebody is a victim. These commitments will form part of their contract if they are the successful bidder.
All bidders must also complete a Standard Selection Questionnaire, a Living Wage Survey and an Anti-Slavery and Human Trafficking Questionnaire for high value tenders above the Procurement Regulation threshold of £177,897.50 + VAT for goods and services.
The Standard Selection Questionnaire requires bidders with an annual turnover of £36 million or more to confirm that they have a have a modern slavery statement (as per the Modern Slavery Act 2015) and include a link to this on their website. If suppliers fail this question, they will be disqualified from the bidding process.
The Living Wage Survey requires bidders who pay staff less than the hourly rate, as recommended by the Living Wage Foundation, to confirm the hourly rate for staff in each age group, including apprentices. This ensures that suppliers are not exploiting their staff by paying less than the National Minimum Wage. Successful bidders have to re-submit this survey once a year.
The Anti-Slavery and Human Trafficking Questionnaire asks bidders for more information about their anti-slavery policies, their staff training around modern slavery, and how they respond to businesses within their own supply chains who are non-compliant with the Modern Slavery Act. Contract managers at the Council have access to guidance which helps them to use questionnaire responses to identify areas for improvement and to work with suppliers to improve their capacity to prevent and respond to modern slavery. Like the Living Wage Survey, this questionnaire also has to be re-submitted once a year.
Training and awareness
All Council employees are made aware of modern slavery signs and indicators, and what to do if they have a concern, through the Council's mandatory safeguarding awareness course. Awareness is also raised through internal communications and campaigns, and additional training relevant to specific roles is frequently 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. During Safeguarding Week in June 2021, a modern slavery briefing session was co-delivered by Leeds City Council and West Yorkshire Police to 150+ professionals working in different sectors and organisations across the city.
Progress in 2021/22 and next steps
At the last review of the modern slavery statement, the council set out it's goals for 2021 to 2022. There is an update on progress below.
To promote the use of modern slavery self-evaluation resources to small and medium enterprises in the city which will assist them to assess the risk of modern slavery in their supply chains and mitigate against this risk
Progress
In February 2021, Stop the Traffik and the Shiva Foundation launched the Modern Slavery SME Toolkit. We have promoted this toolkit across our networks and on our website.
Next steps (ambitions for 2022-23)
In 2022-23, we will 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.
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
As well as delivering and promoting training to council staff and partner organisations, we developed a modern slavery workforce development survey for our modern slavery partnership organisations. This helped us to understand the training needs and gaps.
Next steps (ambitions for 2022-23)
In 2022-23, we will be using the findings of this survey to address the needs and gaps through our modern slavery workforce development subgroup.
To work with modern slavery partners to share good practice about how modern slavery is being prevented in their supply chains
Progress
This year, we have developed our supply chain statement and practice by looking at and learning from what other organisations are doing. This has been helped by having access to the new Modern Slavery Statement Registry.
Next steps (ambitions for 2022-23)
In 2022-23, we will continue to stay up to date with best practice and guidance.
To develop self-assessment processes within internal commissioning and contract management procedures to identify and respond to modern slavery in supply chains
Progress
In 2021-22, we identified the high-risk industries where we have significant spend and undertook some random dip-sampling of suppliers in these areas to ensure they had up-to-date modern slavery statements published on their websites.
Next steps (ambitions for 2022-23)
In 2022-23, we will review and republish our guidance for contract managers to support them with their annual reviews of the Anti-Slavery and Human Trafficking questionnaire. We will also utilise the council's e-Tendering platform to record the outcome of the questionnaires, including the Living Wage Survey, for statistical information as and when required.
This statement was approved by James Rogers, Director of Communities, Housing and Environment, and Neil Evans, Director of Resources on 9 September 2022.
You can request previous versions of the statement by email: saferleedssafeguardinganddvteam@leeds.gov.uk
