Modern slavery statement

The following is the modern slavery and human trafficking statement of NHS Cornwall and Isles of Scilly Integrated Care Board (the ICB) for the financial year ending 31 March 2025 in accordance with Section 54, Part 6 of the Modern Slavery Act 2015.

Modern slavery is a serious crime that violates human rights. Victims are forced, threatened or deceived into situations of subjugation, degradation and control which undermine their personal identity, financial security and sense of self.

NHS Cornwall and Isles of Scilly Integrated Care Board (ICB) recognises our responsibility to take a robust approach to modern day slavery and human trafficking and we are committed to its prevention within all corporate activities. We make this statement in respect of this commitment to prevent slavery and human trafficking in both our employment and supply chain.

Definitions

The Modern Slavery Statutory guidance 2024 provides information about the definitions of modern slavery for staff who may encounter or support potential victims.

Modern slavery encompasses:

• human trafficking
• slavery, servitude and forced or compulsory labour

The definition of a victim of human trafficking, slavery, servitude and forced or compulsory labour is set out in the Slavery and Human Trafficking (Definition of Victim) Regulations 2022.

Human trafficking

The essence of human trafficking is that the victim is coerced or deceived into a situation where they are exploited. Article 4(a) of the Council of Europe Convention on Action against Trafficking in Human Beings (the Convention) defines ‘human trafficking’ as:

“the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation”

This may include one or more of the following:

• 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

Our organisation and structure of supply chains

The role of our organisation is to plan and buy health and care services for people registered with GP practices in Cornwall and the Isles of Scilly.

These services include general practice, planned hospital care, mental health and learning disability services, urgent and emergency care, children’s health services, community services, NHS 111, a GP out of hours service, pharmacy, dentistry and ophthalmology. Together, we serve a population of over 600 000 people.

As well as people services we also consider supply chains in our non healthcare services such as our joint working relationships with the voluntary, community and social enterprise sector.

Our approach

Our overall approach will be governed by compliance with legislative and regulatory requirements. It will also be led by maintaining and developing good practice in our employment, contracting and procurement processes. The foundation of this approach is to uphold the human rights of all citizens that work for us or are part of our supply chains. 

This approach includes prevention, working with partners both in health care and other sectors, to respond to incidents and taking steps to develop and improve our arrangements as needed.

Our safeguarding policies and arrangements

The ICB recognises safeguarding as a high priority and ensures there are arrangements in place to provide strong leadership, vision and direction for safeguarding. The ICB will ensure it has clear and accessible policies and procedures in line with relevant legislation, statutory guidance and best practice.

Human trafficking and modern slavery guidance is included in our safeguarding policies. This includes our safeguarding children policy and our adult safeguarding policy which are cross-referenced to the Cornwall and Isles of Scilly Safeguarding Adults Board and Safeguarding Children’s Partnership and Safer Cornwall policies.

Any safeguarding response that is needed for a person affected by modern slavery would be provided through the agreed multi agency policies and procedure of these boards and partnerships.

Training

Reference is currently made to Modern Slavery and Human Trafficking within NHS Cornwall and Isles of Scilly ICB’s mandatory Safeguarding Children and Adult training programmes and in house training carried out in accordance with Section 6 of Procurement Policy Note (PPN) 02/23 – Tackling Modern Slavery in Government Supply Chains – Guidance.

Emergency preparedness, resilience and response

The ICB is committed to deliver against its statutory duty as a category one responder under the Civil Contingencies Act 2004 and will deliver our incident response function in relation to any modern-day slavery incident that requires activation of a victim reception centre requiring wider health support which in turn support multi agency partners.

Our procurement and contracting policies and arrangements

We recognise our responsibility for ethical and responsible purchasing of goods and services within  our  procurement protocol. The protocol details how we purchase goods and services in line with legislation. This includes recognising social value in the award of contracts. 

Due diligence and risk assessment in our supply chain

Our procurement protocol also details how the ICB  supports responsible and ethical sourcing; meaning socially, environmentally and economically accountable procurement to ensure that the ICB awards contracts in line with its regulatory and legislative responsibilities, including the Modern Slavery Act 2015. Activities as part of the sourcing lifecycle ensure that those undertaking procurement activity are taking every opportunity to identify where there is the possibility of Modern Slavery occurring within the supply chain, for example, costs that appear abnormally low, and seeking assurance from bidders that that subcontractors will be managed to ensure Modern Slavery is identified and tackled further down the supply chain. This enables us to assess and manage risks through our procurement process.

The ICB’s contractual agreements have been risk stratified in accordance with the Procurement Policy Note 02 23 Tackling Modern Slavery in Government Supply Chains 2023 .

The ICB’s contractual agreements (Standard NHS Contract) contain an obligation within clause SC1 Provision of Services for providers of services to perform all its obligations under the contract in accordance with:

• the terms of this contract
• the law
• good practice

Providers who execute goods and services through sub-contracted or supply activity have an obligation to pass on the terms stated above through their contractual relationships and supply chains.

The ICB is committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have systems in place to encourage the reporting of concerns and protect the rights of employees to have freedom to speak up.  

We adhere to the national NHS employment checks/standards. This includes employees UK address, right to work in the UK and suitable references. The ICB expects national or international supply chains, to have suitable anti- slavery and human trafficking policies and processes in place.

This statement is made pursuant to Section 54 (transparency in supply chains) of the Modern Slavery Act 2015 and constitutes our organisation’s modern slavery and human trafficking statement for.