From 2022 the Modern Slavery Act 2015 (section 54) will require Arun District Council to publish a ‘Transparency in Supply Chains’ Policy Statement. The purpose of the Statement is to demonstrate the actions the Council will take to identify, prevent and mitigate incidences of modern slavery and trafficking in its supply chain.
This report sets out for approval the Policy Statement and the registration of the Policy Statement with The Home Office.
The Chair invited the Council’s Safeguarding Officer to present this report. She outlined that the report had provided detail with regard to modern slavery and the Council’s duties. This report had been prepared in advance of an imminent amendment to the Modern Slavery Act 2015 requiring local authorities to publish a ‘Transparency in Supply Chains’ Policy Statement, to prevent exploitation in procurement supply chains.
The report aimed to assist Managers to identify and mitigate any known risks and to ensure that any new contracts complied fully with the new duties.
The Committee, in discussing the report, was interest to learn what checks and balances were in place prior to contracts commencing with the Council and what type of activities would be put into pace to ensure contracts when procured had detailed the necessary tests to ensure compliance with the amended Act. It was explained that the new requirements stipulated that it was necessary for the Council to upload an annual statement of compliance to the home office registry. Training would be offered giving best guidance to current contractors setting out robustly other factors that would be held to account. It was recognised that there were some industries that had a higher likelihood of exploitation and so the Council would be working with its providers to ensure that all necessary checks would be actioned.
This would be assisted by providing training to Officers managing those type of contracts to ensure that the relevant questions to potential suppliers, starting with the larger contacts, would take place.
Concerns were raised as over the high levels of horticultural industry in the District which was often where exploitation could take place. Would the Council proactively inspect some of those premises to ensure compliance or was this a responsibility for the police? It was explained that this was a police function to ensure the safeguarding and welfare was actioned, however, the Council would ensure that that the businesses it was contracted with would undergo the required checks with the Council looking at the services it held contracts with to ensure that close working with partner agencies continued and the required checks were undertaken. The Group Head of Wellbeing outlined that through training staff and in undertaking the necessary site visit checks, Officers would be able to report back anything that was of concern.
Having had the recommendations proposed by Councillor Cooper and seconded by Councillor Stanley,
RESOLVED - That
(1) The Arun District Council’s Transparency in Supply Chains (TISC) Policy Statement be adopted;
(2) The Corporate Support Committee be requested to review the Council’s Procurement Policy to ensure that supply chain transparency is given appropriate consideration I the purchasing of goods and services;
(3) A break clause is required in contracts where Modern Slavery and Trafficking is identified and no remedial action is taken;
(4) A procurement threshold of £100,000 is supported for suppliers to evidence compliance with the Modern Slavery Act 2015; and
(5) Support is given to training in the principles of due diligence to mitigate any risk of exploitation in supply chains for front line officers and Officers involved in the procurement of goods and services.