Modern Slavery Transparency Statement

Kingston Council Modern Slavery Transparency Statement 2021/22

1.0 Summary

The Modern Slavery Act 2015 requires commercial entities with an annual turnover of £36m or more to report annually on their actions to identify, prevent and mitigate modern slavery in their supply chain. On a voluntary basis, Kingston Council has determined to annually publish a statement setting out the actions that are being undertaken to understand all potential modern slavery risks related to its business and actively ensure that there is no slavery or human trafficking in its own business and supply chains. This statement covers the period September 2021 to September 2022.

For the purposes of this statement and associated Policy, the term ‘Modern Slavery’ covers slavery, servitude, human trafficking, forced or compulsory labour and child labour. 

1.1 Our Commitment

Kingston Council has a zero tolerance approach to any form of modern slavery. We are committed to acting in an ethical manner, with integrity and transparency in all business dealings. We expect all those who work for us, or on our behalf, to share our zero-tolerance approach and are taking steps to help tackle forced labour, protect vulnerable workers and help prevent human rights violations.  

The Council understands the risk that all forms of modern slavery pose, both to its own residents, visitors, and internationally through the global nature of modern supply chains. Accordingly we are putting in place steps to eliminate and eradicate acts of modern slavery and human trafficking within our business, supply chains, sub-contractors and partners by adopting a zero tolerance policy in respect of modern slavery and human trafficking. 

The Council is fully committed to using all available avenues to tackle modern slavery by using its statutory powers, its role as a public procurer, through utilising the strengths of all its partnerships with the Police, the NHS and other organisations, and through wider awareness raising. 

This statement explains the steps that the Council has undertaken to ensure that there is no slavery or human trafficking within the organisation, its sub-contractors, partners or supply chains. It also sets out the plans for improvements in the next year. 

2.0 Organisational structure and supply chains

The ‘Making Kingston Better, Together’ Kingston Corporate Plan 2019-23 sets out an ambitious vision for Kingston, which we are determined to work with residents, businesses and local strategic partners across the public, private and voluntary sectors to achieve. This also focuses on delivering the following strategic outcome:

“A safe borough which celebrates our diverse and vibrant communities, with local priorities shaped through participatory democracy”

Kingston’s communities are places where residents feel safe and the fear of crime is low, with a zero-tolerance approach to domestic violence, hate crime and action against anti-social behaviour and modern slavery.

The vast majority of the Council’s net spend (nearly £146m); 55% goes on our ‘people’ services - learning and children’s services (£31.4m) and adult social care, health and community housing (£48.5m). Of the rest, we spend approximately £64m through our Corporate and Communities Directorate which includes some of our biggest contracts with external providers in relation to services such as waste management, street cleansing, parking, green spaces, and leisure. This directorate’s budget includes, amongst other things, spending on highways; environmental health; community safety; registrars and bereavement services; customer services and ICT. The Place Directorate spend includes planning, construction and works, facilities management, repairs and maintenance. 

These goods, services and works are procured from a wide variety of local, national and international businesses, public sector partners and voluntary sector organisations. Each supplier in turn may have its own supply chain. The challenge for the Council is to ensure compliance and best practice, not only within the organisation and across our immediate supplier base, but also through the wider supply chains that serve them.

The Council is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that its supply chains are free from slavery and human trafficking.

Responsibility for the organisation's anti-slavery and human trafficking initiatives sit as follows:

  • Developing local policies, responses and protocols that can identify and protect potential victims of modern slavery - Modern Slavery working group, a forum for safeguarding and community safety partnerships across both children and adults services in Kingston and Richmond 

  • Producing and revising the council’s modern slavery and human trafficking statement in line with current legislation and guidance - Assistant Director, Culture, Communities and Engagement and Corporate Strategy and Partnerships Manager

  • Including the Council’s approach to eliminating modern day slavery and human trafficking in its procurement policies, procedures and practices. - Assistant Director, Contracts & Commercial and Corporate Head of Commissioning

  • Ensuring staff are appropriately trained and equipped to minimise the risk of modern slavery and human trafficking through the Council’s corporate responsibilities, and to spot signs and report concerns through the appropriate routes - Assistant Director, People and Organisational Design & Director of Public Health.

3.0 Policies in relation to slavery and human trafficking

Kingston Council has set out clear and rigorous policies and procedures and high standards for employees that support early identification and management of risks in relation to modern slavery and human trafficking within the organisation and its suppliers. 

  • Recruitment and agency workers: The Council has a robust and transparent recruitment and selection process and ensure that all new workers recruited into a post at Kingston, whether full or part time employees, agency employees, or contractors/consultants have the requisite checks, which includes identification and right to live and work in the UK. There are additional DBS checks for anyone working with vulnerable people, including 5 years of referencing, ID validation and police checks. The Council uses Matrix SCM to supply temporary and interim staff. Matrix SCM has a proven and successful track record of delivering a managed service for temporary staff provision and the agencies in their supply chain have their practices verified to ensure that they are complying with good practice and employment legislation.

  • Code of Conduct: Kingston employees must behave honestly and follow Kingston’s policies and procedures. Our code of conduct makes it clear that staff must not behave in a manner inside and outside working hours which could damage the Council’s reputation. All employees are expected to keep within the law during their employment at all times. 

  • Safeguarding children and vulnerable adults: The Council embraces its responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and vulnerable adults. 

  • Living Wage: The Council operates a Job Evaluation Scheme to ensure that all employees are paid fairly and equitably. As part of its commitment to being a good employer, the Council has been an accredited Living Wage Employer since September 2019. To maintain the Living Wage accreditation it is mandatory for Kingston to pay all staff the living wage. Ensuring suppliers pay their staff the Living Wage is mandated through our procurement process. More than 200 Council suppliers pay living wages to over 4,000 commissioned staff. Implementing Living wage requirements was successfully introduced in Adult Social care with the launch of Care at Home and Supported Living Frameworks in July 2021.

  • Commissioning framework, policies and procedures:  Mandatory modern slavery requirements are built within the procurement sourcing process. Our standard contract terms include clauses that specify the supplier’s contractual obligation concerning Modern Slavery. The Council’s contract management principles and scorecards set out quarterly measurement of modern slavery risks under the ethical measurement criteria for all Tier 1 suppliers. Kingston Council was successful in its accreditation to the Good Business Charter in September 2021 which demonstrates a commitment to maintaining high ethical standards. Through this accreditation we will encourage all our suppliers to sign up to the Charter and adhere to the 10 ethical standards. 

  • Equality and Inclusion: Being Respectful of difference and valuing diversity, is one of our STAR values that also reinforces our ongoing commitment to equality, diversity and promoting a cohesive community in Kingston. We are in the process of reviewing actions linked to our Equalities, Diversity and Inclusion Strategy and Action Plan for Kingston (2021-26). The strategy has a focus on being a safe borough for all where diversity is celebrated and respected. We aim to work with all our partners to promote this within the borough and beyond. We have plans to further explore how we can promote equality and inclusion within our procurement processes. The Council has a commitment to creating a diverse and inclusive workplace, where staff feel respected and valued in their job. We will continue to work with and involve our equalities networks in our approaches to both valuing diversity and supporting staff to raise any incidents of inequality. 

4.0 Due diligence processes

Kingston Council is unequivocally opposed to the use of exploitation of forced labour and we are determined to do all we can to help stamp it out. We expect all those who work for us, or on behalf, to share our zero-tolerance approach and are taking steps to help tackle forced labour, protect vulnerable workers and help prevent human rights violations.

We want to ensure that our commissioned organisations and their supplier chain have appropriate due diligence processes in place and fully comply with the Modern Slavery Act 2015. It is important that our suppliers/ contractors continue to identify and address risks of modern slavery in their operations and supply chains as a priority, recognising the impact that COVID-19 may have had in creating or exacerbating situations of modern slavery in supply chains.

Steps already taken:  

  • In the standard selection questionnaire, used to shortlist suppliers, we ask organisations whether they are required to produce a Modern Slavery Statement and provide a link to the statement on their website if they are in-scope. All tender processes require bidders to provide confirmation that they are compliant with the Act.

  • The current standard terms and conditions make provision for our supplier base to comply with the Modern Slavery Act

  • The Council has implemented a Tier 1 contract management scorecard approach for high value/ high risk contracts which includes an evaluation criteria on ethical sourcing and includes quarterly monitoring of contractors to ensure they are meeting their legal obligations and are compliant on preventing Modern Slavery, ensuring legal working rights in the UK, human rights and equality requirements. 

  • Measuring Modern Slavery Risks in your contract - assement tool designed in collaboration with our internal and external stakeholders and shared with over 500 key suppliers in the early part of 2021. 

  • Safeguarding the most vulnerable children and young people - Ofsted inspection commended the Council and Achieving for Children for protecting vulnerable adolescents from sexual and criminal exploitation, gang involvement, missing children, radicalisation, trafficking and modern slavery. 

5.0 Risk Assessment and Management

The Council has carried out a Risk Assessment for COVID-19 workplace arrangements, identifying COVID-19 related risks and appropriate measures to control risk. The assessment includes:

  • How employees are supported to work from home

  • Guidance and recommendations for employees required to travel for work 

  • How to ensure safe working practices at home and correct desk set up guidance to prevent injury

  • Reintroducing staff to the office on a hybrid work plan and ensuring social distancing and correct hygiene practices are maintained in common areas and meeting rooms. 

There is a wealth of information about the hybrid working arrangements for Council staff on the Future Workplace intranet pages.

In addition, the findings from ‘Measuring Modern slavery risks in your contracts’ has informed the supply chain mapping and has helped identify areas for further investigation, learning, support and monitoring. Over 120 suppliers participated in the initial mapping exercise, which has now moved onto the validation stage and will inform the contract performance meetings with suppliers for the remainder of the year. An initial targeted training programme for both officers and suppliers is being devised. 

Throughout the COVID-19 pandemic victims of Modern Slavery may have become even more isolated, therefore awareness raising is occurring throughout the whole Council. There are E-learning courses for staff and numerous communications on the intranet. The commissioning network provides thorough training on new updates in legislation and then filters these learnings throughout their teams. Additionally, the Richmond and Kingston safeguarding partnership regularly sends out best practice updates. 

Actions moving forward: 

  • Developing a modern slavery measurement framework that will be incorporated to service specifications and contracts with all our suppliers and ensure effective monitoring.

  • Enrolling in a contract management scorecard approach that includes specific requirements under ethical contract management criteria across all Tier 2 contracts on an annual basis.

  • Continuing to map our supply chains of impacted contracts, identifying areas for further investigation, support, monitoring and awareness  

  • Creating a webpage with information and guidance to all staff and external stakeholders on managing modern slavery risks and useful resources and contacts.

  • Developing a Modern Slavery Policy which will take account of the leadership role that the Council can play in tackling Modern Slavery across the borough  

    • identification and referral of victims

    • provision of support to victims – this can be through safeguarding children and adults with care and support needs and through housing/homelessness services

    • community safety services and disruption activities, including a focus on awareness raising in the local community 

    • ensuring that the supply chains councils procure from are free from modern slavery.

    • Data collection mechanism to understand the extent of Modern Slavery at a local level

6.0 Key performance indicators to measure effectiveness of steps being taken 

Kingston Council will use the following performance indicators to measure the effectiveness of actions in managing the modern slavery and human trafficking risks in any part of its business or supply chains: 

  1. All suppliers confirming their adherence to the Modern Slavery Act 2015. 

  2. Annual monitoring of modern slavery risks with our suppliers which informs gap analysis and reflective action log and programme. 

  3. % of Contract Management scorecards receiving ‘meeting expectations’ under ethical sourcing assessment criteria. 

  4. All Corporate procurement and Contracts teams complete CIPS ethical procurement training. 

  5. Rate of completion of modern slavery e-training module. 

  6. The percentage of suppliers reporting that all their staff have completed modern slavery training.

  7. The number of cases reported, how it results in action and the lessons learned moving forward. 


7.0 Training on modern slavery and trafficking

As well as training key staff, the council will raise awareness of modern slavery issues by circulating information through intranet links and messages and inclusion of information in briefings of operational staff. This will be done in conjunction with the Safer Kingston Partnership, Healthy & Safe Communities. This includes:

  • Anti Slavery programme involving a series of training throughout the week. The modern slavery event includes  presentations on the NRM Process from Home Office, Identification and Support to adult victims of Modern Slavery and Identification and support to Children victims. 

  • Identifying and reporting the signs of modern slavery - Developing a corporate e-learning training programme on Modern Slavery for all council employees. The length of the training (60- 75 minutes). This is designed to raise awareness and to help recognise individuals’ roles in identifying and reporting concerns. The council also provides additional in-depth training for staff, including Train the Trainer, who are involved directly in working with communities. A new pathway for manging modern slavery risk has been approved and is now being implemented.

  • Procurement and contract management staff will complete a bespoke e-learning Ethical test module developed by the Chartered Institute of Procurement and Supply (CIPS). This training covers human rights, environmental considerations and corruption and bribery. By completing this training the team will be applying for a CIPS Corporate Ethics mark and additionally will be listed on the CIPS Global Corporate Ethical Register. A commissioning competencies model and a learning development plan has been designed alongside the commissioning framework, which will support its implementation.

  • Recruitment and agency staff - The Council ensures all HR professionals are suitably qualified in relation to recruitment procedures and all recruiting managers are supported by HR staff, with training offered in recruitment and interviewing techniques.

  • All Party Members briefing and awareness raising sessions - recorded sessions, resources and infographics/posters that can be used to raise members’ awareness.

  • Awareness-raising through its partnership: The organisation has raised awareness of modern slavery issues through its partnership work and in line with its statutory duty to identify and refer victims through the National Referral Mechanism. An example of this is the inclusion of “Roy’s Story” as part of the Annual Adults Safeguarding Report. This demonstrates how agencies are reviewing cases through the Kingston Safeguarding Adults Board and highlights how partners are working together to identify learning points regarding modern slavery through in depth understanding of real local examples. There is a modern slavery working group that works on referral pathways in Kingston and Richmond to also provide awareness raising and training. 


Approval for this statement 

This statement has been approved by Ian Thomas CBE, Chief Executive, Kingston Council  and will be reviewed in September 2022.

Signed                                             Date

Last Modified: 06/10/2021 13:14:30