Kingston Council modern slavery transparency statement
1.0 Summary
1.1 The statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and explains the steps that Kingston Council has undertaken to ensure that there is no slavery or human trafficking within our organisation, our subcontractors, partners, or supply chains. This statement relates to actions and activities during 2023/2024. It also sets out the plans for activity in the next year.
1.2 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. Although it is not currently a requirement for Local Authorities, Kingston Council publishes this statement to provide transparency and demonstrate our commitment to tackling modern slavery and human trafficking and sets out our role and policies as a public sector organisation, together with our partners.
2.0 Our Commitment to tackling modern slavery
2.1 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.
2.2 The Council understands the risk that all forms of modern slavery pose, both to its own residents, visitors, and through its supply chains and is working proactively 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.
2.3 The Council Plan 2023 - 2027 sets out an ambitious vision for Kingston, which we will work with residents, communities, businesses and local strategic partners across the public, private and voluntary sectors to achieve. We are committed to working with partners and fulfilling our statutory duties to ensure that people are safe and feel safe in the borough. Through the plan, our aim is:
“Safer: Our borough stays safe, well-maintained and resilient so individuals and communities can thrive and prosper. “
2.4 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.
2.5 Having established effective governance arrangements for commissioning activity across the organisation, in line with its Commissioning framework, the Council continues to be highly committed to ethical sourcing practices. We expect that partners will commit to supporting key policies, including paying staff working on council contracts the London Living Wage, adopting a robust approach to Modern Slavery, promoting good mental health in the workplace through initiatives such as the Time to Change Pledge, signing up to the White Ribbon campaign, ensuring equality and diversity considerations permeate all aspects of their delivery, and responding to the climate change emergency.
2.6 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.
3.0 Preventing Modern Slavery in our Business
3.1 Kingston Council has a duty to prevent and tackle modern slavery or exploitation of its own staff [directly employed or appointed through a recruitment agency].
3.2 The Executive Director Residents & Communities has the overall responsibility for ensuring this anti slavery and human trafficking policy and statement complies with our legal and ethical obligations, and that all those under our control comply with it.
3.3 A number of clear and rigorous policies and procedures and high standards for employees support early identification and management of risks in relation to modern slavery and human trafficking within the organisation and its suppliers, as set out below:
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Recruitment and Employment Terms, including paying at least London Living Wage to all employees
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 Living Wage Employer. The supply of temporary and interim staff is provided by Matrix SCM who have 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 and Dignity at Work for employees which sets out the expectations of staff, management, and the whole organisation
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. - Inclusive Kingston: Our Equality, Diversity and Inclusion Strategy outlines how we plan to actively search for and support people who are disadvantaged, and work to break down the barriers to opportunity for all. 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.
- Whistleblowing Policy provides a confidential channel for staff to report any concerns of exploitation and for these to be investigated
- 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. The Modern Slavery Working Group ensures there are strong partnership links between Adult Social Care, Kingston Safeguarding Adults Board, Children’s Services, the Kingston and Richmond Safeguarding Children Partnership and Community Safety to ensure a coordinated response to tackle Modern Slavery in Kingston.
- Learning and development programme, ensuring all staff complete mandatory training on modern slavery and human trafficking. In addition, all our purchasing and contract management staff completed CIPS Ethical procurement training.
4.0 Anti-slavery and human trafficking initiatives
4.1 Modern Slavery working group, a forum for safeguarding and community safety partnerships is set up across both children and adults services in Kingston and Richmond.
4.2 The group is responsible for developing local policies, responses and protocols that can identify and protect potential victims of modern slavery.
Over the past year, this forum has:
- brought in specialist training around Modern Slavery into the borough
- developed a Sexual Exploitation Partnership Protocol/Policy
- developed a local referral pathway/flow-chart for the risk assessment of those at risk of modern slavery, which has been shared with partners
- started to map out local data and needs
- developed and delivered Modern Slavery Awareness multi-agency training for both adults and children's services practitioners using a pool of local trainers.
5.0 Preventing Modern Slavery in our Supply Chains
5.1 Kingston Council recognises the role and responsibility that comes with its buying power and the need to ensure that all purchasing practices consider the ethical, social and law-abiding elements when determining who it may contract with. Part of this is ensuring suppliers act in accordance with the Modern Slavery Act 2015 and take their responsibilities under all modern slavery legislation seriously. This is not only to comply with the law but also to ensure we support and safeguard vulnerable people and make Kingston a safer borough.
5.2 Commissioning framework, policies and procedures: Mandatory modern slavery requirements are built within the commissioning, procurement and contract management 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 our supply chain.
6.0 Steps taken since the last statement
The following activities and actions have been undertaken during the past 12 months period:
6.1 Following the publication of PPN 02/23 - Tackling Modern Slavery in Government Supply Chains, we have reviewed and amended where necessary our procurement operating procedures, process, and related documentation. We have also incorporated the additional guidance on enhanced due diligence activities and on using existing exclusion grounds.
6.2 The new PPN 03/23: Standard Selection Questionnaire (SQ) introduced additional requirements under Modern Slavery and bidders must also demonstrate that they are tackling Modern Slavery in their supply chains. Whilst this is mandatory for Central Government contracts, Kingston council implemented the proposed changes to SQ stage prior to June 2023, effective date.
6.3 Modern slavery contract provisions contained within the Model Services Contract template, published by the Cabinet office in August 2023, have been incorporated with amendments to the Council’s form of agreement templates. This strengthens the anti modern slavery measures through contracting.
6.4 Rolling out of contract management scorecard requirements to Tier 2 and Tier 3 contracts meant that anti modern slavery requirements are now built into contract management practices throughout our supply chain. The scorecards include an evaluation criteria on ethical sourcing with requirements for suppliers to meet their legal obligations and take proactive action to prevent Modern Slavery, ensuring legal working rights in the UK, human rights and equality requirements.
6.5 Renewal of the accreditation with Living Wage Foundation as a Living Wage Employer. The Council’s ongoing commitment to London Living Wage (LLW) has resulted in 12,000 staff benefiting from LLW across 327 suppliers. Kingston Council was nominated for the Living Wage Public Sector Champion Awards in May 2023 in recognition of its significant commitment to living wage movement.
6.6 The Council also renewed its accreditation with the Good Business Charter and achieved the Chartered Institute of Purchasing and Supply (CIPS) Corporate Ethics Mark, with over 50 procurement and contract managers completing the CIPS Corporate ethical procurement and supply e-learning course, which includes a module on modern slavery. Mandatory training for a wider workforce is now in place.
6.7 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. A protocol has been created to support those who are at risk of sexual exploitation through a multi-agency response. The Adult Vulnerable Adult Multi Agency risk assessment panel (VAMA) oversees the adult safeguarding modern slavery reported cases to ensure awareness of these cases with the right professionals and elements such as NRM referrals or notifications, take place.
7.0 Risk Assessment and Management
7.1 The existing financial pressures will continue to present a challenge for the council due to the increasing rate of inflation, rising energy costs and the ‘cost of living crisis’ impacting adversely not only on the council but also the supply chain. This will require the Council to be more diligent in managing our relationships with our supply base.
7.2 There has been a recent spike in migrant populations in Kingston through the various Home Office led migration initiatives such as Afghan Resettlement, the Hong Kong BNO Warm Welcome, the Homes for Ukraine schemes and other migrant schemes. These communities have fled violence, conflict and dislocated from their communities and family support structures. Serious post-traumatic effects, including depression and anxiety and specific vulnerabilities and the inability to navigate their way in their new environment puts them at risk of exploitation and abuse.
7.3 The Council has been working with key partners to ensure there is commissioned targeted integration support available through direct case work, welfare checks and integration activities available to individuals and families arriving in Kingston across all schemes. The Council has set up a Kingston United for Ukraine Welcome Centre at Guildhall 2 for walk in appointments and for new arrivals to learn about the range of community offers available. New arrivals are provided with local emergency contact phone numbers. This space is also used for all vulnerable migrant families living in Kingston.
7.4 In the post-Brexit surge in migration and 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. The Modern Slavery Working Group also supported the delivery of modern slavery training in 2023, with further sessions planned for 2024.
7.5 Continue to review and amend contract management processes and any related documentation, for both new and existing contracts. Establish modern slavery risk assessment and due diligence annual assessment across the supply chain.
7.6 The Illegal Migration Act 2023 presents serious implications for people who are victims of modern slavery, and Kingston as part of the local partnership, is considering the operational implications this will have on its services and support offering.
8.0 Actions moving forward
The following actions will be completed over the next monitoring period:
8.1 Continuing to map our supply chains of impacted contracts, identifying areas for further investigation, support, monitoring and awareness;
8.2 Continue to monitor all reported modern slavery safeguarding adults cases through our Vulnerable Adult Multi Agency Risk Assessment Panel (VAMA) and work with partners and other Kingston panel to ensure we have oversight of reported modern slavery concerns.
8.3 Awareness-raising through its partnership: of modern slavery issues by circulating information through intranet links and messages and inclusion of information in briefings of operational staff. Develop and deliver VASA Panel's 4-week Exploitation Campaign.
8.4 Anti Slavery Training - A continued commitment to bring modern slavery training into the borough to support the partnership around understanding what modern slavery is, the indicators and how to support those at risk of modern slavery.
8.5 The development of the Responsible Business Guidance that sets out the joint commitment between the council and our third party providers including local businesses, SMEs and Voluntary and Community Sector Organisations, having regard to ethical values and practices, in alignment with Good Business Charter accreditation requirements.
Approval for this statement
This statement has been approved by Sarah Ireland, Chief Executive, Kingston Council and will be reviewed in November 2025
Signed Date 11.12.2024
