1.1 The Lancashire Procurement Cluster (LPC) hosted by East Lancashire Hospitals NHS Trust is a shared collaborative procurement and logistics service for Blackpool Teaching Hospitals NHS Foundation Trust, East Lancashire Hospitals NHS Trust and Lancashire Teaching Hospitals NHS Foundation Trust.
1.2 The LPC are committed to improving our practices to combat slavery and human trafficking. We are fully aware of our responsibilities we have towards patients, service users, employees and the local community. We have a robust set of ethical values that we use as guidance for our commercial activities. We also expect all suppliers to adhere to the same ethical principles.
2 LPC COMMITMENT
2.1 The LPC have the patient at the heart of everything we do and this is reflected in the way we run our business which makes sure that we are able to deliver against the quadruple aims of:
- Safe, Effective and Personal Care (patient centred)
- Delivering efficient and cost effective services
- Delivering social value such as through local employment, compliance with the Modern Slavery Act 2015 , reducing environmental impact
- Staff Joy – aiming to be the employer of choice for procurement and logistics professionals
2.2 By publishing this statement the LPC believe it demonstrates its commitment to:
- Comply with the Modern Slavery Act 2015 and regulatory requirements;
- Make suppliers and service providers aware that we promote the requirements of the legislation;
- Develop an awareness of human trafficking and modern slavery within our workforce; and
- Consider human trafficking and modern slavery issues when making procurement decisions.
3 WHAT DO WE MEAN BY MODERN SLAVERY & HUMAN TRAFFICKING?
3.1 Modern Slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. Any consent victims have given to their treatment will be irrelevant where they have been coerced, deceived or provided with payment or benefit to achieve that consent.
3.2 Modern slavery is the recruitment, movement, harbouring or receiving of children, young people or adults through the use of force, coercion, and abuse of vulnerability, deception or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.
4 WHAT IS THE LPC DOING TO DELIVER ITS COMMITMENT?
4.1 The LPC take steps to work with its supplier base and associated supply chain partners as far as is possible to identify and mitigate the risks of modern slavery and human trafficking and ensure modern slavery is not taking place.
4.2 All LPC staff upholds the Chartered Institute of Procurement and Supply (CIPS) code of professional conduct and practice relating to procurement and supply and have been briefed on the Modern Slavery Act.
4.3 All members of the LPC are required to undertake Safeguarding training at a level appropriate to their roles and responsibilities. Members of the procurement team attend external Modern Slavery training courses.
4.4 The current procurement processes dictates, all spend, aside from a few exceptions such as rates, is ordered and paid via a Purchase Order (PO). The applicable contract terms policy applies to any NHS organisation and states that where an NHS body issues a PO the standard NHS Terms & Conditions apply.
4.5 Section 10 (Warranties) of those standard NHS terms and conditions state the following:
4.6 The LPC will:
- check and review specifications to ensure they include a commitment from suppliers to support the requirements of the act.
- ensure no contracts are awarded where suppliers do not demonstrate their commitment to ensuring that slavery and human trafficking are not taking place in their own business and/or supply chains.
- work with the trust when appointing new suppliers so appropriate checks can be undertaken
5 NATIONALLY - NHS SUPPLY CHAIN
5.1 NHS Supply Chain is the NHS primary supplier of medical equipment and consumables.
5.2 Supply Chain Coordination Limited (SCCL) is the management function of the NHS Supply Chain.
5.3 SCCL in conjunction with the Category Tower Service Providers (CTSPs) are undertaking a Modern Slavery Assessment Programme.
5.4 This programme complements the government’s programme of work, which is well underway – with departments such as the Home Office, HMRC and the Department for Business, Energy and Industrial Strategy (BEIS) and demonstrates both the government’s commitment to the issue and the key role that public procurement can play in tackling modern slavery.
5.5 Aims of the programme:
• More transparency will be required of suppliers and their supply chains.
Modern slavery will become part of supplier performance and suppliers will be expected to work collaboratively on this issue with CTSPs to drive improvements.
- Creation of a Modern Slavery Assessment Tool
The tool itself is a risk identification and management tool that will help CTSPs work in partnership with suppliers to reduce the risk of exploitation of workers in supply chains and help to drive improvement and remediation.
6 KEY PRIORITIES FOR 2021
6.1 The LPC is committed to delivering the following priorities:
- Work closely with other public sector partners across Lancashire and South Cumbria to deliver a coordinated approach that shares best practice and increases overall awareness.
- Continually review our procurement processes to ensure that the LPC is meeting its commitment to eradicating modern slavery in its supply chains.
- Work with NHS Supply Chain to explore the adoption of the Modern Slavery Assessment Tool
7.0 PUBLISHING STATEMENT, GOVERNANCE AND REVIEW
7.1 The LPC Modern Slavery & Human Trafficking Statement will be published on trusts websites and the LPC website.
7.2 The statement will be reviewed annually with the next review June 2022.