Modern slavery statement 2023 / 2024
In accordance with Section 54 of the Modern Slavery Act 2015, the Police and Crime Commissioner for Gwent and the Chief Constable recognise their responsibility as an employer to be aware of the potential for instances of modern slavery, and to report such instances or concerns to the relevant bodies. This statement is underpinned by a local action plan.
This statement sets out the work undertaken during the financial year ended 31 March 2023 to further identify, prevent and address modern slavery across the force and its supply chains.
What is modern slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, sexual exploitation, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
The Police and Crime Commissioner for Gwent and the Chief Constable are committed to ensuring that there is no modern slavery or human trafficking in the force supply chains or in any part of the business. The force’s policies, procedures and our work to tackle modern slavery through a working group, demonstrates our commitment to act ethically, with integrity and to identify risks that we can work to mitigate.
In 2017, the police and crime commissioners and chief constables from the four Welsh police forces signed up to the Welsh Government Ethical Employment in Supply Chains Code of Practice.
Gwent Police is fully committed to combating unethical or illegal employment practices in supply chains. This commitment is underpinned by an action plan to deliver the commitments within the Code.
Our approach to identifying and tackling modern slavery is broken down into four key areas:
Enforcement - we will play an active role in enforcement and will use our roles in employment and purchasing goods and services to improve intelligence gathering whilst ensuring full compliance with the Code of Practice as well as acting promptly on information received.
The Force’s Modern Slavery policy, set by the Chief Officer team, is in place to reduce the risk of serious harm to victims and improve safety, health and wellbeing.
The policy outlines how modern slavery offences will be dealt with and offenders held to justice. Working with the Crown Prosecution Service or other bodies, we endeavour to successfully prosecute offenders, with the aim to enhance the trust and confidence of victims.
Robust training is provided to all officers, highlighting signs, process, victim care and support services.
Ethical procurement – promoting the development of ethical supply chains in the delivery of contracts for the police service in Wales and specifically in Gwent.
Employment – following best practice and demonstrating full commitment to constant improvement within the systems and structures of Gwent Police, as well as working with the other forces in Wales and with partners to identify and eradicate any form of exploitation.
Environment – we will create an environment where the public in Wales have confidence and understanding of how to report any signs of exploitation in all its forms. We will ensure that all our staff, particularly Community Support Officers and staff in our Force Control Room, are fully aware of what to look out for and what to do when concerns are reported.
We recognise that modern slavery extends far beyond our national borders and that risks are increased with complex supply chains.
An initial review of our supply chains has highlighted the potential risk of modern slavery in the following categories:
- information communication and technology
- cleaning and waste disposal services
- uniform manufacture
We appreciate that modern slavery can and does occur in many other supply chain categories and we are mapping our supply chains using a risk tool to identify the areas we should prioritise as part of our practical response to modern slavery risks.
Fully investigating supply chains is a challenging task but in the previous 12 months we issued supplier assessment questionnaires (SAQs) to a further 19 suppliers, bringing the total issued to 79 with 63 suppliers given a rating. The suppliers selected are identified as higher risk due to their industry type, nature of the workforce, supplier location, commodity type or the level of our expenditure or are suppliers to whom we have recently awarded a contract and issued the assessment as part of our contract management activity.
We are committed to sharing information to make the best use of our resources. By working with other forces, we can better investigate supply chains based on the greatest risk of human exploitation.
We will continue to work to raise awareness of modern slavery issues across our supply chain. Our action plan includes a target to assess the top one hundred suppliers across South Wales Police and Gwent Police by 2025 and we are on track to achieve this.
Due diligence and risk assessment
Gwent Police has continued to advance this work to fulfil the actions agreed and recorded on our local action plan for the period 2022-23.
- The Joint Collaborative Commercial and Procurement Strategy, 2020-2025 incorporates a responsible procurement policy. The policy includes our commitment and activity to implement the Welsh Government Ethical Employment in Supply Chains Code of Practice, and ethical purchasing principles. In addition to this, we are supportive of the principles in the Bluelight Commercial Responsible Procurement & Commissioning Strategy.
- ethical procurement is reflected in the Force Delivery Plan, deliberately recognising ethical procurement as a tool in the creation of a more hostile environment for modern slavery.
- our recruitment policy reflects our commitment to the Welsh Government Ethical Employment in Supply Chains Code of Practice and is operated and assessed in line with the equality, diversity and inclusion force direction. The recruitment team are responsible for ensuring ethical principles of employment are adhered to when utilising job sites and recruitment agencies.
- our Business Interest Policy reflects the Ethical Employment in Supply Chains Code of Practice. Officers and staff must be aware of the Code when submitting a business interest approval request.
- The Welsh Government Code of Practice is a standard agenda item on the agenda of our trade unions.
- The Force’s Modern Slavery Policy for frontline officers is reviewed annually by the Force Intelligence & Organised Crime Unit.
- Other relevant policies include the College of Policing Code of Ethics and we have launched the All Wales Whistleblowing policy to empower staff to raise suspicions of any unlawful and unethical employment practice.
- Where appropriate and proportionate, we are using the Bluelight Commercial Social Value Toolkit to ask bidders how they are tackling modern slavery within their organisations and supply chains. We score social value in our tenders to demonstrate how we expect our suppliers to reflect our response and in turn, assist the force in delivering a range of social value initiatives.
- We are embedding a culture of wider responsibility within the Force for those involved in the procurement of goods and services.
- Our standard contract terms and conditions include the right to investigate and establish accountability and a commitment by the winning bidder to complete an assessment questionnaire to establish a baseline where appropriate.
- We continue to share best practice and our work to assess suppliers with the Welsh forces.
Payment Performance Statistics
- Invoice payment performance statistics are published annually on the Police and Crime Commissioner’s website in line with the statutory requirement.
Assessing existing suppliers and supply chains
- We have simplified our Supplier Assessment Questionnaire (SAQ) tool.
- We are working with Bluelight Commercial to expand the Netpositive Tool to include modern slavery, ethical practice, social contribution and climate emergency in a single tool for suppliers. This will replace the SAQ tool. The objective is to share the work completed by Bluelight Commercial and the southern Wales forces and provide tools to enable other police forces to expand this initiative nationally.
- Bluelight Commercial have committed to investigate the supply chains of suppliers common to many police forces in the Fleet and ICT categories. This will bring a benefit to all forces and make effective use of resources.
- We have identified high risk subcontractors, and in certain cases such as within the waste sector, we have ensured our tier one supplier flows down the ethical supply chain assessment to the subcontractor to provide assurance that fair work practices are in place at all tiers of the supply chain.
Training and raising awareness
- Completion of annual CIPS (Chartered Institute of Purchasing and Supply) refresher training by strategic procurement staff
- 66 officers and staff across South Wales and Gwent Forces (March 2023 figure) completed or had reserved a place on the Fundamentals of Contract management training provided by Bluelight Commercial. The training includes an awareness of ethical supply chains.
- Ethical dilemma scenarios are shared across the Welsh forces to improve awareness of ethical matters across the forces.
- A Task and Finish Ethical Supply Chains group met regularly throughout the year, chaired by the Chief Financial Officer as the Ethical Champion. Actions were progressed for each of the four strands, Ethical Procurement, Employment, Environment and Enforcement.
- Recruitment, promotion, interview and related internal processes encourage equality, diversity and inclusion good practice.
- A communications plan is in place to ensure staff are aware of and trained in the internal referral routes for highlighting modern slavery concerns where they emerge.
- The success of this work is reported into the Welsh Forces’ Finance Joint Assurance Group and at the All Wales Collaboration Board Group.
This Statement has been approved by The Police and Crime Commissioner for Gwent and the Chief Constable. It will be reviewed and updated annually.
The public and staff equally have a responsibility to be aware of potential instances of modern slavery or of a business using forced labour. If you have any such concerns, please contact any of the following bodies:
Gwent Police: Telephone 101 (or 999 in an Emergency). Report a crime online
Modern Slavery Helpline: Telephone 0800 0121700
Crimestoppers: Telephone 0800 555 111
Confidential Concerns Line, Safecall 0800 9151571 (Gwent Police employees only)
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