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Modern Slavery Act statement

Modern slavery is the recruitment, movement, harbouring or receiving of children and adults, through force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.

Frimley Health NHS Foundation Trust (“the Trust”) has a zero-tolerance approach to modern slavery and any form of abuse. The aim of this statement is to demonstrate that the Trust follows good practice and takes reasonable steps to prevent slavery and human trafficking.

Organisational structure

Frimley Health NHS Foundation Trust was formed 1st October 2014, through acquisition of Heatherwood and Wexham Park Hospitals NHS Foundation Trust by Frimley Park Hospital NHS Foundation Trust. The combined organisation provides acute, specialist and other health care services across three main hospital sites, community hospitals and other services. Frimley Health NHS Foundation Trust is a key partner in the Frimley Health and Care Integrated Care System.

The Trust has 13,500 employees and provides services for 900,000 people, across Berkshire, Hampshire, Surrey and South Buckinghamshire.

The Chief Executive for Frimley Health NHS Foundation Trust has ultimate accountability for ensuring that the health contribution to safeguarding and promoting the welfare of children and adults is discharged effectively. The Chief of Nursing and Midwifery is the executive lead for safeguarding and has responsibility for providing leadership and gaining assurance in relation to safeguarding issues within the Trust.

Procurement and supply chains

Frimley Health NHS Foundation Trust is committed to acting ethically and ensuring transparency in all business dealings. The Trust has effective systems and controls in place to safeguard against any form of modern slavery. The Trust’s approach to procurement and the management of our supply chains includes:

  • The Trust’s Procurement Policy requires purchases to be made in line with the Modern Slavery Act 2015 and the Government’s Procurement Policy Note (April 23), which provides guidance on tackling modern slavery within government supply chains.
  • The Trust’s suppliers must ensure their goods, materials and labour-related supply chains fully comply with the Modern Slavery Act 2015 and are transparent, accountable, and auditable.
  • Where possible Frimley Health NHS Foundation Trust adopts the NHS standard contracts for goods and services, which are governed by NHS Standard Terms and Conditions. These conditions include significant requirements in relation to modern slavery, with appropriate remedies in place for breaches for those conditions.

The Trust recognises that certain categories of spend are more likely to have modern slavery within their supply chains. During 2024 the Trust will be carrying out a specific review on our electronics supply chains, to identify any specific modern slavery risks and associated mitigations.

The Trust’s Procurement staff will be undergoing specific training on tackling modern slavery during 2024.

Policies, processes and training

The Trust has the following mechanisms in place to identify and mitigate the risks of modern slavery and human trafficking within the organisation:

Employment/recruitment

  • The Trust adheres to national NHS employment checks and standards for both substantive and temporary staff, including the right to work in the UK, employment clearance, immigration and identity checks. The Trust complies with national pay, terms and conditions of service.

Freedom to Speak Up

  • The Trust encourages raising and reporting of concerns and the protection of whistle-blowers.
  • The Trust has two Freedom to Speak Up Guardians who provide outreach to staff across the Trust, offering support to individuals or to teams who wish to raise a concern. The role of the Freedom to Speak Up Guardian is discussed during corporate induction, which is mandatory for all incoming staff. All staff are also required to complete mandatory Freedom to Speak Up training.
  • The Trust has a ‘Raising Concerns at work’ in place, which can be accessed by all staff, and provides guidance and signposting to raise and escalate concerns.

Safeguarding

  • The Trust employs a Head of Safeguarding and Named Nurses for safeguarding for both children and adults plus Named Midwives for Safeguarding, to ensure the Trust is complaint with the requirements of the Act.
  • ‘Safeguarding adult’ and ‘Safeguarding Children’ polices are in place and can be accessed by all staff. The Trust is committed to the principles setup in our safeguarding policies. The policies provide guidance so that Trust staff are able to raise safeguarding concerns and appropriate signposting for cases of potential modern-day slavery and human trafficking.
  • Safeguarding training is mandatory for all colleagues and includes information on trafficking and modern-day slavery. The training raises awareness and ensures that all staff are fully aware of the steps to raise and escalate a safeguarding concern.

Future plans

Frimley Health NHS Foundation Trust is a learning organisation and will continue to raise awareness of modern slavery both internally and with suppliers as part of the procurement process. The Trust is also considering the appointment of an external provider to undertake an audit of the organisations supply chain, particularly for digital services.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year ending 31 March 2024.

This statement was approved by the Board on 1 March 2024.

Neil Dardis, Chief Executive

Frimley Health NHS Foundation Trust