Modern Slavery Statement

Modern slavery refers to situations of exploitation that a person cannot leave due to coercion, use of force, abuse of vulnerability, deception or other means. It is the illegal exploitation of people for personal or commercial gain and is a violation of fundamental human rights. Modern slavery is an umbrella term that encompasses a wide spectrum of crime, including:

• Slavery

Ownership of another person as personal property.

• Servitude

Complete control over a person short of owning them.

• Forced and compulsory labour

Work performed involuntarily due to the threat of punishment.

• Child labour

Illegal or exploitative work performed by a child.

• Human trafficking

Movement of people without their consent for the purpose of exploiting them.

• Bonded labour

Forced work to repay a debt

Great Ormond Street Hospital for Children NHS Foundation Trust (GOSH) supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS has to play in both combatting it and supporting victims. Any identified concerns regarding Modern Slavery and Human Trafficking are escalated as part of the organisational safeguarding process. All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to Great Ormond St Hospital for Children NHS Foundation Trust.

GOSH’s procurement and contract management activity is delivered through our internal governance arrangements and processes to ensure we buy goods and services responsibly and in line with applicable law and NHS requirements. We work with a range of suppliers and, where relevant, use NHS collaborative procurement routes and frameworks to support ethical and sustainable procurement.

Great Ormond Street Hospital for Children NHS Foundation Trust (GOSH) is a specialist children’s hospital and research centre. We provide services for children and young people and work with partner organisations across the NHS, academia and the voluntary sector. GOSH is a public body for the purposes of delivering health services in England and procures a wide range of goods and services to support patient care and organisational operations, including (but not limited to) medical devices and consumables, pharmaceuticals and laboratory supplies, facilities management, estates work, catering, cleaning, security, temporary staffing and IT services.

GOSH is committed to preventing modern slavery and human trafficking in our organisation and supply chains. We take a zero-tolerance approach to any form of exploitation and expect the same standards from the organisations we buy from.

Our approach is supported through our safeguarding arrangements and through procurement and contract management controls, including relevant procurement policies and procedures; supplier and contract management processes; the requirement for suppliers to comply with applicable law (including the Modern Slavery Act 2015); and mechanisms for staff and suppliers to raise concerns (including Freedom to Speak Up and whistleblowing routes).

The Trust believes that every member of staff has a duty to raise concerns and promotes a number of ways in which this can be achieved - by the incident reporting system, talking to their line manager, speaking to the Freedom to Speak Up team or by following the Trust’s whistleblowing policy and procedures.

In addition, professionally registered staff have duties imposed upon them to raise such concerns by their respective professional regulatory bodies, such as the General Medical Council (GMC), Nursing and Midwifery Council (NMC), and Association of Allied Professionals (AoAP).

The Trust has also implemented the ‘Speaking up’ programme to encourage staff to raise their concerns

Our procurement activity is risk-based and focuses on identifying and addressing the risk of modern slavery and human trafficking across the commercial lifecycle, from planning and sourcing through to contract award and contract management.

We seek to understand modern slavery risk in the categories we buy, including known higher-risk goods and services and higher-risk geographies and labour models. We use supplier engagement and available intelligence (including information provided via NHS frameworks and NHS Supply Chain arrangements where relevant) to inform a proportionate response.

We expect our suppliers to comply with applicable law and to have appropriate policies and controls to prevent modern slavery. Where appropriate, contracts include requirements relating to ethical employment practices, transparency and cooperation (including responding to due diligence queries and addressing identified risks), and the flow-down of relevant expectations to subcontractors and upstream suppliers.

We monitor supplier performance through contract management and respond to any indications of modern slavery risk. Where concerns are identified, we will work with suppliers to agree time-bound corrective actions where appropriate. Where risks cannot be adequately mitigated, we will escalate within our governance arrangements and consider proportionate commercial actions, including suspension or termination in line with contractual rights and relevant NHS guidance.

In line with NHS England guidance on tackling modern slavery in NHS procurement, we recognise there is no such thing as “no risk” and we take a proportionate approach to due diligence. Our procurement activity seeks to identify the likelihood and severity of modern slavery risk in the relevant supply chain and to take reasonable steps, proportionate to the level of risk, to prevent, mitigate and respond to that risk.

• Low risk: standard procurement and contract management controls, including supplier declarations and appropriate contractual terms.
• Medium risk: enhanced due diligence, which may include targeted supplier questionnaires, review of supplier policies and processes, and specific contract management checks.
• High risk: additional reasonable steps to understand and address risk (for example deeper engagement with the supplier, requesting evidence of supply chain mapping and worker protections, agreeing corrective action plans, and increased monitoring), alongside escalation through our governance arrangements where appropriate.

We work, where relevant, with NHS Supply Chain and other NHS collaborative procurement routes to use available tools, supplier standards and intelligence to inform our approach. Any concerns identified through procurement activity are escalated through appropriate routes (including procurement governance and safeguarding processes where relevant) and managed in line with our commitment to support victims and prevent further harm.

We will continue to strengthen our approach by monitoring activity and outcomes, such as completion of modern slavery-related due diligence where required, supplier engagement and any corrective action plans agreed, and the completion of relevant staff training.

Advice and training about modern slavery and human trafficking is available to staff through safeguarding children and adults training and supporting policies and procedures.

Procurement and contract management colleagues also access role-appropriate guidance and training to help them identify and respond to modern slavery risks within supply chains and to escalate concerns appropriately.

Any concerns about Modern Slavery are taken seriously and managed sensitively, and support is provided. This includes referring to external agencies, where appropriate.

This statement has been approved by the Chief Nurse who chairs the Strategic Safeguarding Committee. The statement will be reviewed and updated annually to reflect changes in risk, guidance and our approach to due diligence within procurement and supply chains.

1. NHS England (n.d.) Tackling modern slavery in NHS procurement. Available at: https://www.england.nhs.uk/long-read/tackling-modern-slavery-in-nhs-procurement/