## Uk Modern Slavery Act Transparency In Supply Chains: Reporting By Local Authorities

 
Research Series Report No. 4. September 2020 

Olga Martin-Ortega and Anna Gorna 
with  
Lucrezia Corradi and Fatimazahra Dehbi 
 


## Contents

Introduction ........................................................................................................................... 1 Mandatory (Formal) Requirements........................................................................................ 3 
1. Unfinished Statements................................................................................................... 4 2. Accessibility 
................................................................................................................... 4 
3. Annual Review .............................................................................................................. 5 4. Confusion Over Financial Years .................................................................................... 6 5. Historical Record ........................................................................................................... 6 6. Responsibility for Drafting and Owning the Statement ................................................... 6 
7. Signatures ..................................................................................................................... 7 
Substantive Content 
.............................................................................................................. 8 
1. The organisation's structure, t's business and its supply chain ...................................... 8 2. Organisational Policies .................................................................................................. 9 3. Due diligence, risk assessment and response, including effectiveness 
........................ 10 
a) 
Assessment and prioritisation of risks ................................................................... 11 
b) 
Engaging with suppliers ........................................................................................ 13 
c) 
Monitoring and remediation of human rights violations 
.......................................... 15 
d) 
Collaboration 
......................................................................................................... 16 
e) 
Measurement of effectiveness .............................................................................. 18 
4. Training on modern slavery and human trafficking 
....................................................... 19 
Conclusions ........................................................................................................................ 21 About the Authors ............................................................................................................... 23 BHRE Resources for Public Buyers .................................................................................... 24 Annex I: Modern Slavery Statements: Council Submission ................................................. 25 Annex II: Transparency in Supply Chains Reporting: Aide Memoire (Updated 2020) .......... 28 Endnotes 
............................................................................................................................. 32 

As it is well known by now, the TISC 

## Introduction

provision of the MSA requires commercial This is a fourth report in the BHRE 
entities to annually report on all actions Research Series, and the second to taken to identify, prevent and mitigate address transparency reporting by local modern slavery in their supply chains. The authorities on their efforts to combat aim of the provision is to encourage modern slavery and human trafficking in commercial entities to investigate their their supply chains. The first research supply chain and the effects of their report, UK 
Modern Slavery Act activities upon others, and to communicate Transparency in Supply Chains: Reporting this knowledge internally and externally. 

by Local Authorities,1 qualitatively analysed Only commercial entities with a total annual statements produced by local authorities turnover over £36 million have been since the Transparency in Supply Chains required to publish their annual Slavery and Provision (TISC) of the UK Modern Slavery Human Trafficking Statement 
(the Act (2015) (Section 54), entered into force Statement). In principle, local authorities do on 29th October 2015. Our first research not fall within the category of entities report on local authorities covered the obliged to report under the MSA. 

reporting periods corresponding to two Nevertheless, local authorities have financial years: 2015/2016 and 2016/2017. 

demonstrated ethical leadership by The current report analyses the efforts of voluntarily publishing statements, as our local authorities to respond to the new first research report showed. This will all responsibilities towards their supply chain change soon when the government and their progress in transparency the past implements its commitments following its years. This research report covers the MSA 
response to the transparency in supply reporting periods corresponding to the chain consultation in September 2020. On financial years 2017/2018, 2018/2019 and, 
22nd September the UK Home Office the most recent, 2019/2020. The number of announced that the government is Councils which have published a modern introducing new measures to strengthen slavery statement (or at least attempted to) 
the MSA by, among others, requiring public has increased exponentially in these years bodies which have a budget of £36 million 
- with 132 local authorities identified as or more, including local authorities in having some form of statement out of 404 
England and Wales, to regularly report on in the entirety of the UK, whether individual the steps they have taken to prevent or jointly written. i modern slavery in their supply chains.ii  
Since BHRE's first research report on local and increase their efforts to map supply authorities there has been significant chains and develop MS due diligence.   
developments both in private and public Our first BHRE research report on local sectors with regards to transparency in authorities focused in the detailed analysis supply chain initiatives and modern slavery of the 35 statements published by the reporting. Particularly in the public sector, deadline for publication of the second where more public institutions are taking financial year. At the time of writing, as their responsibilities to purchase mentioned 132 local authorities have been responsibly and not contribute to human identified as having published statements exploitation seriously. The UK Government for this financial year. This second BHRE 
produced its first Modern Slavery local authorities' research report instead Statement in May 2020 and we have seen focuses on the trends in quality and overall a significant increase in reporting among progress since the last report, rather than other public sector entities. 2 Equally, more changes occurring on annual basis. This is local authorities across the UK have why distinctions between reporting years produced MS statements, as this report are no longer explicitly and continuously analyses.  
pointed out in this report. Governmental The Local Government Association (LGA) 
changes to the composition of councils in has led this process of engagement of local the past years has also resulted in a authorities with their own supply chains in merging and reduction in number of local order to identify, prevent and mitigate authorities, which would make it difficult for modern slavery. The LGA has developed a us to exclusively compare annual reports.iii  
comprehensive portal on Modern Slavery As this report highlights, local authorities in Supply Chain- Council Transparency have made impressive progress in Statements on their website and has assuming their responsibility to combat on produced, among other important modern slavery in their supply chains and resources, a Councillor Guide to Tackling be transparent about it. This is not an easy Modern Slavery and a Transparency in task, especially during a time in which Supply Chains Statements Aide Memoire resources are scarce and there are many 
(with the authors, Olga Martin-Ortega and competing priorities when considering Anna Gorna). They, too, continue to review more sustainable and responsible ways to and publish their own Statement annually, procure goods and services. 

Local authorities continue to lead the public This second Research Report reflects sector, together with universities, in generally on the quality of statements, committing and developing tools to analyses compliance with the formal prevent, identify and mitigate human rights requirements of the law and analyses the abuses in their supply chains. This substantive content local authorities research report aims to underline local disclose in their statements to highlight authorities' experiences, as communicated good practice and point out where we think in their statements, focusing on best changes are needed.   
practices and identifying developments in In Annex I we have included an updated order to encourage continued improvement Aide Memoire to support local authorities in for the coming years in which many their sustained journey towards being part councils will not only have an ethical but a of the solution to modern slavery in supply legal responsibility to produce their MS 
chains, rather than one more element in the statements.  
long chain that perpetuates the abuse of Whilst the first two years of reporting on those who produce the products they transparency in supply chains purchase and provide the services they demonstrated a great effort by local contract.  
authorities to come to terms with new 

responsibilities and procedures, we should 

## Mandatory (Formal)

alert against this becoming a routine tickbox exercise. Some of the practices we 

## Requirements

have recorded in our analysis of the reports corresponding to financial years It is mandatory for entities to publish their 
2017/2018, 2018/2019 and 2019/2020 are MS statement on their website with a link in certainly underwhelming. However, there a prominent place on their homepage or in are still recurring issues with the quality and a relevant and obvious dropdown menu. 

finish of MS statements produced by local Statements must also be approved at the authorities. These issues appear to be highest level of governance of the consistent in both the private and public institution and signed by one of the most sectors, however, we are calling on local senior members of the organisation. As in authorities to continue their efforts to learn previous years, many Councils still fall and build their experience to overcome short when following these formal them. In some cases, it is simple mistakes requirements. 

that take away from the message and 
 
integrity of the statement, and create an impression of little attention being given.  
as analysed below, it is difficult to check 

## 1. Unfinished Statements

whether this is because of an oversight In our review of the past three years we during the drafting processes or because found a number of statements which read the Council has merely republished the as unfinished drafts; 
a 
'delete as previous' year statement whilst announcing appropriate' exercise. In some cases, it was a new one (see historical record Councils chose to upload statements in the section below for further discussion).vi    
drafting or approval phases, and given that 
 
it can take a long time to gather full approval, it can be seen as an attempt to 

## 2. Accessibility

further transparency. However, not only According to s.54, statements ought to be does it not give a good impression to have easily accessible on the webpages of the unfinished drafts available, it may confuse reporting organisations. Yet, very few residents, suppliers and the general public Councils maintain the statement on their as to the level of commitment and the homepage. Reiterating the reasoning from extent of progress. We have encountered our first Research Report, local authorities several published draftsiv and one are reminded that they have to ensure that statement in particular contained an the statement is easily accessible not only unfinished final paragraph, giving the for government officials or academics but option of "[will be/have been]",v which also for the members of the public. 

leaves the statement lacking in authority. 

 
This example also suggests the potential use of a template. In previous BHRE 

## S.54(5) Msa 2015:

reports we have discouraged the use of 

"… include a link to the slavery and human 
templates, and we continue to do so. The 

trafficking statement in a prominent place 
use of templates has certain merits, for 

on that website's homepage." [Emphasis 
example can make comparisons between 

added.] 
statements easier, however, we consider 

 
 
that adhering to a preestablished form does not allow for the reflection on own The majority of the statements collated processes and practices that is needed if during the research process were identified the exercise of identifying, preventing and either via the search function inbuilt on the mitigating modern slavery risks in supply Councils' websites, or by using the Google chains is going to be a substantive one.  
search engine. As in the earlier years of reporting, statements were also included in Statements need to be published annually the "About us" section, or the Council on the financial year which has ended. 

Decisions/Meetings sections of the When a statement contains the wrong date, websites. In cases where statements could for another year. This is inadequate in light not be located, we referred to the TISC 
of the requirements of s.54 which indicates Report database as a last resort - 
that a statement is primarily intended to surprisingly, several statements were only show the steps undertaken by an found there.  
organisation during the financial year to ensure that trafficking is not taking place in It is a testament to how difficult a statement its own business and its supply chains.  
may be to find where it is far easier to search using a search engine, than by 

accessing Council websites directly. In 

## Modern Slavery Act (2015)

several cases we could only find Section 54(4): A slavery and human statements as part of minutes of Council trafficking statement for a financial year is— 
meetings or buried away in sections of local 
(a) 
a statement of the steps the authorities' websites.vii This not only organisation has taken during the financial contravenes the requirements of the MSA 
year to ensure that slavery and human and Home Office Transparency in Supply trafficking is not taking place— 
Chains Guidance (hereinafter government 

(i) in any of its supply chains, and 
Guidance), which are clear in establishing a mandatory requirement of publication in 

(ii) in any part of its own business, or 
a visible place on the home page of the 

(b) a statement that the organisation has 
website, but also defeats the purpose of the 

taken no such steps. 
reporting exercise. 

Transparency is 

[Emphasis added] 
 
essential for all stakeholders involved in the Whilst not all sections of a statement in combatting of modern slavery. Local relation to its substantive content need to authorities are accountable to their be rewritten every year if there have been constituents, and if these cannot access no changes in the organisation's structure, such a key document, Councils are failing business or policies, they ought to describe in their transparency responsibilities.viii As actions undertaken in the past year and we advised in our first Research Report, reflect on their effect. Where no such steps the best place to link a statement is on the have been undertaken in a financial year, bottom of the homepage. This is in fact this fact ought to be adequately stated in directly prescribed by s.54(7)(b). 

the statement instead, as per s.54(4)(b).  
 
If those in charge of drafting the modern 

## 3. Annual Review

slavery statement find the entirety of it unchanged, the local authority needs to It has been observed that some Councils reflect on whether there have not been any have limited the review of their statements new steps undertaken in the past year or to replacing dates and indicating it is valid whether there are not enough adequate Statements published for a financial year procedures to record such steps. Perhaps, that has not ended cannot reflect on and the statement is not detailed enough and is asses the measures undertaken during that not able to reflect the actions that have, in specific year. For clarity in reporting fact, been developed or are planned. If practices Councils are encouraged to there really has been no change and no carefully review they are reflecting the right action taken, then the statement should dates.  
reflect this, and the Council should 

consider what needs to change in the 

## 5. Historical Record

coming years.    
Most reporting entities tend to replace old Statements must be reviewed annually. 

statements when they publish the new one. 

Yet, a number of councils have failed to However, we suggest that local authorities update their statements from 2018/2019, maintain a historical record of their past 
2017/18, or even from the first reporting statements on their website to facilitate period of 2015/2016. Few local authorities comparisons and reflections on the even indicated 'review by dates' which progress they have made. Only few have clearly not been met.ix  
Councils maintain all their previous 
 
statements, such as Nottingham City 

## 4. Confusion Over Financial Years

Council, Derbyshire County Council and Sunderland City Council. This is a good As it is clear by now, statements should practice which increases transparency and report on actions taken during the past shows local authorities are not avoiding financial year and must be produced public scrutiny. xi  
annually. Statements should not cover more than one financial year at the time, as 

they are not intended as a 'strategy' or 

## 6. Responsibility For Drafting And

intentions statement but a 'reflection' on 

## Owning The Statement

undertaken activities.  
Ideally, a statement would be written Statements are to be retrospective and are collaboratively by representatives from to discuss activities undertaken in the different departments. A holistic statement financial year on which they are reporting. 

that shows understanding of the systems in Thus, the 2019/2020 statement should place can only be achieved through a have been published as this financial year collaboration among different actors, came to a close. At the time of writing, including HR, legal, safeguarding, however, some Councils have already procurement staff, etc.  
published the 2020/2021 statements.x The City of London Council, for instance, Still, no guidance has been published as to has an interdepartmental Working Group whom is the appropriate person to sign a which includes: City of London Police, the Council statement. We maintain our earlier Barbican, City Procurement, Department suggestion that ideally the statement would for Community and Children's Services, be co-signed by the Leader of the Council Community Safety and Corporate Strategy and the Chief Executive, or equivalent and Performance Team. The Council position, such as the Chief Operating indicates that it will invite representatives Officer. A Director or a senior enough from other relevant departments, such as Portfolio Holder, for example a cabinet HR and Licensing, moving forward.xii  
member councillor, could also be considered a relevant person, especially in Statements should generally be authored smaller district councils. In any event, the by the Councils themselves. The purpose approval process has to demonstrate that being that members and employees of a the statement has been discussed and Council know its business, supply chains approved at the highest level of and activities best. We do not think governance of the institution and reflects delegating the writing process to an an overall commitment from those in external organisation is a good practice.xiii  
positions of authority. The rationale being A MS Statement is to be written by the that modern slavery awareness and the Council about the Council. Equally, a s.54 
commitment to combat abuse remain at the statement by public authorities should core of each organisation. 

consider their activities as a public body rather than just focusing on their private Signed statements continue to display the commercial activities.xiv signatures of the Chief Executive and/or Leader of the Council and Portfolio Holder 

(of various departments, such as 

## 7. Signatures

Communities, HR or Equalities). Due to the Statements analysed in this report continue unique structure of the City of London, a to lack appropriate signatures. Given the signature from a Town Clerk, a deceptively likely robust approval process carried out insignificant sounding title which is in reality by Councils before a statement is a central position combined with the published, the lack of a signature makes it position of the Chief Executive, of course fall short of the expectations established by satisfies the requirement. Conversely, a the MSA, which is especially unfortunate signature from a Town Solicitor may not be where a statement is overall highly detailed adequate.xv Local authorities should and fulfils other expectations. A signature always contemplate if the person signing elevates the authenticity of a statement and the statement is truly representative of the approves the details contained therein. 

Council as a whole. 

Some unchanged, unsigned statements 

still state that they have been approved without specifying by whom, while others 

## Modern Slavery Act (2015)

indicate that this approval has been granted by the Broad, the Council itself, a Section 54(5): An organisation's slavery and human trafficking statement may include information about— 
specific post holder or by the Management Team without providing any names. Or, 
(a)the organisation's structure, its business and its supply chains; 
conversely, a statement is signed by a named person without providing their 
(b)its policies in relation to slavery and human trafficking; 
post.xvi We recommend that the post and the name of the approving person are 
(c)its due diligence processes in relation to slavery and human trafficking in its business and supply chains; 
present in the statement in order to not only follow best practice, but also clearly send a message of commitment to transparency and accountability. 

(d)the parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk; 

## Substantive Content

(e)its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate; 
Section 54(5) provides a non-exhaustive list of information that may be included in 
(f)the training about slavery and human trafficking available to its staff. 

statements. As in our previous Research Report for our analysis we have grouped 

 
some of these criteria and present our findings under following headings: 

1. The organisation's structure, t's 
1. The 
organization's 
structure, 
its 
business and its supply chain  
business and its supply chain;   
Most Councils describe their jurisdiction 

2. Organisational policies;   
and population, and on too many occasions 

3. Due diligence, risk assessment and 
provide information which is not of 

response, including effectiveness of 
particular relevance to the section. Others, 

such response; and   
fail to provide any significant information at 

4. Training on modern slavery and human 
all, as we highlighted in our previous 

trafficking  
Research Report. But there are also 

 
examples of good practice, such as East Lindsey District Council, which continued to include of a detailed breakdown of the Council's organisational structure. 

Its statement specifically highlights positions The government Guidance suggests within the Council structure and focusing on 
"sector(s) 
the business operates in" or relationships with suppliers responsibilities of the post holders on the different aspects of the modern slavery and others, including trade unions and other bodies representing workers". Most statement production and modern slavery monitoring.xvii   
importantly, Councils should address in their statements the following: "the make-
East Riding of Yorkshire Council has up and complexity of the supply chains" 
broken down their approximate £270m and "the countries it sources its goods or annual spend on the services they services from including high risk countries provide.xviii This is a good start, and the where modern forms of slavery are information provided is useful. This may be prevalent". Improving our understanding of further enhanced by focusing on supply chains and risk areas is essential, procurement spend and looking at services and without a strong base of knowledge on and goods that are most prominent. This is what we buy and where it comes from it is a first step into mapping supply chains and very difficult to proceed to assessing risks assessing risk, as discussed further in the and determining what needs to be done to due diligence section below.    
respond to them.  
Good knowledge and an understanding of Too many Councils continue to declare that supply chains and the structure of supply chains are local and imply that commercial relations in terms of suppliers, having UK based suppliers is somehow contractors and subcontractors remains a equivalent to having no modern slavery fundamental part of effective reporting. As risks. All supply chains are interconnected is the ability to trace the origin of products, in a way or another, and even if we materials and services purchased. In the purchase as local as possible, we know case of local authorities this allows for that UK supply chains are not free of abuse. 

understanding of the level of risks within This is why all organisations need to each of the sectors from which they develop policies, processes and procure products or provide the services mechanisms to address the risks of contracted. The government Guidance violations and assume their responsibility highlights that a greater level of detail when for their own role in the supply chain.  
reporting on the organisation's structure, business and supply chain is likely to be 

more helpful. However, too much technical 

## 2. Organisational Policies

or legal information should be avoided, for Reporting on policies remains the same as the statement should remain accessible to in the previous years. The same policies the public.   
are mentioned across all statements, including Anti-Slavery Policies, found in one case, reproducing s.54 into Recruitment Policies, Whistleblowing the statement, as the only content, Policies, Equality and Diversity Policies, accompanied with a signature, is not an adequate representation of any Council's Employee Codes of Conduct, Safeguarding Policies and Procurement efforts against modern slavery.xix   
Strategies. This section of the statement is Many Councils report having signed to the one of the sections which needs less recent Cooperative Party's Charter Against updating during the annual review unless Modern Slavery. The list can be found on new policies have been approved or the  Cooperative Party's website. This is a updated during the year.  
third-party initiative. The Charter contains a As the government Guidance suggests, series of commitments that the signatories organisations need not have a standalone fulfil and uphold. The impact of adhering to policy in place - but may develop one or the Charter and action on its commitments explain how current policies and practices will be apparent in the coming years. Whilst are relevant to the cause.  Most Councils good practice, Councils are encouraged to still don't have specific modern slavery not treat this as an end goal, and still focus policies and even if statements tend to on having robust policies and strategies contain long lists of policies, reporting and publish serious and sound statements authorities still fail to link the relevance of which contain evidence of their activities those to combatting modern slavery and implementing either this Charter or any human trafficking. 

Councils should other public commitments which they have consider expanding in this section on how adhered to. Commitments without action policies are implemented, or, where it was will not be sufficient. A good start has been indicated that policies were to be reviewed, conducted by Sunderland Council, for how that was done and what conclusions instance, which has already set out a were reached. As s.54 suggests that detailed table of actions and progress in companies may report on ''b) […] policies implementing the Charter.xx in relation to slavery and human 
 
trafficking'', Councils should make a 

## 3. Due Diligence, Risk Assessment

conscious effort to include how their policies are linked to modern slavery 

and 
response, 
including 
prevention.  

effectiveness  
Making generalised commitments against Due diligence processes inherently require slavery, and proclaiming rejection over an ongoing assessment of modern-slavery abusive practices in general is not within risks, their monitoring, engagement with the letter and spirit of s. 54 MSA. As we the relevant actors to address both the risks and the actual instances of violations This section analyses how local authorities identified, and putting in place measures to have reported on their efforts to exercise prevent the risks from materialising, due diligence to mitigate and prevent mitigating them and remediating the actual instances of modern slavery and human violations and abuses when they do trafficking by addressing the following occur.   
elements:   
In our first Research Report, we highlighted 

a) Assessment and prioritisation of 
how Councils were only just beginning to 

risks;   
learn how to approach writing a MS 

b) Engaging with suppliers;   
statement and developing their 

c) Remediation 
of 
human 
rights 
understanding of what modern slavery 

violations;   
was, what due diligence measures could 

d) Partnerships and collaborations; 
be instilled, and what risks existed within 

and   
supply chains. All reporting organisations 

e) Measurement of effectiveness.   
and those assessing statements too were 

  
faced with a fast-developing area. In the 

a) Assessment and prioritisation 
five years since MSA entered into force, 

of risks    
standards have risen, as has an awareness of the wide range of due diligence The first step within the due diligence measures needed to ensure MS risk are process is to identify potential risks within identified and mitigated. We now expect the supply chain and prioritise action over local authorities to have kept up with these them. 

Risks should be considered developments.  
according to country risks, sector risks, Statements need to reflect a thorough transaction risks and business partnership understanding of the organisation's risks. Little details are provided in Council operations (as described above) and how statements to the processes local due diligence can be carried out within that authorities use to assess modern slavery framework. With the information and risks and prioritise which ones should be knowledge readily available, Councils are addressed first.   
encouraged to reach for it and utilise it.  In Dedicating time to learning of high-risk order to demonstrate that organisations areas within the UK and outside of the UK 
have strong due diligence processes in 
(which may appear down the supply chain), place they need to provide specific will place Councils in a better position for examples of actions undertaken or developing effective due diligence. A good decisions made.  
understanding of geographical and sector risks is essential to identify such risks in supply chains. 

Only then will local which sectors are more exposed to authorities be able to create and develop leverage, for examples those that depend effective due diligence procedures to directly of their relationship with the address modern slavery. All Councils Council, such as adult social care or children's services, and which would should have by now made efforts to understand the risks faced by public require a much longer-term strategy to buyers, and have a better awareness of the impact.  
risk they face in their own supply chains.  
Examples of Councils that report on efforts Councils indicating one or two areas where to assess risks are very encouraging. In its risks have been identified is welcome draft MS statement, Lewisham Borough progress. Conversely, merely stating that a Council highlights ICT hardware, a known risk assessment had been carried out, risk area, as a concern within their supply without indicating the process or chain.xxii The Council then lists a series of conclusions reached, is not sufficient.xxi mitigating measures regarding use of shared services and joint procurement As has been pointed out before, merely agreements. It too makes reference to stating that the Council operates within the signing of the Cooperative Party Charter UK or has only local or UK based suppliers, against Modern Slavery, discussed above.  
is not a satisfactory assessment of risks. UK operations are not risk free, modern The City of London sets out a clear picture slavery is all around us and understanding of high-risk areas in its statement.xxiii It how to spot these invisible abuses is part of further describes how those risks are the due diligence measures that need to be monitored and mitigated. Cited measures taken.  
reflect good practice. They range from meeting a corporate responsibility code for It is unlikely that local authorities will be textile suppliers (for the City of London able to map all supply chains and identify police, led by Metropolitan Police); 
all risks at once as they continue to be requiring construction contractors to faced with the pressing challenge of present their due diligence procedures and managing diminishing resources to developing a mutual action plan; to the address increasing local needs. This is why most robust one of all - the requirement prioritisation is key. Councils should focus that contractors for contracts involving on the risks which they can address faster electrical equipment produce a map of their and most effectively by engaging with supply chain. The City's IT managed suppliers and collaborating with other service provider is also, according to the councils or external organisations to statement, mapping the supply chain on IT 
maximise resources and capabilities. 

Equally, decisions need to be taken as to hardware used to support the services their MSA 2015 obligations is a good delivered by the City. 

practice, and sends a powerful message of commitment by local authorities, it is 

important to remember that this kind of self-
City of London Statement 2018/2019: 
certification has its limitations. The SSQ does not allow to compile detailed enough 
61.The highest risks of people falling victim to information to ensure that abuses are not modern slavery in our UK-based supply chain 

include 
           construction 
                            workers, 
                                         those 

present in supply chains, or whether 

undertaking service contracts in relatively low 

suppliers are themselves exercising due 

paid industries such as cleaning, catering, 

diligence in their own supply chains.  

security, agriculture and the care industry. 

The SSQ operates on a on the basis of self-

Although not necessarily defined in the same 

certification. As in previous years, Councils 

way, the City Corporation recognises that 

continue to request that suppliers selfthose industries that operate as part of the gig 

certify that no modern slavery is taking 

economy  

place in their supply chains. Overall, it is a 

62.The highest risks of modern slavery further 

low effort due diligence measure, and as 

up our globalised supply chain, especially 

emphasised in or first Research Report, it 

forced and child labour, are associated with the production and manufacture of electronic 

is likely to be ineffective due to the lack of 

equipment, textiles, agricultural commodities 

proper checks and monitoring. Moreover, if 

and construction materials. Conflict minerals 

questions to suppliers are limited to 

including gold, tin, tantalum and tungsten, 

whether they comply with their MSA s.54 

found in computer equipment and vehicles are 

obligations, smaller businesses will not be 

also of significant concern. 

questioned on their efforts to combat modern slavery as they do not meet the 

£36 million reporting threshold.  

City of London Council again shows good 

## B) Engaging With Suppliers

practice relating to small and medium This section looks at various due diligence enterprises (SMEs). The Council is a measures adopted by local authorities and founder of the 'Heart of the City', a ways in which they engage their suppliers.  
business-led charity which runs a responsible business programme designed There is a noticeable increase in the use of for SMEs. 

The Council's statement the Standard Selection Questionnaire describes the aims of the programme as 
(SSQ) provided by the Crown Commercial intending to coach business leaders on Service, or at least some variation thereof. 

how to make a positive difference and Whilst using questionnaires to gather supporting those businesses in tackling information on supplier's compliance with complex issues, such as modern slavery. 

legality and welfare of those working for the This appears to be an innovative approach council, directly through employment or that remembers smaller businesses that indirectly through subcontracts or in the would otherwise not engage with modern supply chain, means local authorities are slavery prevention through s.54 
not aware of the working conditions those reporting.xxiv  
who produce goods and provide services for them are facing. Risks are particularly 
 
high when organisations recruit personnel 

## Standard Selection Questionnaire By Ccs

through third party agents and our on-going research into other sectors has highlighted that the recruitment process requires due diligence measures. Councils provide scant descriptions on how employees might be vetted or how third-party recruitment agencies are chosen and monitored.xxvi Our previous Research Report highlighted Further good practice is demonstrated by and encouraged the use of contract Neath Port Talbot, which is one of few clauses to establish legal responsibilities Councils that indicates it will require for suppliers and rights for Councils suppliers to explain abnormally low tender regarding engaging to identify, prevent and quotes, and to explain their impacts on mitigate modern slavery. In the statements workers. 

This aims to ensure that analysed for this report, we are pleased to employment is both considered during the see local authorities reporting on the use of procurement process, and that the Council such contract clauses. Basingstoke and does not contribute to unethical Deane Council states that it may impose employment.xxv  
specialist safeguarding clauses in Local authorities' statements tend to focus contracts where it is deemed relevant.xxvii on recruitment processes when describing Essex County Council reports, as in due diligence. Several Councils have previous years, that standard contract indicated a commitment to ensure that their terms have been incorporated with clauses employees are vetted and that appropriate on supplier's obligations regarding modern employment checks are carried out. These slavery. It would have been an example of checks are of course important, but best practice to further clarify the phrasing exclusive focus on direct employees leaves of said clauses.xxviii Flintshire County many individuals out of the risk assessment Council statements says that a review of process. Limiting efforts to check the terms and conditions will be carried out with the option of including sanctions or a Remedial action includes protecting the termination clause if modern slavery is victim, resolving the violation, and suspected. xxix As we have expressed addressing the perpetrator. Some Councils before, automatic termination of contracts still conflate their responsibilities under is not always the best course of action, s.52 MSA with the requirements and specially to protect victims and those expectations established by s.54 MSA. The vulnerable to abuse. Working with high risk former requires a public authority which suppliers is the only way local authorities has reasonable grounds to believe that a will be able to exercise their leverage and person may be a victim of slavery or human play a part in transforming abusive supply trafficking to notify it. Given the nature of chains and protecting vulnerable workers. 

local authorities' competences there is a persisting focus on safeguarding of 
 
children, vulnerable adults and victims in 

c) Monitoring and remediation 
statements. Yet, whilst those can be included in a modern slavery statement, 

of human rights violations    
section 54 has a specific focus on the Local authorities cannot on their own supply chains. Therefore, a further effort monitor the lower tiers of their supply chain. 

needs to be developed to understand how Organisations such as Electronics Watch, to participate in remediation of violations which some Councils have affiliated to (see further down the supply chain, this is, to below) provide access to independent address the violations which relate to worker-driven monitoring and remediation supply chains and the risks that local for workers who suffer abuse in the authorities' activities pose to those who production of the goods purchased by produce the goods they purchase and public bodies.xxx Electronics Watch provide the services they contract to partners with local organisations, develop their functions. Action plans monitoring partners which are located near referring to remediation of abuse which workers' communities and already have a was exacerbated by procurement from a relationships of trust with workers. This supply chain with modern slavery are allows them to meet workers in conditions lacking. However, this is something which which allow them to report more freely what very few organisations even in the private their real working conditions are and sector have considered as part of their minimise their fear of reprisals. This responsibilities, so Councils cannot be facilitates that workers report problems to faulted for lacking in this area. This is one these local organisations, which they may of weakest elements of the law and one not discuss with social auditors sent in by that requires special attention in the coming brands or retailers, which they may never years. In order to participate in remediation have met before. 

for specific violations, collaboration is, Trafficking Advocates, the Council also again, essential.  
supports victims through their housing and homelessness service. Further support is A number of local authorities, such as provided to the local Police if a victim is Swindon Borough Council, indicate that identified. Croydon Council highlights the any suspected case of modern slavery will support victims can receive through the be reported to a relevant police authority.xxxi NRM process, i.e. safe houses, and legal, This, of course, is an expectation for all psychological and administrative support. 

Councils. 

Whilst protection and law xxxv Wirral Council notes that victim-focus is enforcement agencies are the relevant an important part of anti-modern slavery authorities and the ones that should be activities, especially given the repeat tasked with protecting victims and victimization of vulnerable persons.xxxvi  
providing redress, it is important that local authorities get involved in remediation too. 

 
Here we provide some examples of ways in 

## D) Collaboration

which Councils have considered how to Collaboration between organisations is contribute to redress for the abuse suffered crucial for mitigating and preventing by modern slavery victims. Generally, any modern slavery in supply chains as pledges to remediation are condensed into collaborations and partnerships promote generic commitments for support to knowledge and best practice sharing, and victims. Many Councils rely on the National can also be utilised for a more efficient Referral Mechanism (NRM) which is an resource management. Local authorities identification and support process for are at the forefront of these collaborative victims of trafficking in the UK. Salford City efforts and showcase very important Council is on the right track as it recognises partnerships to address modern slavery, that long term support may be needed, and albeit mostly focused on direct employees considers providing assistance on access and residents of the Council rather than to welfare benefits, housing, health and those in their supply chains. Below we social care, legal advice and highlight both the external collaborations employment.xxxii Likewise, East Riding of and collaborations among local authorities Yorkshire Council's statement refers back which have been reported by local to their Modern Slavery Policy which authorities and suggest some which could commits appropriate support to victims.xxxiii be explored. 

Ceredigion County Council describes the generic step process for victims' 
   
support.xxxiv From referring potential victims to the NRM, notifying the Home Office and referring child victims to Independent Child 

Collaboration 
               with 
                      public 
                              bodies, 

Partnership have jointly written their 

statement. There is also an overarching 

unions and civil society    
aim to coordinate partners to prevent and The main forms of these collaborations report modern slavery, especially in order include those with the police, community to avoid both duplication and oversight. 

and safety partnerships, and non-
The statement indicates that voluntary, governmental organisations. Collaborative community, and faith groups will be work with civil society organisations and engaged in identification, referral and consultants is usually for the purpose of support of MS victims. xxxviii delivering or developing training.  Reaching Sandwell Council chairs the Sandwell Antiout to bodies such as Labour Abuse Slavery Strategic Partnership, which Authority, the Home Office, Trading actually includes procurement employees Standards and the Police is important and as representatives within the expected. However, too many Councils partnerships.xxxix The Council also chairs generally refer to 'partnerships' with such the Sandwell Housing Operational bodies without specific details or include Partnership (SHOP) established by West reference to specific projects or Midlands Police which links agencies agreements in place. 

Therefore, we involved with vulnerable individuals and the encourage them to ensure that the private rented sector housing tenure. It was relevance of the partnership to modern established following the recognition that slavery is described.xxxvii many victims of exploitation are Wirral Community Safety Partnership accommodated within privately rented encompasses the Wirral Council, Police housing.    
Crime Commissioner's Office, Merseyside Notably, many whistleblowing policies Police, Wirral Clinical Commissioning often allow for 'partner' reporting. However, Group, Merseyside Fire and Rescue all remain silent as to who amounts to a Service, National Probation Service, partner in this context. Local authorities are Merseyside Community Rehabilitation encouraged to clarify whether collaboration Company and Merseytravel. It is unclear members and partners could be covered by how involved those organisations are in the those policies.  
partnership and whether they are all of equal standing. The statement does not Several Councils mention their provide further details on how these bodies collaboration with Electronics Watch, an contribute to actions against modern independent monitoring organisation which slavery and what collaborations are taking supports public sector buyers in their place within the partnership. What can be responsible procurement of electronics. 

noted, is that Wirral Council and the Wirral During this financial year two London boroughs have affiliated to Electronics the Derby & Derbyshire Modern Slavery Watch, Lewisham and Tower Hamlets.xl Partnership is made up by Derbyshire Electronics Watch allows local authorities Council and Derby City Council.xliv to maximise their leverage and prevent and Nottingham City Council states that its remediate violations of human and labour 
"Community Protection service is actively rights in the supply chain of the electronics working with other Councils across products they purchase.  
Nottinghamshire to develop a response A surprising absence is the reference to plan should any large-scale occurrence of collaboration with unions. Freedom of modern slavery be discovered within the association is one of the fundamental County, and is working with an external labour rights and the denial of such right is partner to establish a clear support route generally a sign of potential risks of modern for victims of modern slavery within the slavery in supply chains. Public sector region."xlv  
unions are good sources of knowledge and Another collaboration identified was the understanding of the risks in global supply LGSS, which is not discouraged, but as chains and the specific problems in local mentioned above, no partnership should workplaces.xli Engagement with trade write a statement on behalf of a Council, let unions both within the local authority and in alone a single one on behalf of three.  
the supply, chain is essential for due 
 
diligence.xlii They too can provide useful resources such as training.  

e) Measurement 
of 
effectiveness  
 
Councils haven't been successful in Collaboration among local authorities   
strengthening their effectiveness reporting Equally important are collaborations which would have been particularly among local authorities. Those types of expected form Councils that published collaborations can promote increased modern slavery statements over the past scrutiny and regional coordination. 

years. 

The government Guidance Tameside Council is part of the Greaterencourages organisations to report on the Manchester Combined Authority (GMCA) 
effectiveness of their measures by 
(made up of 10 Greater Manchester providing information on existing or Councils); 
the GMCA 
has delivered additional Key Performance Indicators conferences on modern slavery and human 
(KPIs) related to anti-slavery actions. KPIs trafficking to highlight how to prevent abuse should allow for the tracking of progress in and neglect, detect and report incidents short, medium and long term and allow for and provide support to victims.xliii Similarly, substantive measurement of effectiveness of processes and practices. Yet, very few 

2. Employees made aware of Modern 
KPIs are being used. xlvi 

Day Slavery Act 2015 and training provided as identified   
Cardiff Council set out in their 'What the 

3. All employees completed 
Council will do' section in the 2019/2020 

mandatory Safeguarding Training  
statement that they will develop KPIs. The 

4. Number of cases reported on its 
same commitment was maintained in the 

whistleblowing system and 
new 2020/2021 statement, albeit expanded 

resulting action 
upon. The comparison is as follows: 

Cardiff Council  KPIs 

The same KPIs are included in their 
2020/2021 
Draft. 

The Council is 

2019-2020xlvii 
2020-2021xlviii 

encouraged to review this and assess the effectiveness of the KPIs before they 

The number of staff trained 
The number of staff completing 
modern 
slavery training 

publish the 2020/2021 statement officially.  

| A    | review    | of    | the    |
|------|-----------|-------|--------|

As noted in our previous Research Report, 

system for supply chain verification 
Continue development of the process 
for 
the 

Nottingham City Council indicated it was in the process of reviewing their KPI's - both in their 2015/2016 and the 2016/2017 

evaluation of existing suppliers through the formal 
Risk 

statements. However, any mention of KPIs 

Assessment 
process: 
'Tackling 

has been removed from their 2017/2018 

Modern Slavery in Supply Chains' 

and 2018/2019 statements.l 

| Reporting    | on    | the    |
|--------------|-------|--------|

Development of the process 
for 
the 
completion 
of 
evaluation 
of 
supplier 
modern 

## 4. Training On Modern Slavery

| existing suppliers    | slavery    | Self-   |
|-----------------------|------------|---------|

## And Human Trafficking

assessment 
Questionnaire 

 
Training is important for raising awareness, building capacity, but also developing The following are KPIs set out by employees' understanding of the relation Elmbridge Council from the 2018/2019 
between MS and supply chains and the statement:xlix impact of business operations. Training as 

1. All contractors considered for any 

implemented by local authorities often 

opportunities confirming their 
amounts to awareness raising, which 

adherence to Modern Day Slavery 
improves the chances of identifying 

Act (2015)  
potential victims. By focusing solely on signs of modern slavery, however, awareness training is missing the supply chain aspect, and missing an opportunity begun disseminating training to social care for staff to better understand the risks staff in the 2017/2018 period. As the which can be addressed through statement has not been updated, it is engagement with suppliers and public unclear how the training progressed in the procurement decisions. 

2018/2019 and 2019/2020 periods.  
How training is delivered is very important. 

Nottingham City Council committed to 27 
training session for employees and NGO's Disseminating resources is not equivalent to training. Simply rising the matter to between April 2017 and March 2019. It had employees, or bringing the governmental estimated in its statement that it would be website to their attention is not enough. 

disseminated to 823 staff, plus voluntary Neither would be emails on the matter, akin persons. A further 523 staff undertook an to newsletters. Availability of training also e-learning module from November 2018.liii does not necessarily mean it is being used Providing a number of persons who and whether it is mandatory remains a undertook training builds a better picture of question.  
how far it reaches. It would be even more useful if the Council could provide the Cardiff Council, in their 
2020/2021, percentage of all employees who have describe the contents of the training, undertaken the training. This would also including addressing the purchasing advance their effectiveness assessment.  
practices and how those influence supply chain conditions, how to assess the risk of Although Croydon Councils describes that MS, signs of MS, action to be taken to it is working on training being offered to the report concerns, and steps to take if MS is Third Sector this does not fulfil the suspected.li This appears to be a very requirements of this section.liv  The detailed and holistic training. Although, the question is what training is offered to its Council did not reflect on the effects of own employees. 

Perhaps it should training between this statement and their consider working with those nonprevious one - the content concerning governmental non-profit organisations training was identical in both statements.  
instead, as plenty carry knowledge and practical experience on MS.  
Lewisham Council reports to have engaged in Train the Trainer sessions offered by the Councils have to ensure that training ADASS (the Human Trafficking and described in this section is relevant to MS. 

Modern Slavery Multi-Agency Awareness So Equality and Diversity training, unless Raising Train the Trainer by the clearly linked to MS, does not appear Association of Directors of Adult Social relevant. That is why describing the Services in England).lii These who had contents of the training is so important - so undertaken the training have already that readers are able to understand how it 

## Conclusions

contributes to the fight against MS. 

Councils have demonstrated great ethical Furthermore, training needs to be geared leadership by voluntarily choosing to towards specific employees. 

As the publish statements under the transparency government Guidance points out, training in supply chains act. This will no longer be for personnel that may encounter victims voluntary, all local authorities above the personally would be drastically different annual turnover will have to report. Those from the training that would need to be on smaller budgets and turnover should provided to procurement employees. 

continue to do so. Councils as public Noticeably, awareness training may not be bodies should be willing and eager to particularly useful to procurement disseminate their approach and good personnel. Given local authorities' limited practices. Accountability and transparency resources, some may need to prioritise are part of public service.  
which employees are trained first.  
As this report has highlighted there is still a Councils should use this section to answer gap between the detail in the produced questions about the type and content of the statements and the detail expected of training. How is the training dissemination them. Standout statements contain detail 
- in person or as an e-learning module? Is that allows for a picture to be built but it is training mandatory or voluntary? How often clear that some of the Councils could make is the training repeated - on an annual better use of the Government guidance and basis, every few months, every few years? 

other resources produced for Councils on How long is the training? Who is it for? 

modern slavery and public procurement.    
What are the contents? Is it developed by There remains a concern that very few the Council or a third party? 

Councils are writing their own statements. 

Intense activity of training and consultancy Whilst the detail in statements has gone up, in the private sector has been noted, and and whilst it is accepted that many councils which has generally served as an may have similar approaches, it is awareness raising exercise can also, to undeniably clear that identical phrasings, some extent, be an outsourcing of layouts and structures give away the same responsibility to consultants. 

Local origin of the statements.  
authorities should certainly avoid that.  
Councils also continue to display some 
 
naiveté regarding the possibility that 
 
modern slavery is present in their supply chain and that they may at some point in the future be the cause, or at least the exacerbating force, for abuse, trafficking challenge. We are sure they too will rise to and modern slavery. Admitting to the the challenge of keeping the fight against possibility of that happening is not modern slavery in their agenda.  
equivalent to admitting guilt, or even 
 
 
admitting that there are issues. Ignoring a potential problem and refusing to prepare for it, will not make it go away. Without contingency plans and preparation, the fallout from an issue, once it does arise, will be much greater. 

Nevertheless, there has been a massive increase in the number of Councils reporting in general as well as the amount of detail provided in many of the new statements. It is maintained that the level of organisational commitment from local authorities to understand and engage in anti-modern slavery is commendable and so is their willingness to collaborate both with other local authorities and with external parties. It is hoped that Councils will continue developing and improving their due diligence measures in the first instance, and improving their modern slavery statements in the second, now that they will have a legal responsibility to publish such statements. Collaboration among themselves and with external organisations will be key. Modern slavery in supply chains is not an easy issue to address, and Councils have many competing priorities with increasingly reduced resources. COVID-19 has placed local authorities at the forefront of the fight for the lives, health and opportunities of their residents. And they have risen to the 

## About The Authors

Dr. Olga Martin-Ortega is Professor of International Law at the School of Law, University of Greenwich (UK) and leads the BHRE. She has been researching business and human rights for over fifteen years. She has also undertaken extensive research in the areas of post-conflict reconstruction, transitional justice and international criminal law. Professor Martin-Ortega is a member of the Board of Trustees of Electronics Watch and a member of the Board of Directors of the London Universities Purchasing Consortium. She is also a member of the Steering Committee of the International Learning Lab on Procurement and Human Rights and leads its Electronics Hub. She has conducted numerous trainings for public authorities on their legal obligations under the UK Modern Slavery Act and performing human rights due diligence on their supply chain in the framework of the Higher Education Procurement Academy (HEPA). Anna Gorna currently consults the BHRE on projects related to modern slavery reporting, fair recruitment in public procurement and human rights due diligence. She graduated with a degree in Law from the University of Greenwich in 2017, worked as an intern at the BHRE in 2018. In 2019 she worked at LUPC on responsible public procurement and developing the joint LUPC-BHRE project Equiano. She is currently preparing for work at the Bar. Lucrezia Corradi is a Research Assistant at the BHRE. She has worked on modern slavery reporting by public buyers, fair recruitment practices and international labour standards. She graduated from the University of Greenwich in 2018 with a degree in Politics and International Relations. Fatimazahra Dehbi is a Research Assistant at the BHRE. She has worked on modern slavery reporting, business, human rights and the environment, and human rights in the digital age. She graduated from the University of Greenwich in 2019 with a degree in Law.   

## For More Information, Visit Www.Bhre.Org

We acknowledge the support of the Greenwich Work Experience Programme in the development of this research. Special thanks to Guy Head for his invaluable support to our work on the roles and responsibilities of local authorities. All omissions and mistakes remain the authors' responsibility. 

Photo Credit: © Lisa Kristine  
(We are extremely grateful to Lisa Kristine for allowing the use of the cover photo) 

## Bhre Resources For Public Buyers Guidance

- 
Olga Martin-Ortega and Andy Davies (2019), Modern Slavery Statement Checker. Points to check for when reviewing a supplier's modern slavery statement, CIPs Knowledge. 
- 
Olga Martin-Ortega, Anna Gorna and Patrycja Krupinska (2018), Preparing a Slavery and Human Trafficking Statement: Guidance for Higher Education, BHRE Research Series. Policy Paper 6 (BHRE and HEPA), October 2018 (updated November 2019). 
 
- 
Olga Martin-Ortega and Andy Davies (2017), Protecting Human Rights in the Supply Chain. A Guide for Public Procurement Practitioners (CIPS). 
 
- 
LUPC-BHRE (2018), Protecting Human Rights in the Supply Chain. Free E-Learning suite.    ****     

## Research Reports And Policy Briefs

- 
Olga Martin-Ortega and Patrycja Krupinska (2018), UK Modern Slavery Act 2015 Transparency in Supply Chains: The Second Year of Reporting by Universities. BHRE Research Series, Report no. 3. June 2018. 
- 
Olga Martin-Ortega, Anna Gorna and Rahima Islam (2018), UK Modern Slavery Act 
Transparency in Supply Chains: Reporting by Local Authorities. BHRE Research Series, Report no. 2. March 2018. 
- 
Olga Martin-Ortega and Rahima Islam (2017),  UK Modern Slavery Act 2015 Transparency in Supply Chains: The First Year of Reporting by Universities, BHRE Research Series, Report 1. 
                                                                                                                                                                            
 

## Annex I: Modern Slavery Statements: Council Submission

The following Councils have a published at least one MS statement which is available either on their website or via TISC.  

- 
Ashfield District Council 
- 
City of London 
- 
Basingstoke and Deane Borough 
- 
City of York Council 
Council 
- 
Colchester Borough Council 
- 
Bassetlaw District Council 
- 
Corby Borough Council 
- 
Belfast City Council 
- 
Cornwall Council  
- 
Birmingham City Council 
- 
Coventry City Council 
- 
Blaby District Council 
- 
Cumbria County Council 
- 
Blackburn with Darwen Borough 
- 
Dartford Borough Council 
Council 
- 
Derby City Council 
- 
Bracknell Forest Council 
- 
Derbyshire County Council 
- 
Breckland District Council 
- 
Doncaster Metropolitan Borough 
- 
Brentwood Borough Council 
Council 
- 
Broxtowe Borough Council 
- 
Dudley Metropolitan Borough 
- 
Buckinghamshire Council  
Council 
- 
Caerphilly County Borough Council 
- 
Dumfries and Galloway Council 
- 
Calderdale Metropolitan Borough 
- 
Durham County Council 
Council 
- 
East Lindsey District Council 
- 
Cambridgeshire County Council 
- 
East Northamptonshire Council 
(LGSS) 
- 
East Riding of Yorkshire Council 
- 
Cannock Chase District Council 
- 
East Suffolk Council 
- 
Cardiff Council 
- 
Eastbourne Borough Council 
- 
Castle Point Borough Council 
- 
Eastleigh Borough Council 
- 
Ceredigion County Council 
- 
Elmbridge Borough Council 
- 
Charnwood Borough Council 
- 
Epping Forest District Council 
- 
Chelmsford City Council 
- 
Essex County Council 
- 
Cheshire East Council 
- 
Exeter City Council 
- 
Cheshire West and Chester 
- 
Flintshire County Council 
Council 
- 
Gedling Borough Council 
- 
Chesterfield Borough Council 
- 
Gravesham Borough Council 
- 
City of Bradford Metropolitan 
- 
Gwynedd Council 
District Council 
- 
Halton Borough Council 
- 
City of Lincoln Council 
- 
Harlow Council 
- 
Northamptonshire County Council (LGSS) 
- 
Hastings Borough Council 
- 
Northumberland County Council 
- 
Herefordshire Council 
- 
Nottingham City Council 
- 
Isle of Wight Council 
- 
Nottinghamshire County Council 
- 
Leeds City Council 
- 
Oldham Metropolitan Borough 
- 
Leicestershire County Council 
Council 
- 
Lewes District Council 
- 
Oxford City Council 
- 
London Borough of Barking and 
- 
Peterborough City Council 
Dagenham 
- 
Portsmouth City Council 
- 
London Borough of Camden 
- 
Powys County Council 
- 
London Borough of Croydon 
- 
Preston City Council 
- 
London Borough of Hackney 
- 
Reading Borough Council 
- 
London Borough of Hounslow 
- 
Rotherham Metropolitan Borough 
- 
London Borough of Islington 
Council 
- 
London Borough of Lewisham 
- 
Royal Borough of Greenwich 
- 
London Borough of Southwark 
- 
Salford City Council 
- 
London Borough of Sutton 
- 
Sandwell Metropolitan Borough 
- 
Manchester City Council 
Council 
- 
Mid Suffolk District Council (works 
- 
Sevenoaks District Council 
with Babergh District Council) 
- 
Shropshire Council 
- 
Milton Keynes 
- 
Solihull Metropolitan Borough 
- 
Neath Port Talbot Council 
Council 
- 
Newark and Sherwood District 
- 
South Cambridgeshire District 
Council 
Council 
- 
Newcastle-Under-Lyme District 
- 
South Derbyshire District Council 
Council 
- 
South Gloucestershire Council 
- 
North East Lincolnshire Council 
- 
South Kesteven District Council 
- 
North Hertfordshire District Council 
- 
South Norfolk District Council 
- 
North Somerset Council 
- 
South Tyneside Council 
- 
North West Leicestershire District 
- 
Southend-on-Sea Borough Council 
Council 
- 
St Albans City and District Council 
- 
North Yorkshire County Council 
- 
Stevenage Borough Council 
- 
Northampton Borough Council 
- 
Stockport Metropolitan Borough 
(LGSS) 
Council 
- 
Stoke-on-Trent City Council 
- 
Warrington Borough Council 
- 
Sunderland City Council 
- 
Warwickshire County Council 
- 
Swindon Borough Council 
- 
West Lancashire Borough Council 
- 
Tameside Metropolitan Borough 
- 
West Lindsey District Council 
Council 
- 
West Suffolk Council  
- 
Tamworth Borough Council 
- 
Wirral Council 
- 
Telford & Wrekin Council 
- 
Wolverhampton City Council 
- 
Tendring District Council 
- 
Worcestershire County Council 
- 
Torbay Council 
- 
Wyre Forest District Council 
 
The following Councils were not included in the report for the following reasons: 

- 
Babergh District Council - the document linked on the LGA website is a policy not a statement 
- 
London Borough of Newham - LGA link and Google search engine link to the statement are broken 
- 
Canterbury City Council - the document linked on the LGA website is a policy not a statement 
- 
Aylesbury Vale District Council, Chiltern District Council, South Buckinghamshire Council, Wycombe District Council - no longer exist and have been replaced with Buckinghamshire Council 
- 
Forest Heath District Council and St Edmundsbury Borough Council - no longer exist and have been replaced with West Suffolk Council 
- 
Suffolk Coastal and Waveney District Council - no longer exits and have been 
replaced with East Suffolk Council 
 
Many thanks to the LGA for maintaining a list of Councils with MS statement. 

# Annex Ii: Transparency In Supply Chains Reporting: Aide

## Memoire (Updated 2020)

 

MANDATORY (FORMAL) REQUIREMENTS 
DO 
DON'T 
Publication and Accessibility 
Report annually on the past financial year 
within six months of your organisation's 
financial year-end 
Improve the statement year on year - it is a live document Keep a record of old statements accessible to the public (providing URL links etc). This allows for progress to be monitored Publish the statement in a prominent place on your website, eg bottom of homepage or obvious drop-down menu 

## Formulation And Approval Process

Ensure the statement is approved at the highest level and signed by a senior member of the organisation (chief executive/leader of the council); providing their post and name, signature and approval date Ensure the statement is a genuine reflection of your business, practices, and 
culture Formulate the statement as a collaboration between departments, with procurement teams leading and others participating eg human resources, legal and safeguarding teams Provide relevant information in your statement with sufficient detail 
Report either in advance of the end of a financial year or after six months of your organisation's financial year 
Reproduce your old statement with minor word changes or merely altered dates Delete old statements, only have the current statement publicly available Publish it in a place difficult to find or password protected Leave the statement unsigned/dated or in draft format; simply state it has been approved without specifying Use templates without making the 
statement your own Leave it to one department or person to write the statement without input and contribution of others Use the statement to showcase non- Modern Slavery and human rights related activities and overwhelm the reader with excessive details, ie too much legal or technical information 

## Substantive Content Of Statements

DO 
DON'T 

## Organisational Policies

Showcase your Modern Slavery policy if you have it and explain the link between your existing policies and Modern Slavery Amend existing policies to include references to Modern Slavery or create a standalone Modern Slavery policy If approving a standalone Modern Slavery policy, clearly set out the obligations on 
staff, suppliers, business partners and agents, as well as procedures to be followed Clearly state who is responsible for the implementation of the relevant policies, how implementation will be monitored and how it should be reported on Circulate policies in your organisation and relevant parties to make it known to all and explain how this is done in the statement   

## Due Diligence: Identifying And Prioritising Risks

Show you understand the risks of abuse your organisation and practices pose:  

- 
towards your own staff 
- 
related to recruitment practices (including use of agencies) 
- 
related to sub-contracting 
- 
related to the products/services you procure 
- 
in your supply chains. 

Consider risks associated by country; sector; transaction; and business partnerships as set out in Tackling Modern Slavery in Government Supply Chains Guide for Commercial & Procurement Professionals Highlight your high-risk areas, whether product or service based, in your supply chain Prioritise risks and focus on high-risk supply chain mapping 
Try to map all of the supply chain at once 
Understand that risks may change   
Reproduce the same risks year on year in your statement 
List or reproduce all of your organisational policies Refer to policies that have no relation to Modern Slavery Create a Modern Slavery policy composed of a collection of empty 
statements with no clear impact on your council's work and behaviour eg. merely referring to a zero tolerance approach is not enough Publish a policy without a responsible department/person and an enforcement, reporting and review mechanism Have policies your staff, constituents and customers, business partners, suppliers and other stakeholders don't know about and wouldn't be able to find unaided Reproduce the risks found in other statements or templates without 
assessing how they relate to your own practice and suppliers State that procuring solely from the UK means your supply chains are at a low or no risk of Modern Slavery. Modern Slavery is occurring every day in public sector supply chains in the UK Merely list all products or services procured 

## Mandatory (Formal) Requirements Due Diligence: Preventing, Mitigating And Remedying Abuses

Ensure that you have functioning and responsible procurement and contract management due diligence procedures to minimise risks of modern slavery taking place within domestic and global supply chains. For example: 

- 
referrals, site visits and spot checks 
- 
contractual provisions and contract 
monitoring and management 
- 
asking for suppliers to provide their own due diligence of their subcontractors and supply chains 
- 
use online modern slavery risk identification and management tool 
such as the government's Modern 
Slavery Assessment Tool (MSAT) 

Seek assurances from suppliers during the tendering process. Ask the questions up front and probe responses, where appropriate Pre-procurement specification, questionnaires and checklists can be found in Tackling Modern Slavery in Government Supply Chains Introduce Modern Slavery related clauses into contracts and terms and conditions and use them to engage with 
suppliers meaningfully, making your expectations clear Work with suppliers to create action plans, take corrective measures, and if suppliers refuse to cooperate, consider measures against them When contracting services robustly question recruitment processes Report on planned monitoring and auditing measures for your own sites and sites of your suppliers When using third party audits engage in the process and create action plans   
Rely on the audit without a follow-up 
Identify and report violations, and address how you will mitigate them   
Do not make vague and generalised declarations stating that you take all appropriate measures without providing 
details Solely rely on a checklist and allow this to become a tick box exercise Simply inform suppliers of your policies or ask them for theirs and seek vague 
anti-slavery assurances Immediately terminate the business relationship Use minimal vetting techniques, or state 
that you use 'reputable recruitment 
agencies' which you have not assessed Outsource the responsibility to your suppliers, merely assuming they will carry out adequate monitoring Hide or dismiss violations or rely on suppliers to resolve them when they take place lower down in your supply chain 

## Mandatory (Formal) Requirements

| DO                                        |
|-------------------------------------------|
| Establish Modern Slavery working groups   |
| internally in which relevant departments  |
| are involved to address instances where   |
| you have identified risks or actual abuse |
| Review these procedures annually and      |
| continuously seek to innovate and         |
| improve on these over time                |

## Collaborating With External Partners

Provide details of your collaboration with external partners, including the measures taken Collaborate within your sector and share good practice Seek to collaborate with organisations working in different sectors that can help you manage modern slavery risks - for example Electronics Watch4who provides intelligence, collaboration and support about working conditions in factories that assemble IC. 

## Measuring Effectiveness And Planning For The Future

Report on how you will measure effectiveness and who is responsible for this measurement  
Provide information on existing Key 
Performance Indicators (KPIs) 
Ensure KPIs are Modern Slavery related, including responsible procurement KPIs Track progress at short, medium and long term, and allow for substantive measurement Review your aims, goals and KPIs annually, with distinct future goals 
Be honest, if you've not had much success it's fine to be upfront about this 
whilst striving to improve in the future 

 

Make due diligence the responsibility of one sole individual or department in the institution - it is an organisation wide process. Be complacent that current due diligence practices will always mitigate the risk of Modern Slavery in your supply chains - unscrupulous suppliers will always be looking for new ways to exploit the situation 
Sign up to partnerships or collaborations, expecting for them to resolve the problem for you Treat the statement as a competition or a trade secret Think you can combat Modern Slavery on your own, pooling resources and intelligence will often be required. State the procedures have been reviewed without indicating the assessment and impact they had  
Make vague and general commitments 
for the coming years 
List commitments which are not directly relevant Fail to assess and report on the effectiveness of measures undertaken Reproduce the same KPIs year on year without measuring their effectiveness Be afraid of publishing a lack of progress or hide setbacks 

 

## Mandatory (Formal) Requirements Training And Capacitation

Provide Modern Slavery specific training which is relevant to your organisation Provide training to all staff, including refreshers and new courses Provide targeted Modern Slavery supply chain and contract management training for relevant staff, especially to procurement teams, contract managers, 
trading standards, compliance, legal and finance teams Use external and internal training 
Outsource all training responsibilities to consultants 
Cite training unrelated to Modern Slavery in your statement or provide training which is not relevant to your work Reduce Modern Slavery training to induction processes for new staff Use a one fits all approach  

## Endnotes

 
i Most statements were identified through individual Council websites. In addition, the research process also relied upon the Modern Slavery Registry hosted by the Business and Human Rights Resource Centre and the list compiled by the Local Governments Authority (LGA) as well as the database compiled by the TISC Report.  Despite upmost care having been put into identifying statements, some are not readily available and easily identifiable. ii See Home Office, Transparency in supply chains consultation. Government response (22 September 2020). iii We understand that those changes are still being implemented and administrative adjustments take time - however, we have sought to use statements published by new entities, forgoing obsolete councils, even if those still maintain a website and have previously published statements. iv Lewisham Borough Council Statement 2018/2019 is a officially labelled as a 'Draft'. The statement which can only be found under the Council Meetings section, had been approved in February 2019, according to the decision log. It is only available in that section of the website and has a 'Draft' watermark on it. On one hand, the attached statement has seemingly been approved but on the other, it is still a draft. At the end of the day, the decision as to whether it should be considered a finalised statement is down to the reader.  
v Ashfield Council 2018/2019 Statement - which has since been replaced on the Council website with the updated 2019/2020 Statement, and the issue corrected.   
vi For example Coventry Council's Statement 2019/2020 states that it is a statement for the financial year ending in 2018. This does not match its indicated financial year in the title, beginning in 2019 and ending in 2020.  It would be logical to assume that the statement had not been updated from last year's version, if one even existed or that a template was used. As the Council does not have a historical record of statements on their website, a problem discussed below, this cannot be double checked. vii As mentioned above Lewisham Borough Council statement 2018/2019 is only available in the Council Meetings sections. In fact, it could only be found via a search engine. For the purposes of this report, the Lewisham Council statement was taken into account - as the intention of this research project is to identify progress and good practices. Conversely, a 2020/2021 Elmbridge Council statement, also only found amongst documents from a March 2020 Cabinet meeting, has not been taken into account, as it isn't clear whether the statement had been approved, and it appears to be future dated. viii Uttlesford Council, states on its website it has a modern slavery statement which should be accessed by following a link - which does not exist. A 'Read our' phrase appears on the webpage, but is neither finished, nor is it hyperlinked. ix see, Belfast City Council - September 2019 review; City of London Statement 2018/2019 - new statement due to be published in July 2019. x In some cases it may be simply due to mislabelling and they do discuss the 2019/2020 activities. xi We were only able to review the old statements due to having had downloaded them for the records before they were taken down. BHRE holds a large database of old statements from local authorities and universities. xii City of London Statement 2018/2019 xiii For example, three Councils (Cambridgeshire County Council, Northamptonshire County Council and Northampton Borough Council) had their Statement written by the public sector business support services organisation LGSS. LGSS addresses the statement in its own name on behalf of the Councils and provides no reflection or detail about the business of the individual councils. It is unclear if LGSS is responsible for all business of all three Councils. If not, then it is hardly adequately positioned to prepare a statement on their behalf. Though Councils are not precluded from collaborating and entering partnerships for combating modern slavery and human trafficking, those are better described in the statement rather than used to author a statement. xiv Thus, the Dumfries and Galloway Council Statement linked on its website for Enterprising DG, which appeared to be a commercial company, was a surprise. The statement itself remained silent on the relationship between Enterprising DG and the Council, despite the Council website stating this is their own statement about actions undertaken by them. Further research revealed that enterprising DG is a commercial arm of the Dumfries and Galloway Council. xv For example, as in the Belfast City Council statement. xvi For instance, Charnwood Borough Council Statement 2019/2020 (since removed) was signed by a Cabinet Lead Member for Equalities - a position which was only identified by searching for the councillor's name on the website, and which might not be possible once the member ceases to be a councillor. See also: Charnwood Borough Council Statement 2020/2021. xvii East Lindsey District Council Statement 2018/2019 xviii East Riding of Yorkshire Council Statement 2017/2022 xix Colchester Council's Transparency Statement 2018/2019 is an example of insufficient quality. xx Sunderland Council 2018/2019 Statement xxi Neath Port Talbot Council (Statement 2019/2020) indicates that high risk suppliers will be investigated as and when required on an ongoing basis but did not identify any specific risk areas. Similarly, whilst Cardiff Council listed high risk areas such as agriculture, leisure, hospitality, catering, clothing, construction and manufacturing, they did not specify which were most relevant to their own supply chain. Although an educated guess can be made as to which areas are most relevant to a public body, the Councils should still make that assessment themselves. xxii Lewisham Borough Council Statement 2018/2019. The mitigating measures listed include using the ICT Shared Service provided by the London Borough of Brent. According to our research, this covers staffing, infrastructure 
 
and joint procurement. Other measures adopted by the Council include use of the Crown Commercial Service (CSS) framework agreement to procure ICT hardware. xxiii City of London Statement 2018/2019 xxiv Ibid. 

xxv Neath Port Talbot Council (Statement 2019/2020) xxvi Leeds City Council (Statement 2019/2020 - available only via TISC Report) mentions 'Instinct' which it describes as an internal reporting system for MS that has been in operation for 3.5 years. Where MS is identified it is then reported to relevant bodies and 'appropriate action' is taken, according to the statement. The Council, however, fails to identify any further detail. The questions that remain are whether this is a system concerned with safeguarding and MS within the community of Leeds or is it concerned with the Leeds Council supply chain. There is no indication as to what is a 'relevant body', what incidents have been identifies, or what amounts to 'appropriate action' xxvii Basingstoke and Deane Council Statement (No Date). However, it does not clarify what those clauses may be or the type of situations where it may be deemed necessary. xxviii Essex County Council Statement 2019/2020 xxix Flintshire County Council Statement 2019/2020 xxx The Electronics Watch worker-driven monitoring methodology is guided by workers' rights and priorities. If provides public buyers with an effective tool for public buyers to detect and remedy labour rights and safety breaches in their global supply chains. xxxi Swindon Borough Council Statement 2016/2017 - available only via TISC xxxii Salford City Council Statement 2019 xxxiii East Riding of Yorkshire Council Statement 2017/2022. However, apart from housing support, it provides no other details on the type of assistance that would be provided. xxxiv Ceredigion County Council 2019/2020 xxxv Ceredigion County Council 2019/2020; Croydon Borough Council 2018/2019 xxxvi Ceredigion County Council 2019/2020 xxxvii For instance, Elmbridge Borough Council (Statement 2018/2019) is a member of the Elmbridge Community and Safety Partnership (ECSP) along with other agencies. Operational arms of the ECSP include the Joint Action Group (JAG) and the Community Harm and Risk Management Meeting CHARMM, and deal with long- and shortterm operational issues. However, the Council fails to describe any modern slavery projects undertaken as part of that partnership. xxxviii Wirral Modern Slavery Strategy 2018-2021 xxxix Sandwell Council Statement 2019/2020 xl Electronics Watch list of affiliates includes several European local authorities. Other organisations in the UK which have joined the organisation are Universities and universities purchasing consortia. xli The trade union Unison has produced a Guide to Ethical Procurement in UK Local Authorities (2018) which contains useful information on ethical procurement initiatives and good practice case studies. xlii See for example the International Trade Union Confederation report Towards mandatory due diligence in global supply chains xliii Tameside Metropolitan Borough Council Statement 2020/2021 - available only via TISC xliv Derbyshire County Council Statement 2019/2020 xlv Nottingham City Council. The Council should consider expanding this further in the future, as this exact same paragraph has been copied into each of its statements since the 2016/2017 period. xlvi In their 2017/2018 Statement, Sunderland Council indicated they were in the process of reviewing their KPIs. However, by the following year in their 2018/2019 Statement, KPIs are not even mentioned - however, that may be down to what appears to be a missing page, or pages, in the statement. xlvii Cardiff Council Statement 2019/2020 - since deleted xlviii Cardiff Council Statement 2020/2021 xlix Elmbridge Borough Council Statement 2018/2019 l See: Nottingham City Council– all statements li Cardiff Council Statement 2020/2021 lii Lewisham Borough Council Statement 2018/2019 liii Nottingham City Council 2019 liv Croydon Borough Council 2018/2019