Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Individuals may be trafficked into, out of or within the UK, and they may be trafficked for a number of reasons including sexual exploitation, forced labour, domestic servitude and organ harvesting.
The Modern Slavery Act 2015 introduced changes in UK law focused on increasing transparency in supply chains, to ensure our supply chains are free from modern slavery (that is, slavery, servitude, forced and compulsory labour and human trafficking).
NHS Surrey and Sussex Integrated Care Board (covering Surrey, Brighton and Hove, East Sussex and West Sussex), as an employer, is committed to working with local partners to improve our practice in combatting slavery and human trafficking and to raise awareness, disrupt and respond to Modern Slavery.
Commitment to Prevent Slavery and Human Trafficking
As an authorised statutory body, ICBs are the lead commissioners for health care services including acute, community, mental health, pharmaceutical, optometry and dental across Surrey.
NHS Surrey and Sussex ICB Governing Body, Executive Management Team, commissioners and all employees fully support the government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS must play in both combating it and supporting victims.
NHS Surrey and Sussex are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and in so far as is possible to holding our suppliers to account to do likewise.
Our approach
As commissioners of care and statutory partners of Safeguarding Adult Boards and Safeguarding Children Partnerships, NHS Surrey and Sussex ICB plays a key role in supporting the work and strategic priorities in tackling modern slavery and human trafficking.
The overall approach will be governed by compliance with legislative and regulatory requirements and the maintenance and development of good practice in the fields of contracting and employment.
We are strongly committed to ensuring commissioned services and supply chains are compliant with relevant legislative requirements. NHS Surrey and Sussex ICB acknowledge the provisions set out in the Modern Slavery Act 2015 and will ensure it is open and transparent and effectively utilise its own due diligence to ensure that there is no evidence of acts of modern slavery or human trafficking within the organisation.
As part of the NHS Surrey and Sussex ICB commissioning assurance process, we will request evidence via the NHS contract schedule from all our health providers in regard to their plans and arrangements to prevent slavery in their employment practices and supply chain.
Training
NHS Surrey and Sussex ICB invest in appropriate statutory and mandatory safeguarding training which includes Modern Slavery for all staff to support their understanding and awareness.
Policies and arrangements
NHS Surrey and Sussex ICB recruitment processes are robust and adhere to safe recruitment principles. We adhere to National NHS Employment Standards which includes checks on the employees address in the UK, their right to work in the UK, obtaining suitable references and checking for any criminal records.
Our Safeguarding Adults and Children policy, Civility and Respect at Work, Grievance Policy and Freedom to Speak Up (Whistleblowing) policy provide additional platforms for our employees to raise concerns about poor and inappropriate working practices.
Our procurement approach follows the Crown Commercial Service standard. When procuring goods and services, we apply NHS Terms and Conditions (for non-clinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.
Review of effectiveness
NHS Surrey and Sussex ICB intend to take further steps in 2026/27 to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers. NHS Surrey and Sussex ICB will commit to:
- Employ Designated Safeguarding professionals providing expert support and advice into the commissioning process and supporting multi-agency work to respond to modern slavery and human trafficking.
- Raising awareness of the Modern Slavery Act 2015 internally and as part of all procurement processes. We will request all providers to set out evidence of their plans and arrangements to prevent slavery in their activities and supply chain.
- Gaining assurance that all commissioned services have access to training on how to identify those who are victims of modern slavery and human trafficking. This training will include the latest information for staff to develop the skills to identify and support individuals who come into contact with health services
- Working with NHS funded and partner organisations to ensure modern slavery and human trafficking are appropriately prioritised and feature prominently in safeguarding work plans.
- Working with the local authorities and other partners on the review and effectiveness of emergency planning and procedure for dealing with instances of modern slavery.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year.