NWCH against modern slavery
Slavery has changed its forms and continues to harm 40.3 million people around the world today. At NWCH, we are passionate about people and their freedom of choice and have a zero-tolerance policy on forced labour or any form of employer coercion.
All of our Framework Partners have a Modern Slavery Policy in place, designed to assist commercial organisations to comply with the Modern Slavery Act 2015 and leaving no room for exploitation. Framework Partners also provide an updated annual report as required by legislation, which is published on their websites.
All staff and direct labour are required to provide proof of their right to work in the UK prior to engagement, and contractors will check their original documentation, NI number and CSCS card (for manual labour) before appointment can be confirmed.
A review by our Commercial and Procurement Special Interest Group established that 95% of Framework Partners provide training for on and off-site staff on Modern Slavery, whether in the form of online sessions, face to face webinars or e-learning modules. All of our Framework Partners have due diligence checks in place for the appointment of their suppliers and subcontractors.
Most tier 1 subcontractors are required to prove their compliance with Modern Slavery Legislation by providing appropriate evidence of policies in place.
There is improvement to be made when cascading these requirements down to tier 2 supply chain, as some smaller suppliers don’t appear to have the resources to fully monitor compliance.
A Framework Partner operating nationally cited a small number of instances of where suspected modern slavery were raised, which were investigated and none resulted in the identification of modern slavery. This demonstrates employee awareness of the warning signs and a willingness to report concerns.
NWCH and Framework Partners expect all supply chain members to comply with our values, and it is, of course, a legal requirement to prohibit the use of forced, compulsory or trafficked labour, including anyone held in slavery or servitude. All sites have a whistle blowing procedure in place which includes ways to raise concerns without fear of retribution.
NWCH and our Framework Partners are driving this agenda forward and will continue to do so. It is clear from the review by our Special Interest Group that modern slavery is not prevalent at the top end of the supply chain, but due to their covert nature, instances can be difficult to identify, so we will strive to make further improvements and implement useful strategies wherever possible, putting human rights at the forefront of the way in which we work.