Section 54 of the Modern Slavery Act 2015 requires all organisations to set out the steps it has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.

Aim of this Statement

The aim of this statement is to demonstrate that the Trust follows good practice and all reasonable steps are taken to prevent slavery and human trafficking. All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking, with the Procurement Department taking the lead responsibility for compliance in the supply chain.

About Us

Bolton NHS Foundation Trust is a major provider of hospital and community health services in the North West Sector of Greater Manchester, delivering services from the Royal Bolton Hospital and also providing a wide range of community services from locations across Bolton.

The Royal Bolton Hospital is a major hub within Greater Manchester for women’s and children’s services and is the second busiest ambulance- receiving site in Greater Manchester We employ approximately 6000 staff and in 2023/24 had a turnover of over £400m.

Organisational policies in relation to slavery and human trafficking.

The Trust is fully aware of the responsibilities it bears towards patients, employees and the local community and as such, we have a strict set of ethical values that we use as guidance with regard to our commercial activities. We therefore expect that all suppliers to the Trust adhere to the same ethical principles.

Recruitment policy: We operate a robust recruitment policy including conducting eligibility to work in the UK checks for all directly employed staff. External agencies are sourced through the NHS England nationally approved frameworks and are audited to provide assurance that pre-employment clearance has been obtained for agency staff to safeguard against human trafficking or individuals being forced to work against their will.

Safeguarding Policies: All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking. All staff are required to undertake level one adult safeguarding training which includes an awareness of the risks of modern slavery and human trafficking.

Raising Concerns (Whistleblowing) Policy: We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals.

Equal Opportunities: We have a range of controls to protect staff from poor treatment and/or exploitation which comply with all statutory and regulatory requirements. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities.

These and other internal policies are in place, to protect those that we, and our delivery partners, work with from modern day slavery and human trafficking ensuring that:

• • Staff can report concerns about slavery and human trafficking and management will act upon them in accordance with our policies and procedures.
  • All clinical and non-clinical staff have a responsibility to consider issues regarding modern slavery and incorporate their understanding of these into their day-to-day practices.
  • Staff are able to raise concerns through the Freedom to Speak Up Guardian, about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisal.
  • Advice and training about slavery and human trafficking is available to staff through the Safeguarding Team.

Organisational Structure and Supply Chains

The Trust policies, procedures, governance, and legal arrangements are robust, ensuring that proper checks and due diligence are applied in employment procedures to ensure compliance with this legislation. We also conform to the NHS employment check standards within our workforce recruitment and selection practices, including through our subsidiary organisation iFM Bolton and through any managed service provider contract arrangements.

The treatment of employees is managed consistently across the Trust by the Human Resources Directorate. The Trust pays above both the national minimum wage and the national living wage thresholds set by the Government.

To play our part in eradicating modern slavery and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain we:

• Apply NHS Terms and Conditions for procuring goods and services (for non-clinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.
• Comply with the Public Contracts Regulations 2015, use reputable frameworks where appropriate and for any procurement processes the Trust uses the mandatory Crown Commercial Services (CCS) Standard Selection Questionnaire. Bidders are always required to confirm their compliance with the Modern Slavery Act.
• Ask our awarded suppliers to, sign up to the NHS Terms and Conditions for procuring goods and services which contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains.
• In addition, an increasing number of NHS suppliers are implementing the Labour Standards Assurance System (LSAS) as a condition of contract for tenders within high risk sectors and product categories, as referenced in the Government’s Modern Slavery Strategy.

The Board of Directors has considered and approved this statement and will continue to support the requirements of the legislation.

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 financial year ended 31 March 2024

Fiona Noden, Chief Executive
28 March 2024