NAViGO Health and Social Care CIC as the parent company, and on behalf of our subsidiaries, makes the following statement with regard to the steps taken to prevent slavery and human trafficking within our supply chain in line with Section 54 of the Modern Slavery Act 2015.
Modern slavery can take place in a wide range of employment sectors, including health and social care. As a large health and social care provider we recognise our role in identifying and supporting victims of modern slavery and human trafficking who may come to us for care or treatment. This is part of our safeguarding strategy and arrangements.
We are committed to ensuring there is no modern slavery or human trafficking in our supply chains nor any part of our business activity. NAViGO CIC’s core values are consistent with the government’s aim to eradicate modern slavery in the UK. Furthermore, in providing our range of services, NAViGO CIC has a duty to uphold the principles of the Human Rights Act (1998), specifically article 4 which holds that people have the right to live free from slavery or forced labour.
NAViGO CIC is a social enterprise who provide mental health services to the NHS and beyond across North-East Lincolnshire. The whole basis of our work is to ‘deliver services that we would be happy for our own family to use’.
We offer a range of mental health services, including acute and community facilities - as well as specialist support such as older adult’s inpatient services; rehabilitation and recovery; community mental health; and an outstanding specialist eating disorder facility.
In addition we’ve developed income-generating, commercially-viable businesses that provide training, education and employment opportunities including Grimsby Garden Centre and two cafes.
Further details with regard to NAViGO CIC’s business, Annual Reports and Social Accounts can be found on our website.
As the majority of our business is publicly funded health and social care, a high proportion of our suppliers and contracting arrangements are compliant with the Public Contracts Regulations 2015.
NAViGO CIC purchases a significant number of products through NHS Supply Chain, who’s ‘Supplier Code of Conduct’ includes a provision around forced labour.
Other contracts are governed by standard NHS Terms & Conditions and are paid via Purchase Order. The Applicable Contract Terms Policy applies to any NHS funded organisation and states that by the issuing of a PO the standard Terms & Conditions apply, i.e. Section 10 (Warranties) places specific requirements on providers to assure their compliance with modern slavery requirements within their supply chain.
The majority of our purchases utilise existing supply contracts or frameworks which have been negotiated under the NHS Standard Terms and Conditions of Contract, these all have the requirement for suppliers to have suitable anti-slavery and human trafficking policies and processes in place.
Where a suitable supplier framework exists we use them in preference to tendering. NAViGO CIC will request all suppliers to comply with the provisions of the UK Modern Slavery Act (2015), through agreement of our purchase orders and tender specifications. All of which will set out our commitment to confirming there is no modern slavery or human trafficking related to NAViGO CIC service delivery and business.
NAViGO CIC annual supply chain spend is managed through a robust accounting system.
High value contracts are effectively managed and relationships built with suppliers. Within the supply chain, potential large scale suppliers are asked to confirm their adherence to the requirements of the Modern Slavery Act 2015 through Selection Questionnaires and quotation documentation. The assessment is both in terms of ‘self-cleaning’ declarations and a specific requirement for suppliers to describe the steps it takes to ensure that there is no modern slavery or human trafficking present within its organisation and sub-contractors/ suppliers supply chains. As part of our contracting processes, we will include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude and we expect that our providers and suppliers will hold their own suppliers and sub-contractors to the same high standards.
Key to the contractual relationship with suppliers is the requirement that the supplier represents warrants and undertakes that it conducts its business in a manner that is consistent with the principles of the Modern Slavery Act 2015.
Our terms and conditions also place a requirement on the supplier to notify NAViGO CIC immediately it becomes aware of any actual or suspected slavery or human trafficking in a supply chain which has a connection with the services delivered and NAViGO CIC is then in a position to take the appropriate action required.
Due diligence for any supplier arrangement within the Navigo group may also include written confirmation from the supplier that their business complies with the Act.
NAViGO CIC has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implement and enforce effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.
The ongoing development and cross referencing of relevant policies to support this aim is a key priority for NAViGO CIC. Existing policies particularly around safeguarding, and recruitment describe our approach and actions to take in relation to modern slavery.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
Our Incident Reporting Policy states that staff should report incidents of all types and this includes concerns regarding modern slavery and human trafficking. By using the local risk management system (Datix) appropriate teams, including safeguarding and Freedom to Speak Up are made aware.
As detailed above NAViGO CIC have a number of safeguards in place for the assessment and monitoring of our supply chain with regard to compliance to the Modern Slavery Act.
Internally NAViGO CIC also has a number of measures to safeguard the organisation against slavery and human trafficking:
- All staff employed by NAViGO CIC have an employment contract that is compliant with UK Law.
- All staff undertake mandatory safeguarding training, which includes the key elements of the Modern Slavery Act.
- All staff have the ability to raise any concerns through the NAViGO CIC Freedom to Speak-up Guardian.
We confirm the identities of all new employees and their right to work in the United Kingdom by adherence to the National NHS Employment Checks / Standards (this includes employees UK address, right to work in the UK and suitable references) and pay all our employees above the National Living Wage.
Our Bullying & Harassment, Grievance and Voicing your Concerns for Staff policies additionally give a platform for our employees to raise concerns about poor working practices.
NAViGO CIC is committed to ensuring equality of access to employment and training opportunities. This policy aims to eliminate unlawful and unfair discrimination and ensure that all groups and individuals within the community benefit through having equal access to employment opportunities provided.
Our approach to overseas/ international recruitment differs to many NHS Trusts in that we aim for an ethical and sustainable source of recruits, based on network, local and reciprocal learning approaches, particularly for our Nursing and Medical workforce. We purposely do not engage the services of Recruitment Agencies or companies, recruiting in large cohorts, or seek to engage with those agencies for any overseas recruits that are now UK based.
By developing Alumni networks of our existing overseas staff and engaging with their previous University/ College including our offer to deliver specialist lectures and seminars at no cost we have promoted our openness for individuals to apply directly to us. This avoids any potential for third parties or agents to be profiteering from or coercing the supply of overseas doctors or nurses.
As such we support individual recruits at a personal level, obtaining relevant sponsorship and visas for them ourselves as a company. By providing a relocation package at no cost to the employee or their family, we are able to offer pastoral support to the recruit and dependents whilst they settle and achieve their UK professional registration as a Nurse or Medic.
NAViGO CIC has a Freedom to Speak Up – Raising Concerns and Whistleblowing Policies which detail how staff can raise any concerns that they may have confidentially. This can be through a Freedom to Speak Up email inbox, or through a conversation with the Freedom to Speak Up Guardian, who will provide support to the individual raising a concern. Staff are provided with this information at corporate induction.
We have policies and procedures in place to equip staff with the skills to identify and support victims of modern slavery and to ensure modern slavery is not taking place in our business activities and supply chains.
Our safeguarding training includes role relevant awareness and understanding of modern slavery and helps staff identify, respond to and support victims of modern slavery and recognise the important role of the NHS in protecting these individuals.
All staff on completion of the training are aware of the local contacts and safeguarding champions who are available for additional support and guidance in the formal escalation of any modern slavery concerns.
The effectiveness of the NAViGO CIC compliance with Modern Slavery Act is measured as follows:
- Staff compliance with mandatory training – to ensure that all staff are aware of the Modern Slavery Act and know how to report any concerns to the dedicated hotline.
- As detailed above regarding the supply chain, NAViGO CIC is required to demonstrate, where required, their adherence to the Act.
We intend to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in our supply chains.
The Navigo CIC Board is committed to its compliance to the Modern Slavery Act and has considered and approved this statement and will continue to support the requirements of the legislation and will continue to develop its strategies, policies and keep abreast of any national changes.