Modern Day Slavery Risk Assessment
Legal footing
Whilst the main provision of the UK Modern Day Slavery Act 2015 is focussed on larger organisations with an annual turnover of £36 million or more, there are aspects which are relevant to much smaller organisations and may be undertaken despite there not being a legal requirement to do so.
One such element is a Modern Day Slavery Risk Assessment. This risk assessment reviews the operational and supply chains of the company to assess the potential risk of modern day slavery being used.
Internal Operational Risk Review
Healthwatch Wakefield are committed to working as a productive and positive local force within Wakefield District. Where possible volunteers and staff are sourced locally, and we endeavour to buy local where possible.
Our recruitment, of both volunteers and staff, is taken out using established channels including LinkedIn, Indeed and NHS Jobs. While the organisation does not discriminate against international or national applicants, they are engaged in discussion to understand their plans to live and work in Wakefield and we aim to understand their current situations. Healthwatch Wakefield are not a sponsor for international work visas and do not pursue any sponsored work visas transfers.
All staff are vetted both through Disclosure and Barring Service and through reference checking to ensure that the individual is fit and proper for the role and our information is correct.
All staff are supported through regular supervision and informal support sessions, and any issues around safeguarding of staff and volunteers is taken very seriously should a disclosure be made, this would also be referred to the Safeguarding or Police authorities where appropriate.
Healthwatch Wakefield also takes its duty to safeguard members of the public very seriously and if any disclosure of abuse or modern day slavery was made this would be reported and escalated immediately following established processes.
Supply Chain Risk Review
Healthwatch Wakefield are primarily a service delivering corporation and does not produce any products which require a supply chain of parts and tools. However, the organisation does procure general administrative materials and services, for example printing and marketing supplies.
Healthwatch Wakefield has also secured sub-contractors for specific pieces of work, for example the Young Healthwatch service has been co-delivered with a sub-contractor.
Supply Chain
As a small organisation Healthwatch Wakefield is limited in its ability to influence the majority of suppliers of products and services, however where possible due diligence is undertaken to assess the risk of modern day slavery.
| Supplied item type | Supplier | Local / National / International | Do they have a Modern Day Slavery Policy statement | Risk rating |
| Printing (service of printer and materials such as ink and paper) | Viking Digitec |
International Local |
Yes – Here No – Under threshold |
Low Low |
| Marketing supplies | Solopress LSI Secprint |
National National Local |
Yes – Here Yes – Here No – Under threshold |
Low Low Low |
| Meeting tools (such as Plaud note taking device and Owl labs device) | Plaud Owl Labs |
International International |
No – Not available on website No – Not available on website |
Medium Medium |
| Phone service | Abzorb | National | No – Over threshold | Medium |
| IT support and IT purchasing | Electroville | Local | No – Under threshold | Low |
| Mobile phones and phone provider | O2 | International | Yes – Here | Low |
| Rent agreement | Wakefield Business Centres | Local | No – Under threshold | Low |
| Banking and credit | Unity Bank Lloyds Bank |
National International |
Yes – Here Yes – Here |
Low Low |
| Room hire | Various community centres in Wakefield District | Local | No – Under threshold | Low |
Subcontracting arrangements
Healthwatch Wakefield sometimes enters into agreements with other organisations to provide services together or under sub-contract. Where these arrangements are entered into due diligence is carried out and there is always an intention to work with local and trusted organisations.
Proactive steps to prevent Modern Day Slavery
Healthwatch Wakefield have retroactively reviewed our current internal processes and our subcontracting and supplier arrangements to understand the risk for modern day slavery exploitation.
Moving forwards Healthwatch Wakefield will take steps to ensure that all new contracts with suppliers and sub-contractors are added to this risk assessment as a live document. Additionally, our team will review our recruitment processes to further assure that we are not at risk of facilitating or enabling modern day slavery.
This document will be reviewed at the Trustee board periodically for reflection and update.