NHS England modern slavery and human trafficking statement

NHS England modern slavery and human trafficking statement 2024/25

1. Organisational structure and supply chains

NHS England leads the NHS in England to deliver high-quality services for all.

We do this by ensuring that the healthcare workforce has the right numbers, skills, values and behaviours to support the delivery of excellent healthcare and health improvement to patients and the public.

We share out more than £100 billion in funds each year and hold organisations to account for spending this money efficiently and effectively for patients and for the taxpayer.  We work with the wider NHS and our partners to optimise the use of digital technology, research and innovation, and to deliver value for money and increased productivity and efficiency.

We are responsible for running the vital national IT systems which support health and social care, and the collection, analysis, publication and dissemination of data generated by health and social care services to improve outcomes for patients.

Staff and patients rely on NHS commercial teams to buy the goods and services they need, making sure vital supplies are delivered to the NHS without disruption, so that frontline staff can focus on providing world-class patient care.

The scale of NHS commercial activity is significant, with around 4,000 commercial, procurement and supply management professionals spending £30 billion across approximately 80,000 suppliers, including medical goods and services, office supplies, cleaning, catering and transport services. NHS England Central Commercial Function helps trusts and integrated care boards (ICBs) to leverage NHS buying power through category expertise.

Further details about what we do can be found on our website.

2. Policies in relation to modern slavery and human trafficking

NHS England fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS must play in both mitigating it and supporting victims. This includes a commitment to ensure our supply chains and business activities are free from ethical and labour standards abuses.

The NHS Evergreen Sustainable Supplier Assessment, launched in June 2023 and embedded within Atamis, the NHS-wide e-commerce platform, enables NHS suppliers to share their progress against the NHS Net Zero Supplier Roadmap, published in 2021.  The Evergreen Assessment requires action on modern slavery to progress through the maturity levels of the assessment.

The NHS aligns to the Cabinet Office Terms and Conditions for the procurement of goods and services, which govern how we engage with our suppliers and requires compliance with relevant legislation, including the Modern Slavery Act 2015.  The terms and conditions are aligned to Procurement Policy Note 02/23, Tackling Modern Slavery in Government Supply Chains, and include the option to terminate for breaches of social and labour laws.

NHS England adheres to internal policies that support our commitment to eradicating modern slavery, including the:

NHS England is a ‘prescribed person’. That means itcan receive protected disclosures, is responsible for handling cases of speaking up under the Public Interest Disclosure (Prescribed Persons) Order 2014, and must report annually on disclosures. This allows secondary and primary care staff working at NHS trusts, NHS foundation trusts, GP surgeries, opticians, pharmacies and dental practices to raise concerns about inappropriate activity with NHS England directly. The latest NHS England annual report for freedom to speak up (FTSU) – whistleblowing disclosures made by NHS workers covers 2022/23.

NHS England is working in partnership with the Department of Health and Social Care (DHSC) to draft new regulations, as required by Section 81 of the Health and Care Act 2022, which set standard rules for the procurement of healthcare products and services. Guidance is in development to support the NHS to comply with the new regulations and provide additional support on implementing the requirements set out in Procurement Policy Note (PPN) 02/23 Tackling Modern Slavery in Government Supply Chains. The development of both the regulations and guidance will take into consideration the findings of the review of risk report outlined below (section 4).

3. Due diligence process

When undertaking procurement activity, we use the government’s standard selection questionnaire, which has been built into our e-commerce system and includes exclusionary grounds addressing modern slavery risk.

We have adopted central government’s Social Value Model (Procurement Policy Note 06/20), which requires a minimum 10% weighting in all procurements dedicated to net zero and social value, including the the elimination of modern slavery. From April 2022, all NHS organisations adopted PPN 06/20 and NHS England has provided specific guidance on how to apply the Social Value Model to healthcare settings.

Our safeguarding accountability and assurance framework (SAAF) sets out the safeguarding roles and responsibilities of all individuals working in providers of NHS-funded care settings and NHS commissioning organisations. It supports the NHS by providing guidance and minimum standards.

4. Risk assessment and management

Working with NHS Supply Chain, NHS England completed a review of the risk of modern slavery within NHS supply chains on behalf of the Secretary of State, meeting a commitment of the Health and Care Act (2022), Section 47. The review provided a snapshot of the risk of modern slavery across some 1,300 suppliers and 600,000 products on the NHS Supply Chain catalogue. The recommendations for improvement set out in the review will now be taken forward in partnership between NHS England, DHSC and NHS Supply Chain. Early progress has prioritised actions to:

  • support DHSC to draft the new regulations
  • draft new NHS guidance in collaboration with DHSC
  • procure a risk assessment tool for the NHS
  • update the NHS Terms and Conditions for Goods and Services

To support the NHS to undertake a more efficient and consistent approach to risk assessing procurements in line with PPN 02/23 requirements, we are developing a risk assessment tool to build into Atamis, the NHS-wide e-commerce system. Awareness of how to apply the risk information will be supported through engagement activities, including the NHS’ internal Sustainable Procurement Forum, which convenes sustainability, clinical and procurement professionals across the NHS and meets quarterly.

5. Effectiveness

We are committed to the following actions to further improve our effectiveness for the coming year:

  • establish guidance to support the NHS to implement new regulations, taking a risk-based approach to increased supply chain due diligence, monitoring of performance and managing supplier non-compliance
  • ensure modern slavery provisions in the NHS Terms and Conditions for the Procurement of Goods and Services address supplier disclosure, monitoring, remediation and consider continuity of supply
  • establish robust and consistent risk identification methodology to support a standard approach to product level risk management
  • build risk process into the NHS-wide e-commerce system (Atamis)
  • identify opportunities to support a centralised approach to modern slavery risk assessment and mitigation
  • develop a plan to upskill NHS staff and the supply chain on modern slavery risk and the new processes
  • establish a robust and streamlined approach to supply chain mapping to increase transparency and insight including opportunities for auditing aligned with international standards and reporting platforms to mitigate cost and burden for suppliers
  • continue to engage with NHS organisations through NHS England’s regular sustainable procurement forums, workshops, webinars and other events to increase awareness of modern slavery risks and help to upskill our stakeholders

6. Training

All staff are required to complete a number of compulsory training modules, with awareness of modern slavery addressed through Safeguarding Children and Adults Level 1. Additional safeguarding support tools have been developed for staff groups from safeguarding leads through to the wider healthcare profession.

Evidence has shown that when victims present in healthcare services, healthcare professionals are not always equipped to know how best to support them. To help staff to recognise and respond to suspected incidents of modern slavery within the NHS, new e-learning has been created for NHS safeguarding leads. The training supports them to provide calm, clear and strategic leadership for complex cases and enables them to offer the appropriate support to frontline healthcare professionals.

The intercollegiate Adult Safeguarding: Roles and Competencies for Health Care Staff supports healthcare professionals to identify the knowledge and skills needed for safeguarding including modern slavery, setting out 5 competence levels for practitioners. Training support tools developed include:

Level 1: A free NHS safeguarding app providing an easy-access source of guidance on types of abuse, exploitation and neglect including modern slavery.

Level 2+: The NHS Learning Platform provides background and updates on safeguarding and trauma-informed practice, signposts clinicians and practitioners to the Modern Slavery Helpline for advice and provides guidance when to contact a first responder.

Level 3+: Safeguarding webinars and ‘learning together weeks’ hosted on the NHS safeguarding workspace.

We work collaboratively across government and take a public health approach to the prevention of modern slavery and the protection of the health and wellbeing of survivors, raise wider awareness and ensure consistency of approach. Further details can be found on our website.

Jacqui Rock, Chief Commercial Officer, NHS England
March 2024