Modern Slavery & Human Trafficking Statement

Modern Slavery and Human Trafficking Statement
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. It serves as Salisbury NHS Foundation Trust’s (SFT) official statement on slavery and human trafficking for the financial year ending 31 March 2025.

In line with NHS England’s Group Statement on modern slavery and human trafficking, this document outlines the steps SFT has taken — and continues to take — to prevent modern slavery and human trafficking within the Trust and its supply chains.

1. Organisational Structure and Supply Chains

SFT provides a wide range of clinical services to a population of over 270,000 people across Wiltshire, Dorset, and Hampshire. Our core business is the provision of acute and specialist healthcare, supported by a complex supply chain essential for delivering high-quality patient care.

Our supply chains include the procurement of:

• Clinical goods and services: medical equipment, pharmaceuticals, and surgical instruments.
• Non-clinical goods and services: including high-risk sectors such as construction, facilities management (e.g. cleaning, catering), IT equipment, and textiles (e.g. uniforms, bedding).

Modern slavery encompasses slavery, servitude, human trafficking, and forced labour. SFT adopts a zero-tolerance approach to all forms of modern slavery. We are committed to acting ethically and with integrity in all our business dealings. We recognise our responsibility to understand the risks within our supply chains and to work collaboratively to mitigate them — including with partners in the Bath and North East Somerset, Swindon and Wiltshire Integrated Care System (BSW ICS).

2. Policies in Relation to Modern Slavery and Human Trafficking

We are committed to ethical practices and take all reasonable steps to prevent modern slavery and human trafficking across our operations and supply chains. Our policies are designed to meet the diverse needs of our patients, staff, and wider community, while ensuring our suppliers uphold the same values.

Our Procurement Policy includes specific clauses requiring compliance with the Modern Slavery Act 2015. Awareness of modern slavery is embedded within our safeguarding policies, and all staff are required to report any concerns, which are addressed through appropriate procedures.

This commitment is reflected in the following key Trust policies:

• Procurement Policy
• Adult Safeguarding Policy
• Safeguarding Children and Adults Training Policy
• Overseas Visitors’ Policy

3. Due Diligence Processes

To identify and mitigate risks in our operations and supply chains, we have implemented a comprehensive due diligence framework. This includes:

• Collaborating with NHS Supply Chain and partners to ensure suppliers are selected via robust criteria.
• Expecting suppliers to endorse the BSW ICS Supplier Charter and its mission to deliver ethical and strategic procurement.
• Including human rights clauses, as per NHS Terms and Conditions, in all relevant procurement and tender documents.
• Evaluating tender specifications with consideration for ethical sourcing and social value.
• Using NHS contract templates to ensure modern slavery clauses are embedded in all supplier agreements.
• Encouraging suppliers and contractors to take responsibility for compliance within their own operations.
• Adhering to professional procurement codes of conduct.
• Requiring staff to engage with the Procurement team when appointing new suppliers, to ensure appropriate checks are conducted.
• Operating a robust recruitment policy, incorporating pre-employment checks aligned with national NHS Employment Checks/Standards on directly employed staff, potential employees, bank workers, volunteers and governors.
• Ensuring that all agency workers adhere to the NHS Employment Checks/Standards prior to commencing in the Trust. Assurance is given by temporary staffing checking documentation submitted by the agency against a checklist.
• Implementing controls to protect staff from poor treatment or exploitation, including fair pay, employment terms, and access to training.
• Engaging with Trade Unions and staff-side representatives on employment matters.
• Maintaining systems to encourage reporting of concerns, including a Whistleblowing Policy.
• Promoting the Freedom to Speak Up Guardian and Ambassadors, enabling staff to report concerns without fear.
• Reporting regularly to the Trust Board on Freedom to Speak Up cases, including the categories of concern raised.

4. Risk Assessment and Management

SFT employs a data-driven, risk-based approach to modern slavery risk within its supply chains.

The Procurement team uses the national Atamis platform to assess the risk level associated with different spend categories — classified as high, medium, or low. Where risks are identified, the team uses the Evergreen Portal to determine whether suppliers have completed the Modern Slavery Risk Assessment Tool (MSRAT). Responses are used to guide follow-up actions as part of contract management.

Contract management is currently being implemented, with an initial focus on our “Gold” tier suppliers — contracts with high risk, complexity, or value.

As part of our tender process, suppliers for contracts exceeding £139,000 must confirm whether they have a Modern Slavery Act Statement. This requirement is built into our standard contract terms and conditions.

5. Key Performance Indicators (KPIs) to Measure Effectiveness

SFT is dedicated to monitoring the impact of its actions through clearly defined key performance indicators.

A key KPI that the Trust is working towards is to ensure that at least 90% of staff complete the mandatory Level 1 Adult Safeguarding Training, which includes modern slavery awareness.

All members of the Safeguarding Team complete Level 3 training. Level 1 training is required only for non-patient-facing staff, while all patient-facing staff are required to complete Level 2 training.

A broader KPI framework is in development. Over the coming year, we will define and implement new indicators to improve tracking, accountability, and continuous improvement.

The rollout of Atamis will further strengthen our oversight, allowing enhanced visibility of modern slavery risks across procurement categories and supporting data-driven supplier engagement and contract management.

6. Training and Capacity Building

All staff have a personal responsibility to help prevent modern slavery and human trafficking. Guidance and training are provided through our safeguarding framework and are accessible to all staff.

6.1 Mandatory Training for All Staff

Modern slavery awareness is part of the Level 1 Adult Safeguarding Training and includes:

• Types of modern slavery (e.g. forced labour, debt bondage, human trafficking)
• How to recognise potential victims
• How to report concerns
• How to support potential victims

6.2 Ongoing Resources

Resources available via the Trust’s intranet include:

• Definitions and types of modern slavery
• Who may be affected
• What to do if you suspect someone is a victim
• Information on NHS Employment Checks, including right to work, address verification, and reference checks

6.3 Procurement Team Training

In 2025/26, the Procurement team will continue promoting ethical practices by:

• Participating in CIPS Corporate Ethics Training
• Encouraging staff to complete the annual CIPS Ethics Test
• Ensuring adherence to the CIPS Code of Ethics
• Repeating the ‘Lunch and Learn’ awareness session later in the year

Confirmation

This statement has been reviewed and approved by the Trust's Board of Directors

It will be reviewed and updated annually in line with our legal obligations and ongoing commitment to preventing modern slavery and human trafficking.

4 September 2025