Policies and Procedures
We do not have a stand-alone modern slavery policy (in respect of Section 54 of the Modern Slavery Act). Modern slavery is covered under our Public Protection Procedures. This and the coverage of modern slavery within all of our policies will form part of our continuous improvement action plan, and we are also in the process of mapping all of our policies and procedures.
Risk Assessment Prevention and Mitigation
The responsibility for risk management within the force is managed on a “threat and risk” basis. Modern slavery is managed at an operational level through local to regional and national risk assessment, and the tasking and co-ordination process. Internally we acknowledge that this is an area for development. The risk of modern slavery within our workforce is deemed to be low. The risk is higher along the supply chain.
We use the Government Modern Slavery Strategy called the 4Ps:
As we develop our action plan to include the internal processes described, we will be developing the 4Ps strategy to include plans for HR, procurement and Business Engagement.
Currently there is a risk assessment process whereby we inform our suppliers of our terms and conditions. Once the suppliers have accepted these terms and conditions, we do a risk assessment of the most highrisk companies.
These are then categorised by spend and risk, ranked using a variety of methods including the audits done and stored in SEDEX and other organisations. From this, we prioritise them into a smaller group of suppliers, which may need further investigating.
This review of our modern slavery activity has provided the opportunity to conduct a modern slavery risk assessment across all our procurement functions, and will form part of our continuous improvement action plan. We would like to have full understanding of the risks in our own operations as well as an understanding of the risks in our supply chain.
As with all policing activity we intend to take a proportionate response to this action, so that we are able to focus on priority risk, which will depend on a range of factors such as spend, geographical location, type of workforce, business sector and the enduring relationship that exists with each supplier.
In completing this piece of work, we intend to engage with internal and external stakeholders as well as worker organisations and trade associations to ensure that we understand all the modern slavery risks.
At present we do not have an overarching Modern Slavery Strategy or standalone policy in respect of Section 54 of the Modern Slavery Act. As part of our continuous improvement action plan, the area of a modern slavery due diligence strategy will be developed and reviewed according to risk.
There is an enhanced vetting procedure in Derbyshire Constabulary which has the natural consequence of reducing the risk of employing a person vulnerable to modern slavery within our organisation. Every member of staff, temporary, permanent voluntary or sub -contracted, has to be vetted to “Recruitment Vetting” (RV standard).
The right to work and national vetting policy applies to everyone hired by the force, and other checks may be applied depending on the role under consideration. The degree of vetting depends on the type and the level of the role, but all staff are vetted to the same standards as a police recruit. Vetting is still applied for people hired through recruitment agencies.
The lowest level of vetting is RV vetting for police officers, with character references from previous employers for the past three years, medical and drugs testing, biometrics e.g. DNA and fingerprints. Pre-join induction packs are sent out electronically to candidates before joining. It includes a code of ethics, the values of employer and information they need before they join.
Procurement and estates team requirements have to go through a similar and recognised process of vetting during the tendering process. The process does review the sub-contractors used as well as the principal contractor.
The vetting process is applied to all sub-contracted staff and agency staff used by sub-contractors, which again reduces the risk. There has been no due diligence on the recruitment agency in respect of modern slavery specifically, which will now be included in the continuous improvement action plan.
Our supply chain has a core spend with a few multi-nationals and a large number of small spend organisations. We are committed to the premise of ensuring scrutiny on public money spending with the right checks and balances to address modern slavery. We have completed a formal review of 250 suppliers by means of a standard questionnaire (at least eight questions) which includes the Home Office questions on modern day slavery.
There is a set of terms and conditions reinforcing how suppliers should and should not act. We do not currently know what due diligence suppliers themselves do relating to modern slavery. No checks are made against a company under £25,000 if they have no employees going on site.
There are four people in the procurement team, looking after the principle contracts, anything over £25k, but at present there is not a modern slavery due diligence programme and we acknowledge that operational practices need to be reviewed and changed to minimise modern slavery risks.
We do engage with suppliers and utilise their audit information and we will review their modern slavery audit programme and work together to establish better modern slavery engagement. We are now looking to improve our understanding of the grievance mechanisms and methods of accessing remediation along our supply chains for victims of modern slavery.
We also want to help businesses to ensure that they have incident response plans to support victims in the event of the discovery of modern slavery. As a policing organisation with resources, networks, collaborations and victim care services, we feel that this an area that we can improve on and offer guidance to assist businesses.