Modern slavery and human trafficking are criminal offences under the Modern Slavery Act 2015.
Our board agreed this updated modern slavery and human trafficking statement in October 2023.
Modern slavery and human trafficking are incompatible with our values. These include being caring and acting with integrity. We fully support the government’s objective to eradicate modern slavery and human trafficking.
This statement clarifies our role in tackling modern slavery and human trafficking. It covers:
- how health and social care services protect victims of modern slavery or human trafficking
- how we ensure modern slavery or human trafficking are not present in our supply chains.
See our policy position on modern slavery and unethical international recruitment for details of the regulatory action we will take when we identify concerns relating to these issues in services we regulate.
Modern slavery and human trafficking
Modern slavery and human trafficking are criminal offences under the Modern Slavery Act 2015. The act includes the crimes:
- knowingly holding a person in a position of slavery, servitude, forced or compulsory labour
- facilitating their travel with the intention of exploiting them during or soon after.
Modern slavery and human trafficking can take place in a wide range of employment sectors, including health and social care. People using or working in a health and social care services may be victims of modern slavery or human trafficking. Health and social care organisations have a role in identifying victims who come to them for care or treatment.
We recognise our responsibility as:
- the independent regulator of health and adult social care in England
- a large organisation employing more than 3,000 staff and procuring external services.
We are not legally obliged to publish a statement on modern slavery and human trafficking under the Modern Slavery Act (2015). But as a public sector body we must operate in ways that are compatible with the Human Rights Act (1998). These rights include the right for people to be free from slavery and forced labour under Article 4 Article 4 Human Rights Act 1998. We also have a duty to report criminal activity.
We have a responsibility to protect victims and a duty to report criminal activity.
Publishing this statement, and taking the actions we describe, helps us fulfil these duties.
Why modern slavery and human trafficking are relevant to CQC
- All health and care services have a role to play in supporting victims of modern slavery and human trafficking. We check these services have systems and processes to identify abuse and safeguard people from harm. People who are enslaved or trafficked should have the same high-quality care as any other person and be protected from abuse.
- We may find modern slavery happening in the services that we regulate or in associated services. These could be recruitment agencies or contractors.
Procurement and our supply chain
We employ over 3,000 staff and our total income in 2021/22 was £236.1million. We have a responsibility to ensure our supply chains, procurement and business activities are free from ethical and labour standards abuses.
Our commercial strategy includes the following steps to prevent modern slavery and human trafficking. We review this regularly.
- When we procure goods and services, we comply with UK legislation and government policies. We also apply our contract terms and conditions relating to modern slavery and human trafficking. These are in line with government policy thresholds and relate to the value and type of goods, services and commodities required.
- Organisations with a financial turnover under £36 million are exempt from producing a modern slavery and human trafficking statement. But we still encourage exempt organisations to produce a statement and submit this to us as part of their bids.
- We apply rigorous testing at the tendering stage and when auditing key suppliers. This determines if a supplier and its supply chain are adhering to our standards.
- We monitor how our suppliers comply with contract clauses that we have added about modern slavery and human trafficking. This is part of our key performance indicators and contract management.
- Preventing modern slavery and human trafficking is included in our commercial strategy. We review this regularly.
- We train all our procurement colleagues to apply good practice in preventing modern slavery and human trafficking and promoting social value as key tests. We train contract managers to monitor compliance with our terms and conditions at the point of contract handover.
- Our policies will enable us to respond proactively to amendments to the Modern Slavery Act. This is likely to extend the scope of the current Act to public sector bodies and strengthen procurement legislation. When the Department of Health and Social Care has reviewed the risk of slavery and human trafficking in NHS supply chains, we will also be able to take any action needed.
Public procurement is how organisations in the public sector, such as CQC, purchase goods and services from the private sector. It presents a huge opportunity to address modern slavery in supply chains. Read the blog Public procurement – key for addressing modern slavery in supply chains (Modern slavery and human rights, Policy and Evidence Centre).
We confirm the identities of all our new employees and their right to work in the UK. We also pay all our employees the National Living Wage or above.
Our Flexible Workforce Office manages sessional workers such as specialist advisors and ‘bank’ (temporary) inspectors. They also undertake recruitment checks of identity and employment records.
All colleagues can use CQC’s e-learning resource for training to raise awareness of modern slavery and human trafficking.
We support colleagues to raise concerns about poor working practices through our:
- bullying and harassment, grievance, and Speak Up policies
- work with recognised trades unions
- staff and equality networks
- Freedom to Speak Up Guardian and Freedom to Speak Up ambassadors
- Colleague Support Officers
- occupational health services, including a confidential employee assistance programme.
Our safehouse and outreach support inspection programme
As requested by the Home Office Modern Slavery Unit and the Independent Anti-Slavery Commissioner, we carry out a programme of inspections of safehouse and outreach support services in England and Wales, which started in January 2021. These focus on services provided under the Modern Slavery Victim Care Contract (MSVCC). This is part of a complex system of support for survivors of modern slavery and human trafficking.
Providing safehouse and outreach services is not a regulated activity so we only have the powers to inspect for this work. This means we have no enforcement powers and we cannot register these service providers. However, we report back to the Home Office on the findings of our inspections. If we find a significant concern, we escalate this to the Home Office.
We will continue to inspect and report on support services for confirmed and suspected victims of modern slavery and human trafficking in England and Wales. Our Memorandum of Understanding with the Home Office currently runs until June 2025.
Information about how we work with other agencies when we have concerns about modern slavery and human trafficking in our regulatory work are given in our Policy position on modern slavery and unethical international recruitment.
We will continue to develop our response to modern slavery and keep this statement under review.