Our commitment to addressing modern slavery.
This statement sets out the commitment and intended actions of the College of Policing to address modern slavery through our business activities and supply chains. This statement is made in accordance with the Modern Slavery Act 2015 and relates to the financial year ended 31 March 2022.
Modern slavery exists in almost every part of the global economy. Victims are exploited by criminals for profit, often in seemingly legitimate businesses. This hidden workforce produces some of the goods and services we use every day.
To hold an individual in slavery is a violation of fundamental human rights and a crime. The College recognises this takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another for the purposes of exploiting them for personal or commercial gain.
The College of Policing (the 'College') was established as a company limited by guarantee on 1 October 2012 as the professional body for policing in England and Wales, with the Home Secretary as its sole member (equivalent to shareholder). It is an arm’s-length body of the Home Office.
The College operates from offices in Coventry, County Durham, London (Vauxhall) and Harrogate. At 31 March 2022, we employed 611 staff, 17 agency/contract staff and 69 inward secondees. We also engaged 918 associates.
The College turnover is in excess of £36 million each financial year and it treats the threat of modern slavery as a matter of the utmost importance.
Our supply chains
The College takes a zero-tolerance approach to modern slavery. It is committed to acting ethically and with integrity in all its business dealings and relationships and in implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in its UK business operations or in any of the College’s supply chains.
We recognise that we have large and complicated supply chains across the UK. We have non-pay expenditure of over £31 million and buy various products and services from approximately 360 different suppliers (based on 2021/22 information, excluding associates and secondees spend). It is here where we focus and prioritise our modern slavery procurement best practice skills and focus, using the guidance and tools developed by the Government Commercial Function and the Home Office.
We are committed to working in partnership with our suppliers to support and challenge them on their response to modern slavery. We will ensure our progress is open and transparent, reporting where we have been successful and where we still have opportunities to improve. We welcome and endorse the commitments made in this statement and will closely monitor the progress.
Our policies on slavery and human trafficking and work undertaken in 2021/22
Guidance on how to recognise and respond to the signs of modern slavery are in development together with the College’s anti-modern slavery and human trafficking policy. This sets out how the College aims to prevent, detect and report modern slavery in any part of its business or supply chains.
We aim to ensure that slavery and human trafficking are not taking place in the College, or our supply chains, as follows.
- All of the College’s directly employed staff are on standardised terms and conditions, which include an explicit commitment to the national minimum wage.
- All agencies who supply the College with staff are contractually bound to pay the national minimum wage and provide verification of the identity and right to work of their staff.
- All Chartered Institute of Procurement and Supply (CIPS) qualified members of the procurement team have undertaken CIPS Ethical Procurement and Supply e-learning. All significant service/goods contracts are overseen by the College’s procurement team and include a commitment to, and evidence of, compliance with the Modern Slavery Act within the tender and award process. As part of the College’s contracting processes, it expects that its suppliers will hold their own suppliers to the same standards as set out in our policy.
- Managers (with advice and guidance from the College’s People and Organisational Development unit) are responsible for ensuring all staff training and development needs are met, including around the identification and reporting of concerns around modern slavery. The College has a Reporting Concerns (whistle-blowing) policy, which protects whistle-blowers from reprisal and provides a channel to report wrongdoing.
- The College has a diversity, equality and inclusion (DEI) strategy and policies to ensure that the College meets its legal requirements to comply with the Equality Act 2010. Online training on DEI is provided, together with a programme of supplementary training to ensure staff are aware of their responsibilities under the Act.
- All staff and third parties are required to raise any concerns about any issue or suspicion of modern slavery in any parts of the College’s business or supply chains at the earliest possible stage. The College encourages openness and will support anyone who raises genuine concerns in good faith under its Anti-Modern Slavery Policy and Human Trafficking Policy, even if they turn out to be mistaken. The College is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of the College’s supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If any staff believe they have suffered any such treatment, the individual is encouraged to inform either their manager or the People and Organisational Development unit immediately and to report the matter to the proper authorities.
Our plans for the future
The College is committed to better understand its supply chains and will work towards greater transparency and responsibility towards people working in them. We will continue to:
- review contracts to ensure modern slavery clauses are included and that due diligence processes are in place to minimise the risk of modern slavery
- encourage and support suppliers to ensure their supply chain has measures in place
- embed social value criteria into relevant tender evaluations
- target our action where it can have the most impact by prioritising the risks
Statement of compliance
The board of directors has overall responsibility for ensuring the College’s anti-modern slavery and human trafficking policy complies with the College’s legal and ethical obligations, and that all staff and third parties under its control comply with it.
Through our work, we can confirm that, to our knowledge, we have met our responsibilities under the Act. We will continue to review our approach in relation to the Act and incorporate best practice into our policies, procedures and contractual arrangements.
This statement was approved by the board of directors on 20 July 2022 and signed by the board Chair, Lord Herbert of South Downs.