Modern Slavery and Human Trafficking Statement 2021 to 2022

Introduction

In 2021, the Government introduced legislation that was extended to cover public sector organisations in England and Wales with a budget of at least £36 million or more per year to publish its own modern slavery statement setting the steps Nottinghamshire Police and the Office of the Police and Crime Commissioner (OPCC) are taking to prevent modern slavery in our supply chains.

In line with our Modern Slavery Policy, Nottinghamshire Police and the OPCC are committed to reducing the threat and harm associated with human trafficking and to provide the best service to those affected by these crimes, whilst recognising individual needs and being sensitive to community and cultural issues.

Nottinghamshire Police and the OPCC, as a policing service, occupy a unique position in relation to Modern Slavery. As a police service we have an obligation to prevent and detect crime, including those crimes related to Modern Slavery and also an obligation to protect vulnerable people, including those who are at risk of or affected by Modern Slavery.

• As a police service we are a statutory First Responder for the National Referral Mechanism; the framework for identifying and referring potential victims of modern slavery and ensuring they receive the appropriate support (National referral mechanism guidance: adult (England and Wales) - GOV.UK (www.gov.uk))
• As an organisation we are primarily a direct employer, however we also utilise contractors or agencies to provide staff for specific roles
• As an organisation we are a consumer of commercial goods and services
• As an organisation we are, in limited circumstances, a provider of commercial services

This statement considers the obligations placed on commercial organisations under section 54 (1) of the Modern Slavery Act 2015 and sets out Nottinghamshire Police and the OPCC's actions to understand potential modern slavery risks related to our organisation as an employer and as a consumer; identifying tactics intended to remove any modern slavery present in our organisation or supply chain.

The Modern Slavery Act 2015 defines Modern Slavery (Sec 1 ), Human Trafficking (Sec 2) and Exploitation (Sec 3). For the purposes of this statement Nottinghamshire Police and the OPCC will adopt these definitions.

Any reference within this policy to 'Modern Slavery', unless specified otherwise, will be a reference to Modern Slavery, Human Trafficking and associated exploitation in all its forms, either detailed above or subsequently identified.

Organisational Structure, Business and Supply Chains

This statement covers the activities of Nottinghamshire Police and the OPCC, including all staff, volunteers and agency workers. In addition, this also covers the services delivered on behalf of Nottinghamshire Police and the OPCC by third party organisations and their supply chains. Nottinghamshire Police and the OPCC will work with statutory and voluntary partners at a national and local level in taking a consistent and positive approach in tackling all aspects of human trafficking.

Policies in relation to slavery and human trafficking

The following policies and procedures sets out our response to Modern Slavery within our organisation: 

• College of Policing Code of Ethics - The Code of Ethics provides principles and standards of behaviour expected from everyone who works in policing, supported by our professional body the College of Policing. The 9 policing principles covered by the Code of Ethics are: Accountability; Fairness; Honesty; Integrity; Leadership; Objectivity; Openness; Respect and Selflessness
• Nottinghamshire Police and the OPCC Human Trafficking Modern Slavery Policy - details the organisational response to policing Modern Slavery in all its forms
• National Referral Mechanism procedure - this provides a step-by-step guide when entering a potential victim of trafficking into the National Referral Mechanism
• Nottinghamshire Police Delivery Plan 4P - details the approach to be taken when investigating this crime type under prepare, pursuit, prevent and protect
• Professional Standards Reporting Procedure - details the mechanisms through which individuals can report breaches of professional standards, including the opportunity to report in confidence or through other organisations
• Business Interests Policy and Procedure - sets out the framework for the application and approval of business interests outside Nottinghamshire Police, undertaken by police officers, special constables and police staff or applying to such a role
• Recruitment and Selection Policy - details the organisational recruitment processes including pre-employment checks and vetting for new employees, officers and volunteers
• Vetting Policy - details the organisational decision to adopt the College of Policing Authorised Professional Practice (APP) in relation to vetting activities
• OPCC Financial and Contract Regulations - details the requirement to comply with Public Contracts Regulations, procurement thresholds, tendering and contract management processes
• Procurement Strategy - sets out the strategic objectives of the Contracts and Procurement Team including a commitment to Sustainable, Ethical and Compliant Procurement
• OPCC Safeguarding Through Commissioning Policy - sets out the OPCC responsibilities as a commissioner and co-commissioner of services facilitating the wellbeing and safeguarding of children, young people and adults at risk

Due diligence processes

Nottinghamshire Police and the OPCC undertakes due diligence during the tender process, and dependent on value and/or criticality of a contract there will be periodic due diligence applied during the life of a contract as part of effective contract management. Due diligence is undertaken in line with the Public Contract Regulations, the Standing Orders, the OPCC's Safeguarding through Commissioning Policy and the Procurement Strategy.

Due diligence activities include but are not limited to:

• Tender Evaluation
• Application of Terms and Conditions
• Declaration of Conflict of Interest for Bidders (at point of tender and annually from the date of award)
• Modern Slavery and Ethics Declaration (at point of tender and annually from the date of award)
• Working with selected first tier suppliers to jointly assess their supply chains
• Review of safeguarding policies where applicable

In line with the Recruitment and Selection Policy Nottinghamshire Police and the OPCC undertake due diligence when recruiting new members of staff including but not limited to:

• completing 'right to work' checks,
• interviews or other selection processes
• role appropriate vetting

All Nottinghamshire Police and the OPCC staff, officers and volunteers are subject to ongoing vetting reviews.

Risk assessment and management

Any Modern Slavery concerns identified by a member of Nottinghamshire Police and staff of the OPCC, officers and volunteers should be reported immediately, however it is recognised that concerns may arise for a variety of reasons.
Police officers, staff, staff of the OPCC and volunteers should record concerns in line with incident and crime recording policies.

Those involved within recruitment and procurement activities, should report any concerns to their line manager; where this is not possible or where there are immediate concerns for the safety of any person these concerns should be reported to the force control room immediately.

The strategic and tactical modern slavery leads or officers trained as modern slavery specialist investigators are available to provide advice in relation to modern slavery concerns which do not require an immediate response. Their details are available on the force intranet.

Staff and volunteers who are not trained to undertake modern slavery investigations should not do so without seeking advice from an appropriately trained officer. This does not prevent officers, staff, staff of the OPCC and volunteers taking immediate action to prevent and detect crime, preserve life of or protect vulnerable people.

Support Services

The OPCC has a responsibility to commission support services to help victims of crime recover from harm. This includes victims of modern slavery. The OPCC will work with Nottinghamshire Police and partners to identify and meet gaps in local support service provision.

Key performance indicators to measure effectiveness of steps being taken

Nottinghamshire Police and the OPCC provide regular scrutiny to all modern slavery and organised immigration crimes under investigation by the Modern Slavery, Human Trafficking and Organised Immigration Crime Unit (MSOICU) through monthly management meetings and a force tasking process.

The monitoring of National Referral Mechanism's submissions and the management of those to support victims of modern slavery is conducted by the MSOICU and reported on monthly to the force Chief Officer team via the force tasking process.

Training on Modern Slavery and Human Trafficking

Nottinghamshire Police have a dedicated Modern Slavery and Human Trafficking team made up of a Detective Sergeant and Detective Constables trained as modern slavery specialist investigators. They have received specific training to a national standard to enable them to effectively investigate modern slavery offences.

Nottinghamshire Police are part of a pilot scheme to provide care and support to victims of modern slavery and human trafficking via a Victim Navigator. This Victim Navigator also provides training and support to frontline officers and investigators across Nottinghamshire Police to ensure all early contact with victims is appropriate and robust.

Nottinghamshire Police contribute to the Multi Agency Safeguarding Hub where officers, staff and partner agencies are available to receive and assess any referrals relating to adult or child safeguarding concerns.

Nottinghamshire Police contribute to the Slavery and Exploitation Risk Assessment Conference owned and chaired by Nottingham City Council where staff and partner agencies receive and assess any referrals relating to specific cases of exploitation.

All new Police Officers and Police Community Support Officers are provided with modern slavery awareness training.

The Nottinghamshire Police intranet provides information on Modern Slavery, including a national guide to Modern Slavery Initial Responses and local reporting pathways. This is available to all officers, staff and volunteers.

Officers transferring to investigative roles through the Initial Crime Investigators Development Programme, Detective Development Portfolio or equivalent programme receive additional training in Modern Slavery within these programmes.

Modern Slavery continuing professional development training opportunities are communicated to officers and staff when available, including training opportunities provided through partner agencies or in support of local/national operational activity.

In 2021 Nottinghamshire Police launched their Modern Slavery app on all police mobile devices to support and provide guidance to frontline officers, investigators and staff when dealing with modern slavery offences and foreign nationals. This also contains a step-by-step guide to the National Referral Mechanism.

Declaration

This statement constitutes Nottinghamshire Police and OPCC's Modern Slavery and Human Trafficking statement for the financial year ending 31 st March 2022.

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For a PDF version of this statement please download the below.