NHS Kent and Medway (NHS KM) is committed to upholding the highest standards of ethical conduct and ensuring that modern slavery and human trafficking have no place in our operations or supply chains.

This statement sets out the steps we are taking to identify and prevent modern slavery, forced labour, and human trafficking, in accordance with the UK Modern Slavery Act 2015 and other applicable legislation.

Definition of offences

Modern day slavery, servitude, forced or compulsory labour

A person commits an offence if the person:

  • holds another person in slavery or servitude and the circumstances are such that person knows or ought to know that the other person is held in slavery or servitude
  • requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.

Human trafficking

A person commits an offence if:

  • the person arranges or facilitates the travel of another person (victim) with a view to being exploited
  • it is irrelevant whether the victim consents to travel and whether or not the victim is an adult or a child.

Exploitation

A person is exploited if 1 or more of the following issues are identified in relation to the victim:

  • slavery, servitude, forced or compulsory labour
  • sexual exploitation
  • removal of organs
  • securing services by force, threats and deception
  • securing services from children, young people and vulnerable persons.

Our business and structure

As an authorised statutory body, NHS KM Integrated Care Board is the lead commissioner for health care services (including acute, community, mental health and primary care) in Kent and Medway. The Membership, Governing Body, Executive Team and all employees are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and in so far as is possible to holding our suppliers to account to do likewise.

Our commitment

NHS KM are committed to preventing modern slavery and human trafficking within our business and our supply chains. Our overall approach is governed by compliance with legislative and regulatory requirements and the maintenance and development of best practice in the fields of contracting and employment. NHS KM recognises safeguarding as a high priority for the organisation, ensuring arrangements are in place to provide strong leadership, vision and direction for safeguarding. We make sure we have clear accessible policies and procedures in line with relevant legislation, statutory guidance and best practice. 

Our approach

Policies and arrangements

NHS Kent and Medway has in place the relevant policies to support the modern slavery human trafficking agenda; this includes:

  • safeguarding adults and children policy
  • freedom to speak up - including freedom to speak up guardians
  • managing allegations policy
  • recruitment and selection policy
  • temporary staffing (Standard Operating Procedure)
  • study leave policy
  • equality, health inequalities and quality impact assessment policy
  • anti-fraud, bribery and corruption policy
  • procurement policy.

Procurement

Our procurement approach follows the crown commercial service standard. When procuring goods and services, we apply NHS Terms and Conditions (for non-clinical procurement) and the NHS Standard Contract (for clinical procurement). Both require suppliers to comply with relevant legislation.

Recruitment

NHS Kent and Medway is committed to ensuring equality of access to employment and training opportunities and is committed to eliminate unlawful and unfair discrimination and ensure that all groups and individuals within the community benefit through having equal access to employment opportunities provided.

NHS Kent and Medway has recruitment processes in place to make sure we do not employ anyone without the correct right to work documentation. All external candidates are requested to produce documents confirming their right to work in the UK. The organisation will also verify an applicant's identity to ensure it is genuine and that the individual has the right to use that identity.

Risk assessment

We recognise that modern slavery and human trafficking can be hidden and difficult to identify. As part of our ongoing commitment, we conduct a regular risk assessment to understand the specific risks of modern slavery within our operations and supply chains. This involves.

  • Reviewing the industries and countries in which we operate.
  • Conducting supplier audits and assessments.
  • Engaging with suppliers to ensure they adhere to ethical labour practices.

Due diligence and supplier expectations

We have implemented a robust due diligence process to assess potential risks related to modern slavery and human trafficking in our supply chains. This includes:

  • Requiring suppliers to complete a supplier questionnaire, which asks about their policies and practices regarding modern slavery and human trafficking.
  • Establishing contracts with suppliers that include clauses on compliance with modern slavery legislation and human rights standards.
  • Conducting regular checks to ensure compliance, including site visits and audits where necessary.

Training and awareness

We are committed to educating and raising awareness among our staff and key stakeholders about the risks of modern slavery and human trafficking. We provide regular training on recognising and addressing these issues to:

  • Employees involved in procurement, human resources, and compliance.
  • Senior management and staff responsible for decision-making within the business.
  • Fraud awareness training via TIAA

Our actions in 2025

Over the past year, we have taken the following steps to combat modern slavery and human trafficking:

  1. Committed to our Modern slavery human trafficking statement.
  2. Staff Training: Conducted training sessions for employees on how to spot signs of modern slavery and human trafficking.
  3. Partnerships: We have partnered with organisations and experts who specialise in identifying and addressing human trafficking risks, including Kent County Council MSHT leads.

Looking forward 

  • Continuing to provide expert support and advice, via NHS Kent and Medway designated safeguarding leads, into the commissioning process and supporting multiagency work to respond to modern slavery and human trafficking.
  • Continuing to work with NHS-funded and partner organisations to ensure modern slavery and human trafficking are appropriately prioritised and feature prominently in safeguarding work plans.
  • Continue educating our staff and suppliers to raise awareness of modern slavery and human trafficking.

Conclusion

At NHS KM, we take modern slavery and human trafficking very seriously and strive to ensure that these practices are not present in any part of our business or supply chain. We will continue to review and improve our efforts to combat modern slavery and promote the dignity and rights of every individual involved in our operations.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our organisation's modern slavery and human trafficking statement for the current financial year. 

This statement has been approved by the Executive Management Team and it is reviewed annually to ensure its effectiveness.