Strategy, Finance & City Regeneration Committee

Agenda Item 32


Subject:                          Brighton & Hove City Council 2022/2023 Modern Slavery Statement 


Date of meeting:      13 July 2023


Report of:                 Executive Director Governance People & Resources


Contact Officer:      Name: Dr Akilah Jardine

                                    Tel: 07815473201 



Ward(s) affected:   All


For general release



1.            Purpose of the report and policy context


1.1         The purpose of this report is to seek the Strategy, Finance & City Regeneration Committee’s approval of Brighton & Hove City Council’s 2022/2023 Modern Slavery Statement.


1.2         The Modern Slavery Statement is an annual statement outlining actions that have been taken in the previous financial year to address modern slavery within their operations and supply chains.


2.            Recommendations


2.1         That Committee approves the Modern Slavery Statement (see Appendix 1)


3.            Context and background information


3.1         Modern slavery is an umbrella term used to describe situations of exploitation where people are exploited for financial gain. It refers to situations a person cannot refuse or leave because of threats, violence, coercion, deception and/or abuse of power and vulnerability. It encompasses practices such as slavery, forced labour or compulsory labour, debt bondage, human trafficking, domestic servitude, and sexual exploitation.   


3.2       The key legislation in the UK on this issue is the Modern Slavery Act which was introduced in 2015. Section 54 of the legislation requires commercial organisations with an annual turnover of £36 million or more to report publicly on their efforts to address modern slavery in their operations and supply chains. To comply with the legislation organisations meeting the threshold are legally required to publish a slavery and human trafficking statement for each financial year outlining the steps taken (or not taken) by the organisation to address modern slavery during this year. Statements must be approved at the highest level of an organisation, signed by the most senior member of the organisation, and published on their website with a link in a prominent place on their homepage.  


3.3       Following an independent review and public consultation of the legislation, the government announced plans to make changes to the legislation. One of these changes is the extension of Section 54 obligations to public bodies with a budget of £36 million or more, including local authorities in England and Wales. While extending Section 54 will require legislative changes, in March 2022 the Home Office acknowledged in a letter to public sector bodies that this change will be introduced as soon as parliamentary time allows.


3.4   The statement should focus specifically on supply chains and business operations and must “describe the steps your organisation has taken during the financial year to deal with modern slavery risks in your supply chains and your own business.” Currently, Home Office statutory guidance recommends that statements include information on the following areas:   Organisation structure and supply chains ; policies in relation to slavery and human trafficking ; due diligence processes ; risk assessment and management  ; key performance indicators to measure effectiveness of steps being taken  ; and training on modern slavery and trafficking.  The government announced plans to also mandate these requirements. 


3.5       Surrey County Council, East Sussex County Council and Brighton & Hove City Council have agreed that the responsibility for implementing approaches to responding to modern slavery in their operations and supply chains will rest with Orbis Procurement – a shared partnership service between the three authorities. The authorities jointly funded the role of the Senior Policy Lead on Modern Slavery to support this work.


3.6      Brighton & Hove City Council has made several commitments to addressing modern slavery in its supply chain. For instance, in 2018, the Council joined the Co-operative Party Charter Against Modern Slavery. The Charter commits Councils across England and Scotland to proactively vet their own supply chain to ensure no instances of modern slavery are taking place. This includes committing to take actions such as reviewing contractual spending to identify potential modern slavery risks, train procurement teams, and engaging with suppliers. In 2020, the Council also signed a joint pledge on modern slavery coordinated by the Sussex Anti-Slavery Network. This pledge commits the Council to work proactively with local and national actors to take actions such demonstrating strong local leadership for anti-slavery initiatives and removing slave-based labour from our supply chains.


3.7       The Council published its first statement last year, recognising that further work needed to be undertaken which focused on the unique issue of modern slavery within supply chains pursuant to Section 54 of the modern slavery legislation. Following consultation with stakeholders across the Council last year, our Senior Policy Lead determined that while the Council has made commitments to address modern slavery in its supply chain, much of this work, and the necessary due diligence measures could be built on. The government’s statutory guidance acknowledges that “Organisations will need to build on what they are doing year on year. Their first statements may show how they are starting to act on the issue and their planned actions to investigate or collaborate with others to effect change.” Our second (2022/2023) statement provides more detail on relevant actions undertaken to address the unique problem of modern slavery in our supply chains. This includes progressing understanding of the problem of modern slavery within supply chains, looking more closely at our own spending to understand potential risks, and putting measures in place to strengthen our response. 


3.8       As our previous statement, the 2022/2023 statement will be co-signed by the Chief Executive and the Leader of the Council prior to being published by 30 September 2023.


4.            Analysis and consideration of alternative options


4.1         There are no known arguments against the recommendation.


5.            Community engagement and consultation


5.1          Community engagement was not carried out.


6.            Conclusion


6.1      Brighton & Hove City Council’s draft 2022/2023 Modern Slavery Statement has been brought for to the Strategy, Finance & City Regeneration Committee for approval in advance of its publication.


7.            Financial implications


7.1       There are no material financial implications in this report. No BHCC staff are directly employed in this work, which is managed by a member of the Orbis Procurement Team working at Surrey CC. A share of the costs is incurred by BHCC under the Orbis Partnership arrangement, expected to be in the region of £0.015m per annum


Name of finance officer consulted: Ishemupenyu Chagonda 

Date consulted: 20/06/2023


8.            Legal implications


8.1         The legal implications are covered in the body of the report. The Council is not currently required by law to publish a Modern Slavery Statement, but it is good practice to do so.


8.2     The statement relates to the Council’s potential exposure to modern slavery risks occurring in its supply chains and own organisation. The appropriate committee to make the decision is therefore Strategy, Finance & City Regeneration Committee which is responsible for procurement, Human Resources and Council-wide contract management issues.


Name of lawyer consulted: Alice Rowland    Date consulted: 8/6/23


9.            Equalities implications


9.1         The publishing of Brighton & Hove City Council’s Modern Slavery Statement will not negatively impact on equality and those with protected characteristics groups from the Equality Act 2010.  The publication of the statement aligns with the Council’s equality responsibilities and priorities. This is because certain vulnerable, marginalized, and underrepresented groups are at a higher risk of modern slavery practices. The Modern Slavery Statement references the relevance of our Equality, Diversity and Inclusion policies in addressing modern slavery risks.


10.         Sustainability implications


10.1      The publication of our Modern Slavery Statement and associated actions will have a positive impact on sustainability, particularly in the area of sustainable procurement and consideration of the ethical impacts of our procurement activities. Additionally, it contributes to the wider global sustainability agenda as target 8.7 of the United Nations Sustainable Development Goals focuses on the eradication of forced labour and modern slavery practices.



Supporting Documentation


1.            Appendices


1. Brighton & Hove City Council draft 2022/2023 Modern Slavery Statement