Modern Slavery Statement

Swansea Council is committed to addressing Modern Slavery and has a zero tolerance threshold to it occurring within its supply chain.

1. Overview

The Council is a signatory to the Welsh Government's Code of Practice: Ethical Employment in Supply Chains. The Code of Practice includes the following employment issues:

Modern Slavery and human rights abuses.
No practice of blocking or denying Trade Union activity in our supply chain.
False self-employment.
Unfair use of umbrella schemes and zero hour's contracts.
Paying the Living Wage.

The Code's 12 commitments include tackling Modern Slavery and Human Trafficking. This Statement sets out the action that the Council has taken, and will take, to ensure that there is no Modern Slavery and Human Trafficking in its own business or supply chains. Swansea Council is fully committed to providing visibility to its Modern Slavery Statement and ensuring 'Transparency in Supply Chains'. To this end the Council is working in partnership with Welsh Government, the wider public sector, suppliers, service providers, trade unions and others to address modern slavery challenges and drive collaborative action with a view to reducing risks and incidence of modern slavery.

2. What is Modern Slavery?

Modern slavery is a crime and a violation of fundamental human rights. It 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 in order to exploit them for personal or commercial gain.

Modern Slavery is estimated to affect fifty million people worldwide, including the UK and Wales. Victims are trafficked all over the world for little or no money, including to and within the UK. They can be forced to work in the sex trade, domestic servitude, forced labour and engage in criminal activity. High-risk sectors for Modern Slavery include agriculture, leisure, hospitality, catering, cleaning, clothing, construction and manufacturing.

3. Our Policies

Swansea Council's Corporate plan 2023 / 2028 describes the Council's vision for Swansea, our 6 key Council priorities (well-being objectives) and our organisation values and principles that will underpin the delivery of our priorities and overall strategy.
Our Vision

In 2028 Swansea is a place that has a thriving mixed use city centre and local economy. It is a place where people can gain the skills and qualifications they need to succeed in life, where everyone can achieve their potential and where communities are resilient and cohesive. Swansea is a place where human rights are respected, and people are safeguarded from harm and exploitation. It is a place where nature and biodiversity are maintained and enhanced, and carbon emissions are falling.

In order to meet our vision we have prioritised six well-being objectives. These are:

Safeguarding people from harm - so that our citizens are free from harm and exploitation.
Improving Education and Skills - so that everyone in Swansea gains the skills and qualifications they need to succeed in life.
Transforming our Economy and Infrastructure - so that Swansea has a thriving mixed use City Centre and a local economy that will support the prosperity of our citizens.
Tackling Poverty and Enabling Communities - so that every person in Swansea can achieve their potential.
Delivering on Nature Recovery and Climate Change - so that we maintain and enhance nature and biodiversity in Swansea, reduce our carbon footprint and tackle climate change.
Transformation and Financial Resilience - so that we and the services that we provide are sustainable and fit for the future.

The Council's over-arching Corporate Safeguarding Policy sets out the Council's duty and commitment to safeguard and promote the wellbeing of children, young people and adults at risk and to ensure that effective practices are in place throughout the Council and its commissioned services. The policy covers all functions and services of the Council and applies to all Council employees, elected members, foster carers, individuals undertaking work placements and volunteers working within the Council.
The other key strategies and policies include:

The Council has adopted the Welsh Government's Code of Practice on Ethical Employment in Supply Chains and the elimination of modern slavery, so that Swansea Council plays a leading role in making Wales hostile to modern slavery.
The Whistleblowing Policy enables Council staff and employees of the Council's contractors / suppliers to report unethical employment practices to the Council.
Supporting employees affected by domestic abuse and sexual violence policy
Employee Code of Conduct makes it clear to employees the actions and behaviour expected of them when representing the Council. In performing their duties, they must act with integrity, honesty, impartiality and objectivity. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour in all its operations and when managing our supply chain.
Recruitment policy - The Council aims at all times to recruit the person who is most suited to the particular job. The Council has robust recruitment processes, which includes document checks to ensure that candidates are allowed to work in the UK.
Agency workers - The Council sources all agency workers and temporary staff through third party providers. We will only appoint suppliers who have a zero tolerance approach to modern slavery and are committed to Ethical Employment and Safeguarding of their workers.

4. Our Supply Chain

Swansea Council delivers a wide range of statutory and discretionary services to over 300,000 residents. The Council does this through its own workforce and through over 2,000 private and third sector organisations. The Council has a responsibility to manage public money with probity and to ensure that its £350m+ of annual procurement spend is managed in such a way that it supports the delivery of wider Council priorities.

The Council recognises that our supply chains spread across the world, and that parts of the supply chain could be engaged in modern slavery. The Council will focus on our direct suppliers and will require our suppliers to ensure that their supply chain is free from modern slavery through supplier qualification.

The risk of modern slavery and human trafficking by our direct suppliers is considered low. Through the tendering process, the Council ensures that our direct suppliers are aware of our commitment to tackle modern slavery and human trafficking and that they also understand their obligations as a supplier or contractor of the Council. The Council undertakes due diligence when considering taking on new suppliers. The due diligence and reviews include:

Ensuring compliance with the s54 (Modern Slavery Act 2015) requirement regarding a Modern Slavery Statement and, as part of tender evaluation and ongoing contract management, consideration of the potential and likelihood of modern slavery; seeking mitigations from the supplier through a clear understanding of the suppliers' structure, business and supply chains and policies in relation to slavery and human trafficking.
Conducting supplier assessments to create a risk profile focusing on financial stability and also covering insurance and compliance with various employment policies including the Welsh Government's Code of Practice: Ethical Employment in Supply Chains.
Taking steps to improve sub-standard supplier practices, including the provision of advice to suppliers and requiring them to implement Action Plans; for example to demonstrate compliance with safer recruitment guidelines.
Participating in collaborative initiatives focused on human rights and socially responsible procurement policies in general and modern slavery and human trafficking in particular including the Council Corporate Safeguarding Group.
Invoking sanctions in respect of suppliers who fail to meet our expectations or to improve their performance in line with an Action Plan, which includes a provision to terminate the business relationship.

5. Employee Training

Swansea Council is committed to providing a range of training for our employees in order to raise awareness of modern slavery, human trafficking and forced labour. In addition to awareness level training some staff will need training specific to their role for example identified first responders and commissioning and procurement staff.
Mandatory Staff E-Learning Modules include:

Safeguarding Everyone's Responsibility
Equality in Practice

6. Swansea Council Duties:

Swansea Council has a statutory duty to safeguard and promote the welfare of children at risk and of adults at risk. The council aims to ensure that everyone working with, or on behalf of, children and/or adults is competent, confident and safe to do so, by working within the legal and statutory frameworks set out in the following:

Wales Safeguarding Procedures (safeguarding.wales) (opens new window)
Social Services and Well-being (Wales) Act 2014 (legislation.gov) (opens new window) (SS+WbA)
Children Act 1989 and 2004
Human Rights Act 1998
UN Convention on the Rights of the Child
UN Principles for Older Persons
UN Convention on the Rights of Disabled People (CRDP)
Data Protection Act 2018
Equalities Act 2010
Regulations and Inspection of Social Care (Wales) Act 2015
Modern Slavery Act 2015
To ensure our approach is consistent with the principles of the Social Services and Well-being (Wales) Act 2014 (legislation.gov) (opens new window), and the Well-being of Future Generations act (swansea.gov.uk) (opens new window).
To apply Wales Safeguarding Procedures (safeguarding.wales) (opens new window) for children and adults at risk of abuse and neglect. These are the national Wales Safeguarding Procedures. They detail the essential roles and responsibilities for practitioners to ensure that they safeguard children and adults who are at risk of abuse and neglect.
There is a duty to cooperate, working together as partners with the lead organisation in the exercise of any of its safeguarding functions.
There is a duty to report a child at risk for all relevant partners of a local authority. Under Section 130 of the Social services and well-being (Wales) act 2014 (legislation.gov) (opens new window).
There is a duty for a local authority to make enquiries (linking into section 47 of the Children Act) if they are informed that a child may be at risk; and to take steps to ensure that the child is safe. Under Section 130 of the Social services and well-being (Wales) act 2014 (legislation.gov) (opens new window).
There is a duty of all relevant partners of a local authority to report a concern about an adult at risk, and for a local authority to make enquiries if it has reasonable cause to suspect that a person within its area (whether or not ordinarily resident there) is an adult at risk. Under Section 126 of the Social services and well-being (Wales) act 2014 (legislation.gov) (opens new window).
To apply the Reducing Restrictive Practices Framework (PDF) [549KB] - A new framework to promote measures and practice that will lead to the reduction of restrictive practices in childcare, education, health and social care settings for people of all ages.
As part of Swansea Council's safeguarding arrangements, there are lead officers within each service who have role-specific safeguarding training and who can advise colleagues in their service about safeguarding issues. These officers are called Named Safeguarding Persons.
Staff are directed to follow relevant safeguarding procedures for their individual service and directorate, and services should have their own safeguarding procedures which are accessible to staff in the course of their daily work. Together with their safeguarding lead, they can then decide whether to contact the safeguarding lead in their service area, or to contact specialist help:
- Adult Services Common Access Point
- Swansea Single Point of Contact (SPOC)
- Safeguarding adults concerns

If a Councillor (or any member of the public) has concerns regarding the safety of an adult, then the Social Services Common Access Point should be contacted immediately by completing a referral form or by phone.

Adult Services Common Access Point for Health + Social Care:
Tel. 01792 636519
CAP@swansea.gov.uk

Safeguarding Adults:
safeguarding@swansea.gov.uk
Tel. 01792 636519
Office Hours: Monday - Thursday 08.30am - 5pm and Friday 08.30-4.30pm

If a Councillor (or any member of the public) has concerns regarding the safety of a child or young person, then the Social Services Single Point Of Contact Team should be contacted immediately on:
Child + Family Services Single Point of Contact
Email: singlepointofcontact@swansea.gov.uk
Tel: 01792 635700
SMS: 07796275457
Monday - Thursday 08.30am - 5pm and Friday 08.30-4.30pm
Social Services Out-of-Hours Team should be contacted if the issue arises after 5.00pm, Monday to Thursday, after 4.30pm on Fridays, and on weekends and Bank Holidays. Tel: 01792 775501

7. Key Performance Measures

Swansea Council through the Corporate Safeguarding steering group board will collect, analyse, monitor and review data associated with safeguarding objectives, and to report on a range of key performance measures, both quarterly and annually.

The Council is also independently audited annually by the regional Safeguarding Board, and may be subject to inspection by Audit Wales.
Key performance indicators may include:

Safeguarding procedures in place and understood across the organisation
Number of concerns and referrals generated by non-specialist council teams
All job descriptions to include safeguarding as a key responsibility for all staff posts
Mandatory safeguarding training completed by staff and elected members.

8. What the Council will do

Swansea Council will take the following action in our efforts to ensure that there is no Modern Slavery or Human Trafficking.

Ref	Action
1	In line with clause 7 of the Code of Practice, continue to ensure that the Council carries out a regular review of expenditure. We will continue to: Identify any high risk suppliers and monitor for human rights abuses and unethical employment practices which will become a standard agenda item in contract meetings and reviews. Explore ways of working with our Tier 1 suppliers to raise awareness of modern slavery to prevent it from occurring through a formalised Risk Assessment process: 'Tackling Modern Slavery in Supply Chains'.
2	Utilising the Code of Practice - Ethical Employment in Supply Chains - deliver on a Modern Slavery Communication Strategy to ensure awareness is raised across the Council and with partner organisations and other agencies. Share learning and best practice across the Council, with other public sector bodies, partners and look to learn from their experiences. Continue engagement with Trade Unions to raise awareness of modern slavery with their members.
3	We will deliver a targeted programme of virtual training across the various Council directorates - in compliance with Covid-19-related restrictions, coordinated with wider Corporate Safeguarding training. We shall continue to identify staff requiring training in ethical employment practices and seek to build awareness / capacity particularly amongst front-facing members of staff working in the Community. We shall look to extend the pool of in-house trainers available to facilitate awareness level training for staff across the Council. We will keep records of who has undertaken training across the various directorates and target those where completion rates require improvement.
4	We will review Key Performance Indicators which may include: Safeguarding procedures in place and understood across the organisation Number of concerns and referrals generated by non-specialist council teams All job descriptions to include safeguarding as a key responsibility for all staff posts Mandatory safeguarding training completed by staff and elected members.
5	Review and update where necessary this Modern Slavery Statement annually
6	We shall encourage suppliers to add Modern Slavery social value clauses to new contracts as this will incentivise good practice, including the use of relevant tools and data sets.
7	We shall participate in 'communities of practice' where Local Authorities work together to share best practice and achieve efficiencies of scale, such as sharing due diligence data across public, private and voluntary sectors to inform audits, etc.
8	Complete a review and update the Council's tender documentation to ensure Modern Slavery and Human Trafficking issues are fully addressed which include clauses to: Include the Code of Practice: Ethical Employment in Supply Chains as a part of our tender documents.

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