Modern slavery and human trafficking statement

Introduction from Chris Elliot - Chief Executive

The Council takes the necessary steps and checks to ensure slavery and human trafficking practices are not taking place within the Council or within any of its contracts or supply chains.

There have been no reports of slavery or human trafficking in this Council, its suppliers or in any of our supply chains.

Warwick District Council has a zero-tolerance approach to slavery and human trafficking; recognising its obligation to identify, target and prevent slavery and human trafficking; and that everyone has a role to play.

About Warwick District Council

Warwick District Council is a local authority district of central Warwickshire in England. The District Council deals with, amongst others, waste management, the collection of council tax, planning/building regulations, council housing and council house repairs.

The district comprises of the towns of Warwick, Royal Leamington Spa, Kenilworth and Whitnash, and also includes the surrounding rural areas.

There are over 503 staff employed by the council and manage more than 5,500 HRA properties within the district. There are approximately 62,500 properties within the district.

More information on Warwick District Council local authority.

Council suppliers and contractors

As a local authority goods, works and services are primarily procured for use within the local district; however, the councils' suppliers are located throughout the World. As a result, it is ensured that all procurement is undertaken in accordance with the Procurement Act 2023 and the Modern Slavery Act 2015, to ensure that slavery and human trafficking is prevented within council supply chains and during the process of assessing conflicts of interest.

Policies on slavery and human trafficking

The Council is committed to ensuring that there is no modern slavery within council supply chains or in any part of Warwick District Council. As part of this Policy, there is a commitment to acting ethically and with integrity in all internal and external relationships, as well as implementing and enforcing effective systems and controls to ensure slavery and human trafficking arenot taking place anywhere within council supply chains. As local authority stringent guidelines are provided for contractorsof the council’s commitment to preventing modern slavery; and promote the completion of the government Modern Slavery Assessment Tool within tender documentation.

We also have safeguarding procedures in place and regular role specific safeguarding training for our staff. This helps all staff to identify any safeguarding issues and ensure they follow the correct referral procedures.

Due diligence processes for slavery and human trafficking

As part of the Council’s initiative to identify and mitigate risk systems are in place to:

identify and assess potential risks when appointing a new supplier using our procurement evaluation and the mandatory questions set by central government. Under the New procurement regulations due to be enacted in 2024 identification of risks would be grounds for disbarment.
mitigate the risk of slavery and human trafficking occurring with our suppliers by requesting that they complete the government Modern Slavery Assessment Tool; (Information on how to complete the tool is within our ITT documents)
monitor potential risk areas in contracts and with suppliers through active contract management; and
protect whistle blowers. - Whistleblowing for employees: What is a whistleblower - GOV.UK (www.gov.uk)

Risks and how we manage them

As part of the councils ongoing process to identify and monitor risks it has been identified that the key area of risk lies in relationships with suppliers and contractors. To manage this risk, third parties are required to acknowledge the council's commitment to combat slavery and human trafficking by inserting relevant clauses into all agreements.

Supplier adherence to WDC's approach

Warwick District Council has a zero-tolerance approach to slavery and human trafficking. To ensure all contracts and suppliers comply with Council values, there are validated procurement procedures in place. This includes selection criteria that supports disqualification for non-compliance with Modern Slavery and Human Trafficking commitments; Safeguarding evaluation criteria for contracts that have a high percentage of human resource; and incorporating a standard clause into all new contract agreements with suppliers which informs them of the council's commitment to combatting slavery and human trafficking and requires them to agree to this commitment when working with WDC.

Warwick District Council are committed as a local authority to tackling modern slavery and human trafficking and want to work with suppliers who share this commitment.

Effectiveness in combatting slavery and human trafficking

The following indicators to measure how effective the council has been in ensuring that slavery and human trafficking are not taking place in any part of the organisation or supply chains:

recording and monitoring any incidents or reports made by staff in relation to Anti-Slavery using the Employee Code of Conduct Policy, Whistleblowing and Safeguarding Procedures;
monitoring any incidents or allegations across supply chains which conflict with council values; and
Recording any incidents or complaints received from any third parties concerning slavery and human trafficking.

Training and awareness

It is understood that training is fundamental in the council's duty to ensure that there is no slavery or human trafficking within Warwick district and within the councils supply chains. Awareness continues to be raised amongst staff to help them better understand modern slavery; human trafficking and safeguarding as well as the risks associated with it and how, as an organisation, the council are working to manage this.

Ongoing commitment

Warwick District Council are committed to ensuring that supply chains remain slavery and human trafficking free. During the year actions will be undertaken to continue to ensure:

There is monitoring of contracts to ensure the council are free from slavery and human trafficking. Part of this would be ensuring the maintenance of a monitoring eye on the disbarment list from October 2024.
Suppliers and contractors should provide evidence of a suitable Company Code of Conduct when dealing with the council. Checks on contracts and suppliers are undertaken in accordance with the Code of Conduct policy if they are unable to demonstrate their own code of conduct.; and
There is an on-going awareness of Anti-Slavery Safeguarding Procedures via training methods alongside a programme to ensure staff understand and adopt the councils' values.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes Warwick District Councils slavery and human trafficking statement for the financial year.

Annual review completed 31/7/24