This statement sets out the LGA actions in working to understand all potential modern slavery risks related to its organisation and to put in place steps that are aimed at ensuring that there is no modern slavery or human trafficking in its own business and its supply chains.
This statement sets out the Local Government Association’s (LGA) actions in working to understand all potential modern slavery risks related to its organisation and to put in place steps that are aimed at ensuring that there is no modern slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2021 to 31 March 2022.
The LGA recognises its responsibility to take a robust approach to modern slavery and human trafficking. The organisation supports the Modern Slavery Act 2015 and opposes modern slavery and human trafficking. It is committed to ensuring that such practices have no place within its supply chain or other activities.
In addition to the LGA’s responsibility as an employer, it also acknowledges its duty to notify the Secretary of State of suspected victims of modern slavery or human trafficking as introduced by section 52 of the Modern Slavery Act 2015.
For the purposes of this document we have followed the Government’s six areas of activity set out in; Transparency in supply chains: a practical guide and the LGA’s Modern Slavery: Transparency in supply chains statements.
Definition of Modern Slavery
The term ‘Modern Slavery' captures a whole range of types of exploitation, many of which occur together. These are defined by Unseen UK to include but are not limited to:
- Sexual exploitation: this includes sexual abuse, forced prostitution and the abuse of children for the production of child abuse images/videos.
- Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties.
- Forced labour: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars).
- Criminal exploitation: This can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shop-lifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker.
- Human trafficking: this requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult.
- Other forms of exploitation: organ removal; forced begging; forced benefit fraud; forced marriage and illegal adoption.
Organisational structure and supply chains
This statement covers the activities of the Local Government Association and the Improvement and Development Agency (and for the purposes of this document be referred to as the ‘LGA’). The LGA operates in the United Kingdom, with a small presence in Belgium, and works on behalf of councils to ensure local government has a strong, credible voice with national government. We are the national voice of local government, working with councils to support, promote and improve local government. The LGA is a membership organisation with 394 authority members in 2021/2022.
Relevant Organisational policies
Within our own business
We have a number of policies and procedures in place that contribute to ensuring modern slavery does not occur in our business. These include:
- Whistleblowing policy: The organisation encourages all its employees and those employed on a contract for service or through an agency to report any concerns related to the direct activities, or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of modern slavery or human trafficking. The organisation's whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
- Recruitment/Agency workers guidance documents: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.
- Robust recruitment procedure: For both substantive staff and agency workers. This process is compliant with UK employment legislation and includes a number of pre-employment checks, for example “right to work” document checks, obtaining references and understanding any employment gaps. Banking information is verified by Payroll to ensure salary payment is going to an individual’s account and not a business account. DBS checks are undertaken for relevant posts.
- Awareness-raising: The organisation has raised awareness of modern slavery issues within the organisation by requiring all LGA employees to complete the mandatory e-Learning module on Modern Slavery, covering the basic principles of the Modern Slavery Act 2015.
For our supply chain
- Procurement policy: The policy sets out the LGA’s overarching approach to its procurement of goods and services. Accompanying documents include a Suitability Assessment Questionnaire for suppliers to complete in high value/ above threshold procurements.
- In 2019/20 we reviewed and revised our standard terms and conditions, and our purchase order terms and conditions templates for the procurement of consultancy, goods and services to ensure appropriate contractual provisions are in place in relation to modern slavery. These provisions include the need for suppliers to comply with the Modern Slavery Act 2015 and to have in place such policies and procedures and to take all necessary measures to ensure that nothing relating to dealings in respect of the LGA, or otherwise within a supplier’s business and supply chain, involves slavery or human trafficking.
In the standard selection questionnaire (SSQ) for FTS procurements, used to shortlist suppliers for tender when the restricted process is adopted, we ask organisations whether they are required to produce a Modern Slavery Statement and provide a link to the statement on their website if they are in-scope.
For our members
In its capacity to provide guidance to the local government sector, the LGA worked closely with the Anti-Slavery Commission to produce its useful portal for resources on Modern Slavery to support councils in their work to tackle this issue. This includes Tackling modern slavery: a council guide as well as case studies, a councillor guide and some more specific guidance on hand car washes.
It also produced guidance to help councils produce their own transparency statements: Modern Slavery: Transparency in supply chains statements. The LGA also hosts a portal of council transparency statements which reside on a dedicated Modern Slavery webpage.
Assessing and managing risk
Whilst the LGA has produced guidance on Modern Slavery in the supply chain for councils, our own spend categories and supply chains are much smaller and distinctly different to the councils we advise.
As an organisation a large portion of our non-core staff expenditure goes on bought in services from small to medium sized companies (SME) and professional organisations. None of these services are flagged as high-risk categories in any of the literature or guidance.
We additionally spend a portion of our budget on the day-to-day costs of running a business and carrying out our support offer around the country, these include facilities management, catering, security and cleaning.
Following the guidance, we have adopted a risk-based approach to supply chain assessment to ensure we focus attention on the perceived higher risk categories in our supply chain. We have identified the features which match the high-risk industries in our supply chain:
- Complex employment relationships; a reliance on agency, outsourced or subcontracted workers
- Reliance upon low-skilled or unskilled labour;
- High numbers of temporary, seasonal, or agency workers;
- Dangerous or physically demanding work
Human rights due diligence is not about the risk to the organisation, it is about the risk to the people involved in providing services and producing goods in the supply chain.
The most effective way to apply limited resources to due diligence and to ensure action is targeted at those spend categories taking into consideration; the industry, its geographical source and the nature of the supplier relationship. To this end we decided to focus on our major suppliers of:
- Facilities Management including maintenance and cleaning
For the period 2020/2021 our goal was to review the supplier selection processes and consider whether to embed anti-modern slavery and human trafficking criteria into the evaluation of potential suppliers (for example in Request for Quotation and Invitation to Tender documents) and requiring such organisations to provide evidence of appropriate policies and procedures.
As above, a large portion of our non-core staff expenditure goes on bought in services from individuals or small to medium sized companies (SME) and professional organisations. None of these services are flagged as high-risk categories in any of the literature or guidance.
Therefore, the LGA’s decision is not to include modern slavery compliance as an independent evaluation point for low value or individual’s contracts but to build this as an evaluation point when assessing suppliers identified as higher risk, large services such as construction, cleaning and catering services and naturally any procurements over threshold value.
The Modern Slavery Unit (MSU) in the Home Office has devised a web-based Supplier Risk Assessment Tool to support public bodies to assess their own supply base for modern slavery risks. The tool asks suppliers a number of questions about their business and the processes they have in place to manage modern slavery risks in their supply chains. It provides automated recommendations on how to improve their anti-modern slavery processes and flags up any issues to the recipient.
Responding to an incident of modern slavery
Due diligence is the process of identifying human rights risks in an organisation´s supply chain, preventing them from occurring or mitigating those risks and reducing their impact. It includes planning remedial or corrective action if such an incident is discovered.
Going beyond the LGA’s legal ‘duty to notify’ any incidents of Modern Slavery, the LGA is committed to following government guidance, wherever practicable:
- to engage and work with suppliers to mitigate any issues
- make staff aware of the Modern Slavery Helpline as their first port of call
- adopt an approach that would produce the safest outcome for the potential victims, using any leverage we may have as a public sector membership organisation.
We will know the effectiveness of the steps that we are taking to ensure that Modern Slavery is not taking place within our business or supply chains by:
- Investigating allegations or complaints, received from employees, the public, or law enforcement agencies regarding modern slavery and human trafficking.
- Requiring all staff working in supply chain management, procurement and HR to have completed training on modern slavery.
- Reviewing and evaluating high risk supply chains, periodically using the modern slavery assessment tool to monitor supply chains as part of on-going contract management activity throughout the life of the contract to measure progress.
- Updating our suite of contract clauses so they include provisions of the Modern Slavery Act in line with our pre-procurement clauses.
The LGA raises awareness of modern slavery issues on an annual basis by circulating informative internal communications and requiring all LGA employees to complete a mandatory e-Learning module on Modern Slavery. This module covers the basic principles of the Modern Slavery Act 2015 and provides an overview on:
- the legislation and reference to Section 54 of the act (transparency in supply chains)
- how employers can identify and prevent slavery and human trafficking;
- what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation;
- what external help is available, for example through the Modern Slavery Helpline.
Aims for our continuous improvement
The LGA’s focus for the next 12 months with regards to the Modern Slavery Act 2015 are as follows:
- As a means of carrying out due diligence on the key suppliers identified in the higher risk categories the LGA will review and evaluate high risk supply chains, periodically (and where required) using the Modern Slavery Assessment Tool (MSAT) to monitor supply chains as part of on-going contracts.
This statement was approved on 9 March 2022 by the LGA Board. The board will review and update it annually.