In accordance with Section 54 of the Modern Slavery Act 2015, the Police and Crime Commissioner for South Wales and the Chief Constable recognise their responsibility as employers to be aware of the potential for instances of modern slavery and to report such instances or concerns to the relevant bodies. This statement is underpinned by a local action plan.
This statement sets out the work undertaken during the financial year ended 31st March 2022 to identify, prevent and address modern slavery across the force and its supply chains.
What is Modern Slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, sexual exploitation, 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.
The Police and Crime Commissioner for South Wales and the Chief Constable are committed to ensuring that there is no modern slavery or human traﬃcking in the force supply chains or connected in any way to any activities with which South Wales Police is associated. The Force’s policies, procedures and our work to tackle modern slavery through a working group, demonstrates our commitment to act ethically, with integrity and to identify risks that we can work to mitigate.
In 2017, the Police and Crime Commissioners and Chief Constables from the four Welsh police forces signed up to the Welsh Government Ethical Employment in Supply Chains Code of Practice. South Wales Police is fully committed to combating unethical or illegal employment practices in supply chains. This commitment is underpinned by an action plan to deliver the commitments within the Code.
Our approach to identifying and tackling the issues is broken down into four key areas:
Enforcement – South Wales Police will play an active role in enforcement and will use our roles in employment and purchasing goods and services to improve intelligence gathering whilst ensuring full compliance with the Code of Practice as well as acting promptly on information received.
Ethical procurement – promoting the development of ethical supply chains in the delivery of contracts for the police service in Wales generally and specifically in South Wales
Employment – following best practice and demonstrating full commitment to constant improvement within the systems and structures of South Wales Police, as well as working with the other forces in Wales and with partners to identify and eradicate any form of exploitation.
Environment – we will create an environment where the public in Wales have confidence and understanding of how to report any signs of exploitation in all its forms and work with partners, including local government, the NHS and voluntary and community groups to heighten awareness of – and reporting of – signs of exploitation. We will ensure that all our staff – particularly PCSOs and staff in our Public Service Centre – are fully aware of what to look out for and what to do when concerns are reported.
We recognise that modern slavery extends far beyond our national borders and that risks are increased with complex supply chains. Whilst tackling modern slavery is a policing priority for each force, it is recognised that modern slavery can extend throughout any supply chains and that we have a responsibility to address this.
An initial review of our supply chains has highlighted the potential risk of modern slavery in a variety of categories including the following:
We appreciate that modern slavery can and does occur in many other supply chain categories and we are mapping our supply chains using a risk tool to identify the areas we should prioritise as part of our practical response to modern slavery risks.
Fully investigating supply chains is a complicated task but we have now issued supplier assessment questionnaires to 60 suppliers and reviewed 50 contracts identified as higher risk due to their industry type, nature of the workforce, supplier location, commodity type or the level of our expenditure.
We are committed to sharing information to make the best use of our resources. By working with other forces and partner organisations in Wales and locally we can better investigate supply chains based on the greatest risk of human exploitation.
We will continue to work to raise awareness of modern slavery issues across our supply chain. Our action plan includes a target to assess the top 100 suppliers across South Wales Police and Gwent Police by 2025 and we are on track to achieve this.
The Force’s Modern Slavery policy, set by the Chief Officer team and approved by the Police & Crime Commissioner, is in place to reduce the risk of serious harm to victims and improve their safety, health and wellbeing.
The policy outlines how modern slavery offences will be dealt with, and offenders held to justice. Working with the Crown Prosecution Service or other bodies, we will endeavour to successfully prosecute offenders, with the aim of enhancing the trust and confidence of victims.
Robust training is being provided to front line officers and Inspectors are responsible for co-ordinating response to reports and attendance at incidents, reducing immediate risks and preserving available evidence.
The Joint Collaborative Commercial and Procurement Strategy, 2020-2025 incorporates a responsible procurement policy. The policy includes our commitment and activity to implement the Welsh Government Ethical Employment in Supply Chains Code of Practice, and ethical purchasing principles.
Other relevant policies include the College of Policing Code of Ethics and our Whistleblowing policy. Work is ongoing to finalise an All Wales Whistleblowing policy to support the Welsh Government Code of Practice and to empower staff to raise suspicions of any unlawful and unethical employment practice.
Due Diligence and Risk Assessment
Important progress was made during the previous period to address unethical and illegal employment practices in our supply chains. Factors used in the risk assessment of supply chains included the industry type, high risk characteristics associated with the nature of the workforce such as a reliance on a low-skilled or low-paid workforce, seasonal workers, dangerous work, the location of manufacturing and the presence of complex or tiered supply chains. The work progressed during the period 2021-22 is summarised below:
Payment Performance Statistics
Assessing existing suppliers and supply chains
Training and raising awareness
South Wales Police was granted accreditation as a Living Wage Employer in March 2022.
The Living Wage is a voluntary hourly rate set by the Living Wage Foundation based on the cost of living in the UK. The Living Wage Foundation encourages organisations to become accredited Living Wage employers.
The Police and Crime Commissioner for South Wales and the Chief Constable apply this rate to all officers and staff. Suppliers are encouraged to adopt the Living Wage and are able to evidence this in response to the fair working practice question in relevant tenders.
To further progress the delivery of our commitments to tackle modern slavery, representatives from a wide range of areas across the force have our agreed objectives for 2022-2023 which are captured in the action plan underpinning this statement.
Progress against the action plan is monitored through a working Task & Finish Group, chaired by the Chief Officer with responsibility for the Finance & Business Services Portfolio and the Anti-Slavery and Ethical Champion for South Wales Police.
The public and staff equally have a responsibility to be aware of potential instances of modern slavery or of a business using forced labour. If you have any such concerns, please contact any of the following bodies:-
South Wales Police: Telephone 101 (or 999 in an Emergency)
Modern Slavery Helpline: Telephone 0800 0121700
Crimestoppers: Telephone 0800 555 111
Confidential Concerns Line (South Wales Police internal only)
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This Statement has been approved by The Police and Crime Commissioner for South Wales and the Chief Constable. It will be reviewed and updated annually.
Regular update reports will be produced for the Police and Crime Commissioner and Chief Constable on progress made against the action plan.
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