Modern slavery and human trafficking statement

Steps we take to prevent modern slavery in our business and supply chains

Trafficking in human beings is a serious crime and is now referred to under the term “Modern Slavery”. Modern slavery is a heinous and often hidden crime, and the impact can be devastating for the victims. Modern slavery can be broadly grouped into five categories but is not limited to:

  • Sexual exploitation: this is the sexual abuse of children or adults for the benefit of others and can include in person or virtual abuse such as the production and distribution of child abuse images, videos or live streaming, production of child abuse images, videos or live streaming
  • Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties
  • Labour Exploitation: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and retail businesses that reply on cash payments (for example nail bars and car washes)
  • Debt Bonded Labour: this is a form of forced labour when a person is forced to work to pay off a debt and are tricked into working for little or no pay, with no control over their debt.
  • Criminal exploitation: this can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker

Labour Exploitation is thought to be the most widespread form of slavery today.

Other forms of exploitation include organ removal, forced begging fraud, marriage, and illegal adoption.
Essex County Council (ECC) recognises its responsibility to take a robust approach to modern slavery and human trafficking.

This annual statement sets out ECC’s actions to understand all potential modern slavery risks related to our activities and to put in place steps to eliminate acts of modern slavery and human trafficking within our business and in our supply chains, sub-contractors and partners. ECC is committed to preventing modern slavery and human trafficking in all its activities, and to ensure our supply chains are also free of this.

The publication of this Annual Statement is part of that commitment and highlights our activities to address this.

The Modern Slavery Act 2015 sets out how modern slavery and human trafficking should be dealt with. The Act details organisations and responsibilities for “First Responders” which include, recognising signs of modern slavery and a duty to make a referral for all victims through the National Referral Mechanism (NRM) (S.52).

First Responders are responsible for identifying possible victims that could be trafficked or enslaved. First responders in England include:

  • All those working in local authorities
  • Police forces
  • Certain parts of the Home Office (UK Visas and Immigration, Border Force, Immigration Enforcement)
  • National Crime Agency
  • Gang masters and Labour Abuse Authority (GLAA)

Other legislation which may be useful when supporting victims of modern slavery/trafficking is:

  • Care Act 2014 and associated statutory guidance
  • Localism Act 2011
  • Housing Act 1996
  • Homelessness code of guidance for local authorities 2018

National Referral Mechanism

The National Referral Mechanism (NRM) is a framework designed to identify and refer potential victims of modern slavery and ensure they receive appropriate support. Key aspects include:

  • Identification and Referral: First responders, such as police, local authorities, and certain NGOs, can refer individuals they suspect are victims of modern slavery to the NRM
  • Support for Victims: Once referred, victims can access various forms of support, including accommodation, medical treatment, legal aid, and counselling
  • Decision-Making: The Single Competent Authority (SCA) within the Home Office assesses the referral to determine if the individual is indeed a victim of modern slavery
  • Children: For children, consent is not required for referral.
  • Adults: For adults, informed consent is necessary, and they must understand the implications and support available through the NRM

This mechanism ensures a coordinated approach to tackling modern slavery and providing necessary assistance to victims.

Organisation's structure

Essex County Council governs the non-metropolitan county of Essex in England. At the time of the 2021 census, it served a population of 1,503,300, (excluding Southend and Thurrock) which makes it one of the largest local authorities in England.

As a non-metropolitan county council, responsibilities are shared between districts (including boroughs) and in many areas also between civil parish (including town) councils. We provide county-wide services including:

  • schools
  • roads
  • children's social care
  • adult social care
  • Trading Standards
  • Youth Offending Service

Decisions about the way we run our services are taken by the 75 Councillors that are elected every 4 years. The 75 Councillors come from different political parties, and some have different roles in the decision-making process.

Our Business 

People

We have a number of policies and procedures in place that aim to ensure modern slavery does not occur in our business:

  • Robust Recruitment Policy and process which are compliant with UK employment legislation, the process includes several pre-employment checks, for example 'right to work' document checks, referencing and understanding any employment gaps, undertaking DBS checks for relevant posts
  • Mandatory Corporate Governance Training, which includes the employee code of conduct, how we behave, and Equality and Diversity, defines the responsibilities and standards required for all who work for and on behalf of us including interims, agency workers and employees seconded to other organisations
  • Whistle Blowing: reporting knowledge or suspicion of modern slavery through our whistleblowing procedures and hotline which ensures that staff or members can raise their concerns confidentially without fear of reprisal

For those staff unable to raise their concern with anyone within the council they can contact Ethics point. Ethics point is an independent external whistleblowing provider that delivers ECC’s Speak up! Service.

Safeguarding vulnerable adults and children

We are committed to developing, implementing, and monitoring policies and processes to safeguard the welfare of vulnerable adults and children. Our work within multi-agency partnerships ensures comprehensive protection and safeguarding for all individuals.

To enhance staff awareness, we provide E-Learning training that supports the Modern Slavery Act. This includes courses from the Essex Social Care Academy (ESCA) such as:

  • An Introduction to Modern Slavery and Human Trafficking
  • Child Trafficking and Slavery Human Trafficking
  • Modern Slavery: Spotting the Signs and What You Should Do

Additionally, the Essex Safeguarding Children Board offers E-Learning exploitation training that covers both children and vulnerable adults.

Along with The Modern Slavery Act 2015, The Care Act 2014 & The Children’s Act 1989 includes modern slavery as a type of abuse, so the approach to managing cases of modern slavery is intricately linked to children and adult safeguarding procedures.

The Essex Safeguarding Adults & Childrens Board offers guidance and resources for professionals on Modern Slavery via their websites. Key resources include the Modern Slavery Guidance (March 25), the 1 Minute Guide to Modern Slavery, and the Southend Essex and Thurrock (SET) Children & Adults referral flowchart. These tools are particularly useful for first responders in local authorities, helping them to identify and address modern slavery effectively.

These SET Safeguarding Procedures incorporate national guidance from the Home Office on the National Referral Mechanism (NRM), further strengthening these efforts. These resources emphasize a shared focus on protection and prevention, creating opportunities for multi-agency collaboration and effective intervention.

Additionally, the Safeguarding Adults Board includes Modern Slavery in their Basic Safeguarding Awareness Training for professionals and designated safeguarding leads. In Adult Social Care (ASC), this topic is covered in the Safeguarding Level 1 Essential (Mandatory) training.

Procurement

The Procurement Team supports the sourcing of c£1.2bn per annum with third parties on goods, works and services. It has responsibility for commercial contract management over the contract portfolio value of c£7bn delivered by over 500 suppliers.

Procurement Supply Chains

Our procurement activity complies with the Council’s Procurement Rules and all relevant procurement legislation. To support our Category Management approach to minimise market risks concerning modern slavery within our large and complex supply chain, we have implemented a Modern Slavery Risk Assessment Tool. Where the category is assessed as higher risk, we will consider whether a wider verification of modern slavery risks is required across the supplier base and whether further supply chain mapping is appropriate. This information is captured for tenders over £100k and is discussed by the Procurement Management Team to improve understanding and lessons learned.

To comply with the Modern Slavery Act 2015, we have:

  • updated our professional and technical ability tender questions within the procurement sourcing process: The questions require a bidder to evidence their compliance with the Modern Slavery Act if they are a relevant commercial organisation as defined by Section 54 of the Modern Slavery Act 2015
  • incorporated within our standard contract terms clauses that specify the Supplier’s contractual obligation concerning Modern Slavery

Any bidder who fails to evidence their compliance with the required legislation shall be excluded from participating further in the tender process.

Any supplier engaged by us to undertake the supply of goods and or services is contracted to do so in line with the our following policies:

  • safeguarding
  • equality and diversity code of conduct
  • whistleblowing

These policies are key to ensuring that staff employed by our supply chain have appropriate channels to report any incidents of slavery and human trafficking.

We keep under review and update our contract management processes and guidance as required.

A thorough review was completed in 2023 with the objective of the review to identify approaches that would improve our processes to enable the identification and management of risks in relation to modern slavery and human trafficking. Possible ways of doing this could include:

  • increasing openness, transparency, and efficiency in the management of supply chains
  • improving ability to identify strengths, weaknesses, opportunities, and threats in
    supply chains
  • improving communications with suppliers
  • enhancing relationships with suppliers

One such approach is to (if appropriate and proportionate) introduce annual audits on suppliers to ensure compliance with the contract agreement. A Contract Compliance Audit Template has been developed within our Contract Management Tool. As part of the Contract Compliance Audit Process suppliers with an annual turnover of over £36m are requested to confirm that they have updated their Modern Slavery Statement within the last 12 months. Where feasible, and where justification for further investigation is identified, further audits can be completed.

The outcome of this will inform how we can continue to review how modern slavery is incorporated into the contract management process.

We have added to all relevant workflows a requirement for one contract management meeting per year to have an agenda item covering Modern slavery. This can be used as an opportunity to remind suppliers of the actions they can take to seek to reduce the risk of Modern Slavery.

The Modern Slavery agenda item should cover:

  • whether the supplier has audited, and risk assessed their own supply chain
  • if they have carried out these processes, what the main findings were
  • whether there are any areas of risk that we need to be aware of that the provider is looking into
  • if the provider has not carried out any of these steps, plans for when they intend to do so
  • whether there are updates from the supplier’s Modern Slavery Statement that may impact on the contract

We are also exploring how we can capture information that will enable us to have effective oversight of modern slavery risks. This could take the form of KPIs that might include the following:

  • all suppliers confirming their adherence to the Modern Slavery Act 2015
  • all relevant Suppliers will need to evidence the publication of their Modern Slavery Statement
  • annual monitoring of modern slavery risks with suppliers and internal functions which informs gap analysis and reflective action log and programme
  • percentage of suppliers reporting that all their staff have completed modern slavery training

In November 2023 we launched our Sustainability Charter which sets out to prospective and current suppliers what we expect of them in relation to Modern Day Slavery. This was updated in line with the Procurement Act 2023 in February 2025 and published on the Essex.gov website.

Training

The Procurement Induction Pack given to all new members of the Procurement Team sign-posts staff to available training on The Modern Slavery and Human Trafficking Act 2015. This has included the internal ESCA E-Learning and external training. Going forward it is intended that training on Modern Slavery will be mandatory for all new team members, training options for non-procurement staff is being reviewed. Established members of the team are required to complete the CIPS Ethical Procurement Module on an annual basis. A Procurement Training Playlist has been created which includes Modern Slavery and PREVENT Learning modules.

Finding Help

If you or someone you know is being or has been exploited or you are unsure if someone needs help, assistance and advice is available.

If you are concerned about a child (Under 18)

In cases involving children, the elements of coercion or deception do not need to be present for it to be considered trafficking. Children cannot legally give consent to being moved, so any movement or relocation of a child for exploitative purposes is automatically considered trafficking.

If you think a child is in immediate danger, contact the Police on 999. 

For non-urgent reports, contact the police via 101 or report a crime through their website.

Child trafficking is always a child protection issue, refer the potential victim to Children’s Services as soon as possible. Call 0345 603 7627 or fill in the online Children and Families Request For Support.

If you are concerned about an Adult (Over 18)

Contact Essex Police on 999 if you think an adult is in immediate danger.

If you hold information that could lead to the identification, discovery and recovery of victims in the UK, you can contact the Modern Slavery Helpline on 08000 121 700. Alternatively you can make calls anonymously to Crimestoppers on 0800 555 111.

Contact your Essex Safeguarding Adults as soon as possible by calling 0345 603 7630 or report a concern about an adult online.

Non-consent and duty to notify (DtN) - If a victim does not wish to enter the National Referral Mechanism, Section 52 of the Act still makes it a duty for public authorities to notify the Secretary of State if they have reasonable grounds to believe that a person may be a potential victim. This is done by completing an anonymous 'Duty to Notify' (DtN) form14 also known as MS1 form. An MS1 form should only be used if the potential adult victim wants to remain anonymous and does not want specialist support (or if you are not able to contact the potential victim and do not know their personal details).

Organisations that support victims

The Salvation Army is contracted by the UK Government to provide support to potential victims of modern slavery/ human trafficking in England and Wales. The Salvation Army have a 24/7 confidential referral helpline, which can be called on 0800 808 3733. Leaflets are available in Albanian, Chinese, Czech, English, French, Lithuanian, Polish, Romanian, Slovak, Thai, Vietnamese, and Welsh to offer help and advice for people who think they may be victims of modern slavery in the UK.

The National Crime Agency has best practice information on dealing with victims and the use of interpreters.

UnseenUK.org (run a 24 hour helpline 08000 121 700)·

Gang masters and Labour Abuse Authority (GLAA)
Modern Slavery Helpline can be called on 08000 121 700 or contacted via an online form Victim Support can be called on 0808 16 89 111 or contacted via an online form.

Crimestoppers can be called on 0800 555 111 or contacted via an online form.

Migrant Help can be called on 01304 203977.

About this statement

This statement will be reviewed on an annual basis, which will take place on or before 30th April 2026.

This statement will be published on the Essex County Council website and on the Government ‘Modern Slavery Statement Register’ which went live on the 6th May 2021.

This statement has been signed by Kevin Bentley, Leader of the Council, and Nicole Wood, Chief Executive Officer of Essex County Council.

Further information on modern slavery can be found on GOV.UK.