This statement sets out the work undertaken during the financial year ended 31st March 2024 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.

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.

The Force’s Modern Slavery policy, set by the Chief Officer team, 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 and other bodies, we will endeavour to successfully prosecute offenders, with the aim of enhancing the trust and confidence of victims.

Robust training is 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.

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.

A review of our supply chains has highlighted the potential risk of modern slavery in a variety of categories including the following:

  • information communication and technology
  • construction
  • cleaning and waste disposal services
  • uniform manufacture

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 demanding, unremitting task but in the previous 12 months we issued supplier assessment questionnaires (SAQs) to a further 10 suppliers, bringing the total issued to 89 with 76 suppliers given a rating. In addition, Bluelight Commercial (BLC) are seeking a social value assessment from 15 suppliers, particularly where this will benefit other Forces through national arrangements.  The ratings act as a baseline to measure progress by the supplier in tacking modern slavery, monitored through contract management activity. The suppliers selected are identified as higher risk due to their industry type, nature of the workforce, supplier location, commodity type or the level of our expenditure or are suppliers to whom we have recently awarded a contract and issued the assessment as part of our contract management activity. Where suppliers achieve a basic rating, we encourage them to improve their rating, providing guidance to assist smaller suppliers and signposting them to sources of advice to understand how to make improvements. Social Value is a standard item for regular meetings with suppliers as we recognise that this is an ongoing initiative throughout the life of the contract. Demonstrating social, economic and environmental good practice benefits suppliers who wish to be successful in winning future public sector opportunities.

We are committed to sharing information to make the best use of our resources. By working with other forces and partner organisations in Wales, 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.

Due Diligence and Risk Assessment

South Wales Police has continued to advance this work to fulfil the actions agreed and recorded on our local action plan for the period 2023-24.

Policy

  • 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. In addition to this, we are supportive of the principles in the Bluelight Commercial Responsible Procurement & Commissioning Strategy
  • Ethical procurement is reflected in the Force Delivery Plan, deliberately recognising ethical procurement as a tool in the creation of a more hostile environment for modern slavery.
  • Our recruitment policy reflects our commitment to developing the overall structure of equality, diversity and inclusion in our workforce and in the services we provide.
  • Our Business Interest Policy reflects the Welsh Government Ethical Employment in Supply Chains Code of Practice. Officers and staff must be aware of the Code when submitting a business interest approval request.
  • The Welsh Government Code of Practice is a standard agenda item on the agenda of our trade unions.
  • The Force’s Modern Slavery Policy for frontline officers is reviewed annually by the Force Intelligence & Organised Crime Unit.
  • Other relevant policies include the College of Policing Code of Ethics and All Wales Whistleblowing policy to empower staff to raise suspicions of any unlawful and unethical employment practice.

Procurement procedures

  • Where appropriate and proportionate, we are using the Bluelight Commercial Social Value Toolkit to ask bidders how they are tackling modern slavery within their organisations and supply chains. We score social value in our tenders to demonstrate how we expect our suppliers to reflect our response and in turn, assist the force in delivering a range of social value initiatives.
  • We continue to increase awareness in order to deliver a culture of wider responsibility within the Force for those involved in the procurement of goods and services, considering not only ethical supply chains but decarbonisation and sustainability, ethical business practice and support for local business and our communities
  • Our standard contract terms and conditions include the right to investigate and establish accountability and a commitment by the winning bidder to complete an assessment questionnaire to establish a baseline where appropriate.
  • We continue to share best practice and our work to assess suppliers with the Welsh forces and other Welsh public sector organisations.

Payment Performance Statistics

Invoice payment performance statistics are published annually on the Police and Crime Commissioner’s website in line with the statutory requirement.

Assessing existing suppliers and supply chains

  • In order to progress this initiative nationally and provide an effective tool for all police forces, Thames Valley, West Mercia, South Wales and Gwent Forces worked with Bluelight Commercial to upgrade sections of the Social Value Planning Tool to assess:
    • modern slavery
    • ethical business practice
    • climate emergency
    • equality, diversity and inclusion
    • social and community contribution
  • Through contract management, we are evidencing examples of our suppliers reflecting our modern slavery code of ethical procurement within their organisations and offering tangible social value.

Training and awareness raising

Completion of annual CIPS (Chartered Institute of Purchasing and Supply) refresher training by strategic procurement staff

  • We continue to signpost officers and staff with responsibility for contracts across to attend the Fundamentals of Contract management training provided by Bluelight Commercial. The training includes an awareness of ethical supply chains.
  • Ethical dilemma scenarios are shared across the Welsh forces to improve awareness of ethical matters across the forces.
  • Recruitment, promotion, interview and related internal processes encourage equality, diversity and inclusion good practice.
  • A communications plan is in place to ensure staff are aware of and trained in the internal referral routes for highlighting modern slavery concerns where they emerge.
  • The success of this work is reported into the Welsh Forces’ Finance Joint Assurance Group and at the All Wales Collaboration Board Group, by the Chief Financial Officer.

Living Wage

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 can evidence this in response to the fair working practice question in relevant tenders.

Reporting

Progress update reports will be provided to the Chief Financial Officer as the Anti-Slavery and Ethical Champion for South Wales Police

Reporting Concerns

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.