Introduction
The Office of the Police and Crime Commissioner for Warwickshire (OPCC) has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery within the business or our supply chain.
The OPCC considers the obligations placed on commercial organisations under section 54(1) of the Modern Slavery Act 2015 vital in combating modern slavery and human trafficking. Although we are not a commercial organisation and are therefore not required under the Act to make a modern slavery statement, we are making this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains.
About the organisation
The OPCC supports the Police and Crime Commissioner for Warwickshire in the delivery of his Police and Crime Plan.
The OPCC operates in the United Kingdom, whilst the risk of slavery and human trafficking is considered low, staff within the OPCC remain vigilant and will take steps available to manage the risks presented.
The job of the Police and Crime Commissioner (PCC) is to ensure the policing needs of their communities are met as effectively as possible, bringing communities closer to the police, building confidence in the system and restoring trust. PCCs give the public a voice at the highest level and the ability to ensure their police are accountable.
Key aspects of the role of PCCs include:
- holding the chief constable to account for the delivery of the force ° setting and updating a Police and Crime plan
- setting the force budget and precept
- regularly engaging with the public and communities
- appointing, and where necessary dismissing, the chief constable.
What is Modern Slavery?
Modern Slavery is an umbrella term, encompassing human trafficking, slavery, servitude and forced labour. Slavery is where someone is forced to work through a level of threat, owned or controlled, dehumanised, or who has restrictions placed on their freedom. Servitude is similar to slavery, but there is no element of ownership. Human trafficking is the movement of people who are then forced into exploitation, the movement can be international but also within a country, from city to city or within a few streets.
There are a number of different types of exploitation that victims of modern slavery may be subjected to, and victims may experience more than one type of exploitation at the same time.
The most common forms of exploitation are:
- Sexual exploitation
- Labour exploitation
- Forced criminality
- Organ harvesting
- Domestic servitude.
Our policies
We operate a number of internal policies directly, alongside policies held by Warwickshire Police to ensure that we are conducting business in an ethical and transparent manner. These reflect our commitment to implementing and enforcing effective systems and controls to safeguard against slavery and human trafficking taking place in our supply chains. These include:
1. Code of Conduct for Staff and Representatives
The OPCC is publicly accountable and frequently works in partnership with other organisations, both in the public and private sector. it is therefore vital that all staff and representatives of the PCC conduct themselves in an exemplary manner in all aspects of their work and show no bias whatever their personal or political views might be.
2. Whistleblowing Policy
The Whistleblowing Policy is intended to provide a vehicle for individual employees to raise issues of concern where they reasonably believe, in good faith, that an act or acts of malpractice have occurred in the OPCC.
3. Safeguarding Policy
The Safeguarding Policy recognises that safeguarding is everyone’s business and seeks to ensure that OPCC staff and volunteers undertake their responsibilities with regard to the protection of children and adults at risk, and respond to concerns appropriately, even though they are not in roles where they are responsible for diagnosing, investigating or providing a therapeutic response to abuse.
4. Other Policies
A number of policies are shared with Warwickshire Police, these include but are not limited to:
- Fairness at work. The OPCC and Warwickshire Police are committed to ensuring that all individuals are treated with respect and the Fairness at Work Policy provides an avenue for individuals to raise concerns and to seek resolution.
- Welfare Services. The service aims to assist in maintaining the emotional well-being and resilience of the workforce and to protect, as far as possible, all personnel from psychological harm.
The above policies are regularly reviewed to ensure they continue to be relevant.
Employee training
The OPCC is committed to ensuring relevant training is available to all members of staff, and awareness raising and links to relevant legislation and information is shared. This includes but is not limited to:
- Documents and promotional material related to the government’s work to end modern slavery
- Relevant reports and findings arising from the activity of inspectorate bodies such as Her Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) and the Office for Standards in Education (Ofsted)
- Locally developed learning, such as the e-learning package entitled “See Past the Obvious — Vulnerability and Serious Crime”, which has been developed in partnership with Warwickshire Police and Warwickshire County Council.
Supply Chain and Due diligence
The OPCC has limited resources to monitor and manage the supply chains of direct suppliers of services. The OPCC considers that, due to the nature of its business, there are no areas of its business that are considered high risk of slavery or human trafficking. However, to help identify and monitor the risk of slavery and human trafficking, the OPCC does undertake due diligence when considering new suppliers by working in partnership with colleagues in the procurement team of Warwickshire Police and for jointly commissioned services, Warwickshire County Council.
To vet suppliers and to ensure they are committed to ethnical labour practices, the OPCC has reviewed its Terms and Conditions of grant funded, donated or commissioned service contracts and these will now include the following wording:
“The Customer is committed to ensuring that workers employed or engaged in its supply chains throughout the world are treated fairly, humanely and equitably and to this end the Contractor shall comply, and shall ensure that its Sub-contractors comply, in relation to all workers employed or engaged by it directly or indirectly in connection with the supply of the Goods and/or performance of the Services, with the Modern Slavery Act 2015 and with the policies, procedures and requirements of the International Labour Organisation the United Nations Universal Declaration of Human Rights and the Ethical Trading initiative (“ET1”) Base Code or an equivalent code of conduct (the “Ethical Sourcing Principles”).”
Within the OPCC’s procurement process the supplier assurance questionnaire requires all prospective suppliers to acknowledge their compliance with the principles outlined below and confirm that they will make all reasonable endeavours to ensure compliance across their supply chains. Where applicable a link to their modern slavery statement must also be provided as part of the supplier assurance submission.
Section 7 – Modern Slavery Act 2015
Principles:
Not to employ, support or condone any form of Modern Slavery or Human Trafficking and to comply with the Modern Slavery Act 2015 and not to use forced, involuntary or underage labour.
- Employees should be free to choose their employment and leave that employment without hold by financial deposit or personal items.
- Forced, bonded or involuntary prison labour shall not be used.
- Support the effective abolition of child labour.
- Comply with the national minimum age for employment, unless a lower local minimum age is permitted under International Labour Organisations (ILO) convention 138.
- Where any child is found to be engaged in or performing child labour, to provide support for that child to enable them to complete, as a minimum, their compulsory education (even if they shall cease to be involved in child labour), or an equivalent educational level, as provided for under the UN Covenant on Economic, Social and Cultural Rights. Such support by the supplier should recognise and not prove detrimental to the conditions of the child or those that their work supports.
To provide suitable working conditions and terms
- For staff aged 25 and over and not in the first year of an apprenticeship, at least the National Living Wage must be paid in accordance to the rates detailed at https://www.livingwage.gov.uk/ as updated from time to time.
- For staff under 25, at least the right rate of National Minimum Wage must be paid in accordance to the rates detailed at https://www.gov.uk/national-minimum-wage/employers-and-the-minimum-wage as updated from time to time.
- The above must be paid without discrimination to all employees and all non-statutory deductions must be with the consent of the employee.
- Working hours must not be excessive. A safe and hygienic environment is provided.
- Any hazardous working, as defined by ILO, should only be carried out by persons aged 18 years or over.
- Policies and processes must be in place for recording and eliminating occurrence/reoccurrence of health and safety related incidents.
To treat employees fairly
- Allow employees the freedom of association to join (but not be forced to join) or be represented by a trade union or similar organisation of their choice.
- Provide a workplace free from discrimination, harassment or victimisation.
- Treat all employees with respect and dignity, and not accept inequality as justifiable of any characteristics listed above, unless statutory conditions require otherwise.
- Remunerate all employees equally at the same employment grade, regardless of any characteristics listed above, unless statutory conditions require otherwise.
Warwickshire Police reserves the right to seek further evidence of your approaches to ensuring that Modern Slavery in all its forms is not occurring within your supply chains. Should your organisation’s turnover be £36M or above, you are required to publish a Modern Slavery Statement annually.
| Insert link to your Modern Slavery Statement |
Investigation
Any concern regarding the OPCC’s ethical trading principles or the steps we are taking to tackle modern slavery and human trafficking in our business and in our supply chains, should in the first instance be raised with our Chief Executive & Monitoring Officer, either by email at opcc@warwickshire.police.co.uk or by telephone on 01926 733520.
Our performance indicators
We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:
- No reports are received from employees, the public, or law enforcement agencies to indicate that modem slavery practices have been identified.
The OPCC will provide information to Warwickshire Police and Warwickshire County Council on request to enable them to satisfy any further performance measures.
Approval for this Statement
This Statement relates to the financial year 2024-25 and has been approved by the Police and Crime Commissioner for Warwickshire:
Philip Seccombe TD
Police and Crime Commissioner for Warwickshire
