The John Rowntree Foundation highlighted slavery within the health and social care workforce within its 2007 publication Modern Slavery in the United Kingdom.

This document provides a public statement of Sense Scotland’s commitment to take action to promote fair treatment of those involved in its supply chains. It will therefore be posted publicly on its website, with a link from the homepage, as well as being included in staff guidance.

Businesses with a turnover of over £36m per year have been required to provide an annual Modern Slavery Statement from the financial year-end of March 2016 onwards, within 6 months of each year-end. This requirement is in The Transparency in Supply Chains provision in the Modern Slavery Act 2015. Sense Scotland does not meet the turnover threshold where a statement is required, but has decided to follow best practice and will in future provide an annual statement, to be reviewed in line with its annual accounts. The statement will outline the steps the organisation has taken to ensure the people it supports and workers within its supply chain are not exploited.

The statement will be reviewed annually to note any changes or new steps taken to improve on Sense Scotland’s actions, and will be signed by the Company Secretary.

To provide a public statement and inform all stakeholders of Sense Scotland’s approach to protecting the people it supports and workers in its supply chains. It reflects measures taken by all functions of the organisation to protect people against exploitation.

It is provided for information for anyone interested in the activities of Sense Scotland. It sets out Sense Scotland’s expectations, but in order to take a proportionate approach, reporting from suppliers will only be required from those which meet the legislative requirement.

UK Government – Transparency in Supply Chains etc. – A practical guide

UK Government – Modern Slavery Act 2015 (only some relates to Scotland)

Modern Slavery is defined by the UK government as: “slavery, servitude and forced or compulsory labour and human trafficking.”

Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/she did own the person, which deprives the victim of their freedom.

Servitude is the obligation to provide services that is imposed by the use of coercion and includes the obligation for a ‘serf’ to live on another person’s property and the impossibility of changing his or her condition.

Forced or compulsory labour is defined in international law by the International Labour Organisation’s Forced Labour Convention 29 and Protocol. It involves coercion, either direct threats of violence or more subtle forms of compulsion. The key elements are that work or service is exacted from any person under the menace of any penalty and for which the person has not offered him/herself voluntarily.

An offence of human trafficking 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. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation.

Supply chain, for the purposes of this policy, refers to any person or organisation with a turnover in excess of £36m which are involved in supplying goods or services to Sense Scotland.

Heads of Departments are responsible for ensuring any of their staff involved in contracting or purchasing are aware of this statement.

Staff are responsible for suggesting any improvements to Sense Scotland’s practice, which will be considered by the appropriate forum for the subject, e.g. Partnership Forum, Finance Committee etc.

The Organisation is responsible for reviewing this statement annually, posting it publicly and continually improving its systems where possible or required.

This is Sense Scotland’s first Modern Slavery Statement.

Sense Scotland is part of a family of organisations with charitable purposes, registered in accordance with their geographical area. Sense Scotland has zero tolerance of any exploitation of vulnerable people.

The organisation’s supply chains include:

• The provision of food to its café and other food handling services.
• Stationery to all offices.
• Medical supplies.
• Utilities.
• Banking/financial services.
• Maintenance contractors, including fire equipment, manual handling equipment, legionella monitoring etc.
• Staffing agencies.
• IT equipment and systems support.
• Fundraising event suppliers.
• Consultancy services.
• Auditors and other professional services.

Most of these activities have a low likelihood of exploitation of workers. It is expected most risks to be attached to suppliers which have global supply chains, for example food sourced from some countries abroad and, within the UK, food produced via forced labour. Migrant workers are also at particular risk.

We will expect suppliers meeting the turnover threshold noted under ‘Scope’ and which are employers, to pay the National Living Wage as a minimum to their UK staff. We will expect all suppliers to comply with all Employment Law, remuneration and other legislative requirements in all countries where they operate. All suppliers must provide safe and fair working conditions wherever they operate, and not be involved in child labour or require excessive working hours.

We will conduct due diligence on new suppliers or prospective service delivery partners meeting the turnover threshold set out under ‘Scope’ to ensure they have no convictions in relation to Modern Slavery and any new contracts will establish that this will be a reason for contract termination.

Whilst we will not carry out the same level of examination of employment practices of smaller scale suppliers, e.g. local shops, our purchasing activities will take account of any intelligence which comes to our attention relating to exploitative practice by suppliers of any size.

Sense Scotland’s policies all identify the responsible role for responding to concerns relating to that policy.

Sense Scotland has a Human Rights Policy, and all other staff guidance must be compliant with the Human Rights approach which incorporates Sense Scotland’s position on Equality and Diversity in Employment.

Sense Scotland’s Grievance and Dignity at Work Conditions of Service enable staff to raise complaints about their working conditions.

Sense Scotland has a Whistleblowing Policy.

Sense Scotland’s Health and Safety Policy and associated procedures ensure that the organisation’s staff have a safe working environment, and that where risks are identified, they are responded to positively.

Sense Scotland’s Comments, Compliments and Complaints procedures provide guidance on how to raise and escalate concerns, including to outside agencies.

Sense Scotland works with vulnerable children and adults and has safeguarding and protection policies and procedures which provide reporting procedures in the event that any staff member has concerns that a vulnerable person is being exploited, whether or not they are supported by the organisation. Staff are trained in protection issues. These policies and procedures are: Protecting and Safeguarding Children and Young People and Protecting Adults.

Sense Scotland has a Social Responsibility and Environmental Policy which outlines the steps it takes to provide benefit to communities and minimise any negative impacts from its actions.

In addition to the policies noted above, Sense Scotland has an Ethical Fundraising Policy and a Professional Conduct Policy.

For more information about the policies, please get in touch.

Sense Scotland has taken steps through its staffing agency procurement to ensure good conditions for all staff involved in delivering support to users of its services.

Sense Scotland complies with Safer Recruitment through Better Recruitment 2016 guidance, which involves a number of background checks.

Sense Scotland is a member of a number of umbrella and professional organisations which aim to promote best practice in their respective fields.

Sense Scotland will monitor incidents of exploitation through the following mechanisms, to inform whether it is doing all it can to fulfil its intentions to exclude all forms of Modern Slavery from its own activities and its supply chains: grievances, whistleblowing, complaints, and the termination of contracts due to Modern Slavery convictions.

This statement and associated policies will be reviewed in light of emerging information about Modern Slavery in supply chains, to reflect additional or amended safeguarding systems and to take account of existing suppliers which have met the turnover threshold.