Black Country Healthcare NHS Foundation Trust
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Modern Slavery Statement 2017/18

This statement is made in pursuant to section 54 of the Modern Slavery Act 2015 and sets out the steps that Black Country Partnership NHS Foundation Trust has taken and continues to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Definition of Offences

Slavery, Servitude and Forced or Compulsory Labour

A person commits an offence if:

  • The person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or;
  • The person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.
Human Trafficking

A person commits an offence if:

  • The person arranges or facilitates the travel of another person (victim) with a view to being exploited.
It is irrelevant whether the victim consents to travel and whether or not the victim is an adult or a child.


A person is exploited if one or more of the following issues are identified in relation to the victim;

  • Slavery, servitude, forced or compulsory labour.
  • Sexual exploitation
  • Removal of organs
  • Securing services by force, threats and deception
  • Securing services from children, young people and vulnerable persons.
Black Country Partnership NHS Foundation Trust (BCPFT) is a major provider of mental health, learning disability and community healthcare services for people of all ages in the Black Country.

We provide:

  • Mental health and specialist health learning disabilities services to people of all ages in Sandwell and Wolverhampton.
  • Specialist learning disability services in Walsall, Wolverhampton and Dudley
  • Community healthcare services for children, young people and families in Dudley

BCPFT statement of response:

In accordance with the Modern Slavery Act 2015, BCPFT makes the following statement regarding the steps it has taken in the financial year 2016/17 to ensure that Modern Slavery i.e. slavery and human trafficking, is not taking place in any part of its supply chains.

BCPFT is committed to ensuring that there is no Modern Slavery or Human Trafficking in our supply chains or in any part of our business. We are committed to social and environmental responsibility and have zero tolerance for Modern Slavery and Human Trafficking. Any identified concerns regarding Modern Slavery and Human Trafficking are escalated as part of the organisational safeguarding process working in conjunction with our partner agencies.

The Trust;

  • Adheres to the National NHS Employment Checks / Standards (This includes checking employees UK address, right to work in the UK and suitable references).
  • Have systems to encourage the reporting of concerns and the protection of whistle blowers.
  • Has a Freedom To Speak Up Guardian that all staff can access to raise concerns
  • Has a Trust wide safeguarding forum which has membership from all clinical divisions.
  • Ensures full implementation of the Trusts Safeguarding Adults Policy and the West Midlands Safeguarding Adults Procedures through the multi divisional safeguarding forum led by the Associate Director for Safeguarding
  • Participates in the multi-agency Safeguarding Adult Boards and associated sub groups within Dudley, Sandwell, Walsall and Wolverhampton.
  • Provides links to the various referral processes for adults and children who may be experiencing or at risk of experiencing harm within the Safeguarding Adults Policy, the Safeguarding Children Policy  and on the Trust intranet.

The plan for 2017/18

In addition to the above actions, BCPFT will measure its performance against the following indicators:

  • The Trust will strive to build long standing relationships with our suppliers and make clear our expectations of business behaviour. Where national or international supply chains are used, we expect these suppliers to have suitable anti-slavery and human trafficking policies and procedures and where there is a risk of Slavery and Human Trafficking taking place, steps will be taken to assess and manage that risk.
  • To develop a level of communication with the next link in the supply chain and their understanding of, and compliance with, our expectations in relation to the NHS terms and conditions. These conditions relate to issues such as bribery, slavery and other ethical considerations.
  • To work in partnership with Multi-Agency partners leading on this agenda in the West Midlands and ensure that BCPFT is represented on these Committees.
  • To ensure that Modern Slavery and Human Trafficking training is available to staff and in 2018/19 ensure it is fully incorporated into safeguarding adult and children training.