Modern Slavery Statement 2025 to 2026

Brighton & Hove City Council remains committed to ensuring that public money is spent responsibly and our activities and those working on behalf of the authority are conducted in an ethical, responsible and sustainable manner. 

Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 requires certain organisations to publish an annual modern slavery statement outlining the actions taken each year to tackle modern slavery risks within their operations and supply chains. While not required by the transparency provision to publish a statement, Brighton & Hove City Council recognises the important role the public sector must play in helping to address this critical issue and has voluntarily chosen to report on our activities. This is the Council’s 2025/2026 statement. The structure and content of the statement remain the same as our previous statement, with sections updated to reflect key activities undertaken during the 2025/2026 financial year.   

Modern slavery is a heinous crime, with an estimated 50 million victims worldwide and over 100,000 here in the UK. As a local authority, we recognise that we have several roles to play to help address this problem. This includes safeguarding vulnerable adults and children from exploitation and harm, identifying potential victims in our role as first responders, and working to implement measures that protect workers in our operations and supply chains from modern slavery and other unethical labour practices.  

Brighton & Hove City Council is committed to making the city a better Brighton & Hove for all. Our 2023 to 2027 Council Plan outlines the Council’s vision to achieve this, with focus on four outcomes:  

1. A city to be proud of.
2. A fair and inclusive city. 
3. A healthy city that helps people to thrive. 
4. A responsive and learning council with well-run services. 

Our plan aims to ensure that the necessary support, services and infrastructure is in place so that our people, communities and local businesses can flourish. We are committed to inclusivity to ensure that our city is equitable and that everyone feels safe, included and can thrive. We are striving to ensure measures are put in place to meet the needs of both current and future generations. This includes: 

• ensuring our city’s most disadvantaged are not left behind
• ensuring effective infrastructure.
• championing a flourishing local economy 
• tackling the climate and biodiversity emergency 

Additionally, the Council is committed to a positive, respectful and values driven organisational culture. As part of this commitment, we have developed a Learning Organisation Framework to guide our journey to becoming a Learning Organisation and creating a better Brighton & Hove for all.  

Our framework is built on five pillars:  

1. Be connected. 
2. Be confident. 
3. Be innovative and creative. 
4. Be diverse and inclusive. 
5. Be healthy and psychologically safe. 

These principles directly support our efforts to tackle modern slavery and broader unethical labour practices by ensuring that our staff feel empowered, included in decision-making and supported in their health and wellbeing. Poor labour practices often manifest in organisations that lack measures to protect staff from issues such as exploitation, discrimination and unsafe working conditions. These issues can create environments where unethical labour practices can thrive, and our Learning Organisation Framework helps safeguard against these risks.  

Our 2025 to 2026 modern slavery statement provides an update on all six areas recommended by Section 54 of the Modern Slavery Act 2015: 

• our organisation structure and supply chains 
• policies in relation to modern slavery 
• risk assessment 
• due diligence measures 
• how we measure our performance, and 
• training available to our staff 

The Council recognises the important role the public can play in shining a light on modern slavery practices. As Section 54 of the Modern Slavery Act 2015 encourages public scrutiny of modern slavery statements, we have included information for reporting cases of suspected or actual cases to the relevant authorities.  

Due to the complex and ubiquitous nature of modern slavery, there are different people, teams and local partnerships working to address it and related concerns such as issues around vulnerability and safeguarding. Consequently, it is challenging to document all activities including training, support and correspondence. Therefore, this statement may not fully reflect all actions taken by the authority, but it provides insight into key activities with certain sections of the document updated as necessary.

This statement has been updated to reflect the authority’s current approach and activities undertaken in the 2025 to 2026 financial year. It relates to key steps taken by the Council between 1 April 2025 and 31 March 2026. 

Brighton & Hove City Council provides a range of services to over 250,000 residents in Brighton & Hove including providing social care to children and the elderly, delivering services as diverse as maintaining roads, through providing libraries to waste management services. The Council employs approximately 4,500 staff corporately. 

Our Corporate Leadership Team provides strategic direction to the whole council which is organised into the following directorates and services: 

• City Operations  
• Families, Children and Wellbeing  
• Homes and Adult Social Care 
• Governance and Law 
• People and Innovation 
• Property and Finance 
• Cabinet Office 
• Corporate Leadership Office 

At the time of drafting this statement, Brighton & Hove City Council have a shared procurement service with Surrey County Council and East Sussex County Council. However, in early 2026, following a review of the service through respective governance routes, all three Councils have agreed to move towards a sovereign operating model, enabling services to better support their individual strategic priorities. Brighton & Hove City Council’s procurement service will transfer back to the Council in August 2026. 

The Council has been working with its partners to support a smooth and orderly transfer, including the handover of relevant information, knowledge and responsibilities. Brighton & Hove City Council is committed to maintaining appropriate oversight of modern slavery and unethical labour risks throughout the transfer and to building on the work and learning developed through the partnership within its future procurement arrangements. 

The measures outlined in this statement to address modern slavery risk, particularly those within our supply chain, were carried out through the inter authority agreement. Despite this agreement coming to an end, the Council remains committed to tackling this issue and will continue to build on work undertaken and lessons learned during the partnership.  

Beyond work undertaken in our procurement service to mitigate modern slavery risks in our supply chains, the Council also has people and teams across the authorities working on addressing related concerns such as issues connected to abuse, vulnerability, safeguarding, and community and partnership.

During the 2025 to 2026 financial year the Council spent approximately £512m with 3,944 suppliers.

Brighton & Hove City Council recognises the importance of policies to communicate our commitments and expectations of our staff, suppliers, and those who we do business with, to effectively address modern slavery. 

We also recognise that modern slavery sits on the extreme end of the labour exploitation continuum. Therefore, we have several policies, procedures, and codes of conduct with respect to abuse, fair labour and employment conditions that work to prevent and respond to a range of issues, including modern slavery, in our operations and supply chains. 

This includes:

• whistleblowing
• recruitment
• health and safety
• grievance policies

Details of key policies and their relevance to modern slavery can be found in the Annex.

As a public sector body, we recognise the risk of modern slavery facing vulnerable people and service-users in our community, as well as workers in the supply chains supporting our activities. We also acknowledge that modern slavery is an issue that is prevalent in the UK. While we have an ambition to work with local supply chains, the risk of exploitation still exists as the unfortunate reality is that no supply chain is entirely free of modern slavery or unethical labour practices. 

Modern slavery can take place at any stage of a supply chain, from the extraction of raw materials to the delivery and use of a final product while people delivering and receiving services can be subjected to exploitative practices by perpetrators internal and/or external to an organisation. 

To aid our understanding of risks and inform our due diligence approach, we regularly consult and communicate up-to-date information on high-risk goods and services within the UK and beyond. Regarding modern slavery concerns in services we provide and the communities we serve, we recognise vulnerable service-users including children, young people, and vulnerable adults. Within our supply chains, we recognise risks in our third party spend. 

Risk assessment of exploitative labour practices is embedded in our day-to-day procurement activity and is carried out on a project-by-project basis. This is primarily a desk-based exercise and led by our Senior Policy Lead on Modern Slavery in our Procurement's Policy Team, supported by the Corporate Procurement Team. The frequency of these assessments ensures that due diligence is applied consistently across high-risk categories and in new procurements where risks may be less familiar. We consider risks to workers involved in delivering the core service, and over the past financial year have started taking action to understand and address risks affecting workers further down the supply chain, such as those carrying out cleaning, repair, and maintenance roles to support the delivery of core services.  

Our approach to risk assessment draws on a broad range of sources and considers risks across the spectrum of labour exploitation, recognising that the lines between unethical labour practices and modern slavery can often be blurred, with poor labour practices risk escalating to labour exploitation if not addressed.  

To support our risk assessment, we draw on a range of sources. 

Key sources include, but are not limited to:  

• statutory guidance - such as Procurement Policy Note 009: Tackling Modern Slavery in Government Supply Chains, which provides direction for commercial and procurement professionals  
• research publications -  including UK and international research on modern slavery and global resources such as the Global Slavery Index 
• industry reports - which progress our understanding of sector-specific risks, trends, and issues
• parliamentary reports - including findings and recommendations from parliamentary inquiries and committees
• non-governmental organisation reports - which provide valuable frontline perspectives and evidence on exploitation risks

Given the large number of procurements delivered, risk assessment helps us to identify projects to prioritise for due diligence. When assessing risks there are numerous characteristics that are taken into consideration such as the industry type, nature of the workforce, and business and supply chain model. The highest risk areas include construction, adult social care, facilities management, cleaning, waste management, and certain projects that support transition to a low carbon economy, such as those involving solar panels. Common risk factors in these sectors include complex supply chains, extensive subcontracting, reliance on agency labour, and the vulnerability of low‑paid or marginalised workers.  

In our risk assessment we also give consideration not only to our exposure to modern slavery, but opportunities to manage those risks. To fully understand project specific risks, close engagement is often required between the Senior Policy Lead on Modern Slavery, service stakeholders (such as commissioners and contract managers), and procurement officers.   

Due to the activities and services we undertake and deliver as a local authority, we expect the type of risks we are likely to encounter to remain consistent and unlikely to vary significantly, however, incorporating risk assessment into our day-to-day procurement processes ensures that we are able to capture projects with new or emerging risks. 

This section of our statement reports on activities aimed at understanding and managing risks within our operations and communities and our supply chains.  

Our operations and communities 

The Council has numerous legal responsibilities to protect and safeguard vulnerable adults, children and young people. Under the Care Act 2014 we have a duty to safeguard adults with care and support needs. We also have a duty under child protection legislation, notably the Children Act 1989, the Children Act 2004 and the Children and Social Work Act 2017 to safeguard children and young people in need in our local area. 

Brighton & Hove City Council is also first responder organisation. This means we have a responsibility to refer potential victims into the National Referral Mechanism (NRM). This is the government's framework for identifying and supporting potential victims of modern slavery. Under section 52 of the Modern Slavery Act 2015, we have a statutory duty to notify the Home Office of potential victims of modern slavery that we come across. 

Adults who give their consent and child victims can be referred into the NRM. Where a potential adult victim has not consented to a referral, the Council still has a duty to notify (DtN) the Home Office to support intelligence gathering. 

In 2025, 23,411 potential victims of modern slavery were referred to the Home Office.  

Of these, Brighton & Hove City Council referred 25 potential victims into the NRM. Of the 25 potential victims, 18 were children (aged 17 and under). One DtN referral was also made. 

With regards to adult safeguarding, Section 42 of the Care Act requires local authorities to make enquires, or ask others to do so, if they believe an adult with care and support needs is at risk of abuse or neglect in their area and to find out what, if any, action may be needed to protect them. The Care Act 2014 includes modern slavery as a type of abuse, as well as being a serious crime, therefore, managing cases of modern slavery is closely linked to safeguarding adults procedures. 

A section 42 duty is triggered when three requirements of the Care Act have been met. This is when an adult: has care and support needs, is experiencing or is at risk of abuse or neglect and as a result of those care and support needs is unable to protect themselves from the risk or experience of abuse or neglect. 

During the 2025 to 2026 financial year, 3 safeguarding cases reported as a modern slavery concern progressed to a section 42 safeguarding enquiry. This figure only reflects the cases that have been enquired upon and is not indicative of all safeguarding concerns received by the local authority.  

Our supply chains  

As the authority delivers hundreds of projects annually, we rely on a range of risk management 'pinpoints' and internal systems to identify and address risks in our procurement activity. We continued to maintain our efforts to combat slavery in our supply chains and in the last financial year have focused on strengthening our approach to managing risks in our tendering activity. Key due diligence work undertaken during 2025 to 2026 included:  

Project resourcing

The Procurement service’s Policy Team reviews requests made by Strategic Procurement Managers for resources (such as a Procurement Specialist) to support projects. This review is undertaken on a weekly basis to identify projects that may need input from the Senior Policy Lead on Modern Slavery. When a project is flagged, an automated email is sent to the project lead instructing them to engage with the policy lead. This process ensures that the policy lead is engaged once formal procurement activity begins.  

Procurement forward plan

The Procurement Data and Analytics team provide the Senior Policy Lead on Modern Slavery with a weekly updated report of projects, including those that have been recently added to our project management system. Projects have several filters applied, such as limiting to those that are Active or Pending and due to mobilise within the next 24 months. The policy lead uses this forward plan to track progress of projects and engagement with procurement leads to ensure management of modern slavery and unethical labour risks where required.  

Collaboration and engagement

Our Senior Policy Lead on Modern Slavery has regular meetings with members of the Corporate Procurement Team to discuss project scopes and potential risks. As projects can be at different stages, they engage regularly to ensure the policy lead is kept updated on projects as they progress. Procurement officers also connect the policy lead with other key stakeholders such as consultants, commissioning teams, and framework managers to discuss risks and due diligence measures.  

Procurement activity

Where a project is recognised as high-risk and there is an opportunity for risk management, the Senior Policy Lead on Modern Slavery is on hand to embed appropriate due diligence requirements in tendering activity. This includes supporting market engagement (such as communicating risks and expectations to the market), establishing specification requirements, drafting technical questions and reviewing award criteria, and advising on contract terms and conditions (which are reviewed and signed off by the legal team). The policy lead also supports the evaluation and moderation of modern slavery questions as the subject matter expert. Where a framework is being used for a high-risk project, the policy lead reviews existing framework materials, including terms and conditions, to understand what considerations around modern slavery were built into it and explores ways to strengthen these in call offs.  

Training

Regular training continues to be delivered to the procurement service to keep them up to date on approaches to managing modern slavery risks (see next section on training). 

Preparing for new regulations

The Council has taken several measures to prepare for the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 and associated guidance that entered into force May 17, 2026. This included: attending webinars delivered by the Department of Health and Social Care and NHS on implementing the regulations; issuing comms to procurement staff via our internal intranet to raise awareness of the regulations; and reviewing existing systems and internal guidance for procurement to support implementation 

Additional procurement checks

In addition to the above, other checks typically undertaken within the procurement service for projects at risk of modern slavery and unethical labour practices include: reviewing past activity and checking procurement materials to understand what actions, if any, were taken to manage risks; assessing sector and supply chain risks and the market’s response (e.g. reviewing Modern Slavery Statements); considering the urgency and contract length of projects to determine what is feasible to implement during tendering and the contract lifecycle; and confirming route to market and appropriate actions to manage risks – for example, if using a framework, engage with the framework manager to identify opportunities to strengthen requirements in call offs/mini competition.   

Reporting

Published a modern slavery statement outlining activities undertaken to tackle modern slavery during the 2024 to 2025 financial year on our website and on the Government’s modern slavery registry. 

The Council continue to have the following training available to all staff on our e-learning platform. 

Overview of modern slavery 

This is a 1 hour and 30-minute e-learning course which provides an understanding of modern slavery and the Council’s procedure for working with people that may have experienced modern slavery or human trafficking. The course contains two e-learning modules. 

The first module provides a brief overview of modern slavery and requirements around greater transparency to tackle modern slavery. The second module provides guidance on the Council’s Modern Slavery Pathway Procedure for working with victims and includes information on referring potential victims into the NRM. 

Introduction to modern slavery in supply chains 

This is a 60-minute e-learning course designed by the Council’s Senior Policy Lead on Modern Slavery in the procurement service to help staff in supply chain management roles understand the unique issue of modern slavery in supply chains. 

It includes information on key findings of the Global Slavery Index 2022 in relation to forced labour in supply chains, the current legislative landscape, the International Labour Organization’s Indicators of Forced Labour, high-risk sectors for forced labour, examples of cases within the UK and public sector responsibility for addressing modern slavery risks within our supply chains. This training was developed to ensure consistency in training received for staff working in procurement as well as others in operational roles. 

In addition to the training available above, during the 2025-2026 financial year, two knowledge-share training sessions, lasting between 1 hour and 1.5 hours, were delivered by Procurement’s Policy Team, including the Senior Policy Lead on Modern Slavery, to the service. These sessions focused on the National Procurement Policy Statement (NPPS) which sets out central government’s strategic priorities for public procurement and how contracting authorities can support their delivery. 

The NPPS requires all contracting authorities to have regard to these priorities when exercising their functions relating to procurement and where it is relevant to the subject matter of the contract and it is proportionate to do so. Having regard means that contracting authorities must consider whether the procurement can contribute to achieving one or more of the policy objectives stated in the NPPS in a manner that is appropriate, proportionate and relevant and take steps to address this where it can. 

The NPPS requires the Council to consider issues such as fair working conditions and ensure that suppliers are committed to safe and healthy working conditions and actively working to tackle modern slavery and human rights violations and comply with employment law and other legal obligations. 

The first session delivered to the Procurement service aimed to raise awareness on the NPPS, its importance, and how to have regard to its priorities when undertaking a procurement. The second session explored the priorities in greater depth and outlined the Policy Team’s approach to ensuring that these and the Council’s own priorities are reflected in our service offer and procurement activity. This included: a brief refresher on modern slavery; a reminder of what we are trying to achieve in relation to modern slavery risk management; the factors that influence and shape this work; how projects are prioritised for modern slavery due diligence; and examples of how modern slavery considerations have been embedded. 

Our general approach to tackling modern slavery, particularly within our supply chains, is heavily informed by existing research, best practices, and statutory guidance. Research on modern slavery statements often report that one of the areas organisations tend not to report on are indicators to measure effectiveness of anti-slavery efforts. The Council therefore recognises this as an area for improvement and is working to strengthen how we measure our overall approach. As aforementioned, a challenge the Council faces with tracking actions to tackle modern slavery and consequently their effectiveness, is the number of activities and correspondence undertaken in this area by different people, teams and services across the authority, particularly those that handle concerns such as safeguarding whose work captures modern slavery issues alongside others.   

The indicators below have been drawn from and inspired by external guidance and demonstrate what our organisation believes is feasible for us to monitor at this stage in our journey to managing modern slavery risks. These indicators support our anti-slavery efforts by:

• helping us to understand potential risks
• ensure that we are taking action
• understand the effectiveness of our approach
• identify areas that require improvement

We will monitor and report on our indicators on an annual basis in our modern slavery statements.    

Potential cases of modern slavery

Performance status

Challenges or limitations

Reports of potential cases of modern slavery can be made through various channels within the local authority and the process for addressing different types of concerns may differ. As a result, the number of cases that have been reported in this statement may not reflect all potential cases or concerns received by the local authority.

Why we are measuring it

Identifying cases not only ensures that potential victims have access to necessary support, but also gives us insight into the risks we may encounter as an authority, vulnerabilities within our community, operations, and supply chains, and our overall response to these challenges.

How we are measuring it

Number of reports made through the following channels:

• Our whistleblowing helpline
• Adult safeguarding enquires
• NRM (end of year summary 2023 statistics)

In 2025 to 2026

• Whistleblowing: 1
• Adult Safeguarding (s42 enquiry): 3
• NRM: 25 referrals and 1 DtN

Training of key supply chain management staff

Performance status

Challenges or limitations

Despite the availability of Council-wide training on our e-learning platform, the authority recognises the importance of providing regular and targeted training for our staff. However, it can be challenging to require this type of training due to the large number of staff members who have various roles and responsibilities. Additionally, staff may have access to training (both internal and external) provided by their teams or services. As a result, the training reported may not accurately reflect all staff members who have accessed modern slavery training.

Why we are measuring it

Targeted training ensures that staff responsible for key aspects of service delivery are equipped with the necessary knowledge and skills to address modern slavery within their specific roles.

How we are measuring it

Number of training delivered to staff and attendance

In 2025 2026

Procurement team:

• number of sessions: 2 
• number of attendees:  
• session 1: 50  
• session 2: 44 

Review active high-risk projects to understand how modern slavery considerations were embedded

Performance status

Challenges or limitations

Due to capacity limitations, it is not feasible to review all current projects that are high-risk of modern slavery practices and engagement with suppliers.  

Why we are measuring it

To leverage insights from active procurements and current contracts to inform our handling of future high-risk projects and our overall approach to managing risks in procurement and contract management activity. 

How we are measuring it

Project sampling across the partnership

In 2025 2026

During the 2025 to 2026 financial year, 18 active projects across the Orbis Partnership with a total contract value of approximately £296m were reviewed by our Senior Policy Lead on Modern Slavery.

For further information on modern slavery and how to spot the signs that someone may be a victim, visit the Unseen  website.

Reports of suspected or actual cases of modern slavery can be made via the following channels: 

• non-emergency concerns: call the Modern Slavery Helpline on 08000 121 700 or local police on 101 (ask for their Modern Slavery Team)
• for concerns about your working conditions and your rights, and abuse or exploitation at work contact the Fair Work Agency 
• emergency, immediate danger, or threat to life situation: call 999
• Brighton & Hove City Council Whistleblowing: Read our Whistleblowing policy for details on how to raise a concern
• concerns for an adult with care needs - contact our Adult Social Care team
• concerns for a child with care needs – contact Front Door for Families

This statement has been approved by the Corporate Leadership Team on 25 September 2025. It will be reviewed and updated on an annual basis.

Signed by: Bella Sankey, Leader of the Council

Date: 25 August 2026 

Signed by: Jess Gibbons, Chief Executive

Date: 4 August 2026

Council Constitution

Our Constitution describes the procedures which are followed to ensure that the Council acts in a way which is efficient, transparent, and accountable to local people. 

The Constitution is divided into several articles, which set out the basic rules governing the Council’s business. The “Contract Standing Orders” is included in the Council’s constitution and sets out how the Council authorises and manages spending and contracts with other organisations. 

This is relevant to tackling modern slavery as it requires consideration to be given to all tenders with respect to sustainability and social value issues. It also includes a specific section on modern slavery which requires Council officers to have regard to the risk of unethical labour practices in the supply chains of goods, services and works that being procured.

Whistleblowing Policy

The Council is committed to applying the highest standards of openness, honesty, integrity, and accountability through the services it provides. However, the Council recognises that there is always the risk that things can go wrong. Therefore, the Council is keen to encourage those working for the Council, its elected and co-opted members, and members of the community to express their concerns when they think that there may be something seriously wrong regarding the activities of the council. This gives the Council the opportunity to stop any unethical or unprofessional practices or wrongdoing within the organisation. 

Our Whistleblowing Policy sets out how concerns about serious wrongdoing by the Council can be raised and how the Council will respond to these. This policy is important for individuals wanting to raise concerns about modern slavery and/or related issues.   

Sustainability and Social Value

Our Environmentally Sustainable Procurement Policy sets how sustainability will be embedded into every procurement process or purchasing decision. Relatedly, our Social Value Framework aims to maximise the social, economic, and environmental benefit of all public investments. Our framework is underpinned by a set of guiding principles which organisations from all sectors are encouraged to adopt.

Our principles such a being inclusive in the way we work, supporting people in securing work and paying the Living Wage, and ensuring ethical standards of purchasing and delivering services is relevant to the anti-slavery agenda as they promote good work and procurement practices beyond the cost of a service.   

Code of Conduct for Employees

This Code sets out the responsibilities and rights of employees when carrying out their duties. This includes encouraging employees to report concerns of malpractice and ensuring dignity and respect in in their roles. The Code applies to employees of Brighton & Hove City Council, whether employed on a permanent, temporary, or casual basis. 

This Code of Conduct and the Council’s Behaviour Framework underpin organisational values by setting out in more detail the standard of behaviour expected of officers whilst carrying out their duties. 

This is relevant to the anti-slavery agenda as the Code expects employees to behave ethically and maintain high standards of personal conduct and be aware of and act in accordance with the Council’s values and behaviours.  

Health and Safety

The Council has various policies which aim to promote high standards and good practices in relation to health, safety, and welfare. This includes the Health and Safety Policy and Health and Safety Management Standard which sets out health and safety arrangements and responsibilities for all staff. 

These procedures are important to tackling modern slavery as victims of forced labour and modern slavery may be at increased risk of work-related injuries due to inadequate protective equipment and health and safety measures, including appropriate training.   

Recruitment

The Council’s Recruitment and Selection Policy provides a framework to ensure the Council has a fair, objective, consistent and transparent recruitment, and selection process that promotes good practice and supports a proactive approach to equality and diversity. This policy applies to all individuals employed by Brighton & Hove City Council. Our recruitment policies include undertaking pre-employment checks such as reviewing references, verifying qualifications, conducting Disclosure & Barring Service checks where appropriate to the post, and Right to Work in the UK checks.

The Council recognises that victims of modern slavery can be exploited in legitimate jobs with legal terms of employment but exploited by others unrelated to the Council. Therefore, the checks undertaken as part of our recruitment and selection process are important for identifying potential vulnerabilities and victimisation.   

Grievance and Workplace Conflict

The Council is committed to providing a working environment where individuals are treated with fairness, dignity and respect and will take all employee complaints seriously. The Grievance Procedure sets out the process and stages of dealing with concerns raised by employees, as soon as reasonably possible. This includes the right of workers to be advised and/or represented by a Trade Union representative, where requested. 

The Council also has an Anti-bullying, Harassment and Victimisation Policy which aims  to assist in maintaining a supportive, inclusive, and respectful working environment where unacceptable behaviour is easily identified, challenged, and stopped. 

Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns.

Equality and Inclusion

In addition to other Council policies such as those on recruitment and our Code of Conduct which includes equality and diversity within our organisation, the Council has an Equality and Inclusion Policy Statement and Strategy. This describes how we promote, facilitate, and deliver equality. 

The Council recognises that certain vulnerable, marginalised, and underrepresented groups are at a higher risk of poor labour and employment practices and therefore equality and diversity policies ensure that every member, manager, and employee have a duty to be aware of equality issues in their daily activities.  

Domestic Abuse

Our Policy to Support Employees experiencing Domestic Violence & Abuse (DVA), or Sexual Violence (SV) sets out the Council’s framework for supporting employees who have experienced or are experiencing DVA or SV and the steps the Council will take where it is alleged an employee has, or is, perpetrating this type of abuse. The policy covers elements of abuse such as controlling and coercive behaviour. 

While this policy focuses specifically on domestic abuse, it is important for tackling modern slavery as cases may share similar indicators of abuse.   

Trade Unions

The Council has adopted a policy of seeking mutually acceptable solutions to employee relations problems by discussion and agreement and recognises that effective collective bargaining, negotiation, consultation, and communication can be best achieved at a local level between union representatives, union members and management.

The Council has a Trade Union Facilities Agreement with recognised trade unions representing our employees. This agreement ensures that facilities such as paid time off are available to ensure that union representatives can carry out their duties.   

The Council recognises that trade union representation in the workplace can help reduce the risk of modern slavery by representing the interest of workers, ensuring fair working practices, supporting workers in negotiating their terms and conditions, and the resolving of grievances.   

Sussex Safeguarding Adults Policy and Procedures

The Policy sets out the approach taken to adult safeguarding across Sussex.  The Procedures explain how agencies and individuals should work together to put the Sussex Safeguarding Adults Policy into practice. They have been updated in accordance with the Care Act 2014 and the Care and Support Statutory Guidance, and should be read in conjunction with these. 

This policy and procedures provide an overarching framework to ensure a proportionate, timely and professional approach is taken, and that adult safeguarding is co-ordinated across all relevant agencies and organisations. This is essential for the prevention of harm and abuse.  

Sussex Child Protection & Safeguarding Procedures

Brighton and Hove, East Sussex and West Sussex Local Safeguarding Partners have commissioned the policies and procedures in this manual, which reflects a significant consensus about best practice across the three areas, and all those agencies in Sussex that contribute to the prevention, detection and investigation of abuse or neglect, risk management of offenders and the support and treatment of those affected. 

The development of the procedures manual is one of the core functions of the safeguarding partners in their role to coordinate local work to safeguard and promote the welfare of children. The procedures encourage close working between agencies to facilitate early intervention in a supportive way to meet the needs of children and their families.

Supplier Code of Conduct

The Council believes that its supply chain plays a vital role in making a positive contribution to its communities and society. Procuring in an ethical, fair, responsible and sustainable way which allows us to work with successful bidders to align with our policy objectives is a priority. 

The Council's Supplier Code of Conduct embeds these policy objectives and provides a detailed expectation of our supply chain. We expect our suppliers and their supply chains to follow three key principles which focus on people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly, maintaining high standards of integrity and professionalism in their business dealings.