Modern slavery statement

Modern slavery is the illegal exploitation of people for personal or commercial gain. In its wider sense it is

commonly accepted to include:

• sexual exploitation
• forced or bonded labour
• human trafficking
• criminal exploitation
• financial exploitation
• domestic servitude
• child slavery
• offences under the Protection of Children Act 1978 or the Sexual Offences Act 2003
• forced or early marriage

Buckinghamshire Council has responsibilities as an employer and procurer / commissioner of services and also has duties to notify the Secretary of State of any suspected victims of slavery or human trafficking (as introduced by section 52 of the Modern Slavery Act 2015).

Publishing this statement on a voluntary basis demonstrates our public commitment to play our collaborative part in reducing modern slavery and human trafficking, including through effective partnership working (prevention, identification and support of victims, awareness raising, information sharing, disruption and enforcement).

This statement sets out the steps we have already taken and are planning to take to help detect modern slavery in our own services, businesses and our supply chains. It covers all direct employees, agency workers and externally contracted workers (e.g. consultants).

This statement covers the reporting period April 2024 to March 2025.

Buckinghamshire Council is a unitary authority, created in April 2020, covering the county of Buckinghamshire and a population of 566,700 people. The Council’s vision is to make Buckinghamshire the best place to live, raise a family, work and do business. Key priorities include ‘protecting the vulnerable’ and ‘strengthening our communities’.

The Council has an annual budget of £538 million and employs 4318 staff across 6 directorates (Adults & Health, Children Services, Communities, Assistant Chief Executive, Planning, Growth & Sustainability and Resources). It is a large unitary authority with 97 councillors, reduced from the previous 147 following a review by the Local Government Boundary Commission. The authority operates through a cabinet model.

The Council purchases goods and services and works from 3511 suppliers, across numerous categories.

It is recognised that the Council’s supply chains are global and complex, with many high labour content contracts. Modern slavery risks are present throughout the contracting lifecycle and the Council is therefore embedding due diligence into its contract and supplier management programme.

Review the referral pathway and support offered for adult victims of modern slavery and exploitation to ensure partners know how to refer and staff know how to respond to victims.

Support the work of the Safer Buckinghamshire Board to develop its subgroup structure for partnership activity to tackle modern slavery and exploitation

The Safeguarding Practice Handbook was fully implemented in November 2024. It clearly identifies who a ‘first responder is’, key standards required to respond, and how adults going through the NRM can access specialist tailored support. During 2025 work will be underway to develop a process flowchart to reflect the referral process for adult victims, across Adult Social Care Operations. Scoping work will be undertaken with the ADASS Safeguarding Group to identify good practice across the Southeast region.

The Safer Bucks Board agreed to move to a three sub-group model of delivery for Sexual Exploitation, Criminal Exploitation & Serious Violence Prevention, and Employment & Domestic Based Servitude. The intention is to enable a focus on each element of modern slavery. Buckinghamshire Council plays a significant role within this partnership, and the groups continue to have multi-agency representation with targeted delivery plans.

The following policies and procedures are key in meeting the requirements of the Modern Slavery Act and helping the Council to ensure that it is taking reasonable action to address the risk of this crime occurring in Buckinghamshire.

The Council’s Employee Code of Conduct makes clear to employees the actions and behaviours expected of them when representing the Council. The Council strives to maintain the highest standards of employee conduct and ethical behaviour and breaches are investigated.

The Council expects all Councillors to demonstrate the highest standards of conduct and behaviour. All Councillors are required to abide by a formal Member Code of Conduct. Allegations of breaches are initially handled by the Monitoring Officer. Both the Code and Complaints Process are in the Council’s Constitution.

The Council’s recruitment processes are transparent. This includes robust procedures in place for the vetting of new employees and ensures they can confirm their identities and qualifications, and they are paid directly into an appropriate, personal bank account.

The Council has a managed service contract in place for the provision of temporary agency staff. Modern Slavery is included as part of their Supplier Information Form which is sent across to all 2nd Tier Supplying Agencies to complete. The Council through its human resources policies ensures that all employees are paid fairly and equitably.

The Council encourages all its employees, workers, consultants and agency staff to report any concerns related to the direct activities or the supply chains of the Council. The Council’s whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of reprisal or victimisation.

The Council operates a complaints procedure to deal with complaints about its services, and this can be used to report community concerns such as overcrowding or issues which might reveal slavery or trafficking and which merit investigation or reporting to a partner agency.

The Council takes very seriously its responsibilities to safeguard the welfare of children and vulnerable adults and protect them from harm and develops, implements and monitors its policies and procedures accordingly. We’ve created a set of guidelines and rules that apply not just to employees but to volunteers and contractors and anyone else who will work in these circumstances.

Professionals and members of the public can report concerns about adults or children by phone or online. Our safeguarding reporting page for children and our safeguarding reporting page for adults is clearly provided on the website.

Any referrals that come into Adult Social Care Operations are triaged by the relevant team or allocated worker. This is undertaken by a qualified social work practitioner as part of their role, and appropriate action is undertaken as outlined in the Safeguarding Practice Handbook and in line with the Council's statutory duty to notify through the National Referral Mechanism.

There is a pathway for all referrals into Children’s Social Care with officers trained in the MASH and Locality Teams. There is a clear pathway for all referrals where it is considered that a child is at risk of exploitation and a specialist Missing & Exploitation Hub equipped to work with those children.

The Missing and Exploitation Hub provides consultative support to lead professionals working with children and young people who are victims of exploitation. The Hub works alongside partner agencies as well as offering direct intervention for children who are experiencing exploitation. It will also signpost towards appropriate support for those over 18, up to the age of 25.

The Council is a member of the Safer Buckinghamshire Board. This represents the county’s Community Safety Partnership (CSP) as defined under Section 5 of the Crime and Disorder Act 1998. CSPs are defined as: “An alliance of organisations which generate strategies and policies, implement actions and interventions concerning crime and disorder within their partnership area”.

The Council has responsibilities under the Modern Slavery Act as a first responder and in tackling modern slavery and exploitation which are not covered in detail within this Modern Slavery Statement. The wider work we are undertaking as a council is addressed through the Safer Buckinghamshire Strategy and associated delivery plans under the Safer Buckinghamshire Partnership. Several subgroups support this work.

There is also a countywide Anti-Slavery and Exploitation Network (the Bucks A-SEN) which brings together organisations from the public, private and voluntary sector. The network meets regularly to share best practice, increase understanding, and help deliver against the priorities identified by the CSP.

The Safer Buckinghamshire Board (SBB) is the strategic board for the Safer Buckinghamshire Partnership. The Board works closely with the Health and Wellbeing Board (HWB), Buckinghamshire Safeguarding Children Partnership (BSCP) and Buckinghamshire Safeguarding Adults Board (BSAB), recognising that many agendas are shared and that all players have a role in safeguarding children and adults who are vulnerable to abuse, neglect and exploitation.

Continue to promote the internal modern slavery e-learning and monitor uptake of mandatory e-learning for staff.

Engage with staff in key service areas to raise awareness of modern slavery, promote training opportunities, and the services available.

Provide further training opportunities for professionals and voluntary and community sector organisations within Buckinghamshire.

Mandatory training has been in place for new staff since April 2023 and existing staff are required to complete training once as part of their continued professional development. We are now measuring completion rates as a percentage of the existing workforce, rather than total number of completions since the course was initiated. During the year, the completion rate for Buckinghamshire Council staff increased from 78% on 1st July 2024, to 87% on 1st April 2025. This is an excellent take-up.

Modern Slavery Awareness sessions have been delivered to over 90 members of staff covering Buckinghamshire Adult Learning, Adult Social Care (Direct Payments) and Environmental Health & Licensing. The presentations include a focus on types of exploitation that they may see in their day-to-day work, with further Awareness Sessions planned during 2025.

Staff were informed about key modern slavery issues in Buckinghamshire through a short information session on modern slavery during the 'All Staff Briefing' in April 2024. The event is available to all staff and includes a conversation item with the Chief Executive, to highlight and raise awareness of issues.

To mark Anti-Slavery Day on 18th October 2024, Thames Valley Anti-Slavery Networks hosted a successful information & learning event. Buckinghamshire Council was instrumental in supporting this, with the event held in High Wycombe. Approximately 90 representatives from partner agencies across the Thames Valley attended to hear guest speakers including the Local Government Association, Thames Valley Police’s Modern Slavery and Organised Immigration Crime Team and an Aid Worker.

Working with Hope for Justice, a further 6 Modern Slavery, Human Trafficking and Exploitation training events were delivered for professionals and voluntary and community sector partners during June 2024. This included a new course focused on trauma informed listening and trauma informed case reporting. 105 people attended the sessions in total.

The Council has a programme of mandatory training that all employees and members must complete, including Safeguarding Awareness and Modern Slavery and Human Trafficking eLearning. A Modern Slavery and Exploitation training resource specifically for Councillors is available on the Council’s intranet pages.

As part of the Safer Buckinghamshire Partnership there is introductory training on modern slavery and exploitation for front line professionals. More specialised training is also available to staff within Children’s Services as part of our first responder role and our local authority duty with the National Referral Mechanism (NRM).

Include a section on the Contract Management Protocol still in development for contract managers and commissioners to register and manage the risk assessment results for modern slavery, and mitigation actions

Identify and deliver actions to mitigate risk of modern slavery in locally commissioned care sector services.

The contract management protocol has been drafted and includes references to modern slavery within the document. It is expected to roll out during the 2025-2026 period.

Partners across the Thames Valley continue to meet regularly to map local issues and consider relevant actions so that the risks can be managed by Commissioning staff. We have sought to raise awareness with providers by sharing information and resources at provider events.

Following the successful submission of a joint ADASS bid with Oxfordshire, an exciting short term pilot project will be running during 2025, to support displaced care workers. We will be working with a local voluntary and community sector provider that already has experience of delivering early support to potential victims of exploitation in Oxfordshire.

The Council’s contract procedure rules provide clarity as to the requirements for commercial decisions to safeguard the Council from potential claims that put into question the integrity of the Council and its employees. The Council has standard contract terms and conditions for service contracts above the procurement threshold (currently £214,904 inclusive of VAT) that include an appropriate clause placing obligations on suppliers to comply with the Modern Slavery Act 2015. By including requirements within these terms and conditions we have begun to close the door on new contracts being established where there are risks of modern slavery and exploitation. This is progressive work and over time will capture all commercial relationships, which may include extending modern slavery specific clauses into consultancy, goods, and below-threshold terms and conditions.

Responses to Invitation to Tenders for contracts over the threshold of £214,904 (inclusive of VAT) must confirm whether they have an active modern slavery policy and approach. This must be available for reviewing along with the actions they actively take to negate the risk of modern slavery in their operation. This assessment is part of a standard questionnaire and will determine if their Invitation to Tender response will be considered in the procurement process.

Contract Managers should continue to monitor their contracts with relation to modern slavery commitments by suppliers and their sub-contractors. Where a risk assessment shows there is potential for modern slavery to occur, contract managers will seek reassurance that the supplier has policies, procedures and training in place to detect and deter such abuse. Training is in place to help officers understand the risk of modern slavery and what actions they should take.

Develop a process flowchart to support the referral process for adult victims of modern slavery across Adult Social Care Operations. Undertake scoping work with the ADASS Safeguarding Group to identify good practice across the Southeast region. 

Continue to engage with staff in key service areas to raise awareness of modern slavery, promote training opportunities and help services understand the types of exploitation they may encounter in their roles.

Seek further funding for specific training opportunities for partnership staff to increase understanding of Modern Slavery.

Provide training opportunities for Commissioning Staff to increase their understanding of modern slavery in the care sector.

Ensure the Council’s new Contract Register has the capability to upload completed Modern Slavery assessments as the previous Contract Management Application (CMA) did.

Review and roll out the new contract management protocol which requires contract managers to register and manage risk assessment results for modern slavery.

Undertake a pilot project to support sponsored care workers at risk of exploitation in the care sector.

This statement has been approved by the Council’s Cabinet Committee and is supported by the Safer Buckinghamshire Board, Buckinghamshire Safeguarding Children Partnership, Buckinghamshire Safeguarding Adults Board and Buckinghamshire Health & Wellbeing Board. It will be reviewed and updated annually. The statement, progress and new actions will be reported to the Cabinet Committee and, where appropriate other committees, annually for performance monitoring and assurance purposes.

View our:

• Modern Slavery Statement 2024 to 2025 (the current version) PDF, 484KB
• Modern Slavery Statement 2023 to 2024 PDF, 488KB
• Modern Slavery Statement 2022 to 2023 PDF, 318 KB
• Modern Slavery Statement 2021 to 2022 PDF, 323 KB
• Modern Slavery Statement 2020 to 2021 PDF, 278 KB
• Modern Slavery Statement 2020 PDF, 177 KB