Modern slavery statement


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

  • 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. We also have 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)
  • take action and work with other responder agencies (Civil Contingencies Act 2004)

Publishing this statement on a voluntary basis shows our public commitment to play our part in reducing the horrendous crimes of modern slavery and human trafficking. This includes partnership working such as prevention, identification, awareness raising, information sharing 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
  • supply chains

It covers all direct employees, agency workers and externally contracted workers (for example, consultants).

Relevant policies

The following policies and procedures are considered to be key in meeting the requirements of the Modern Slavery Act. They also help us ensure we are taking reasonable action to address the risk of this crime occurring in Buckinghamshire.

Employees code of conduct

Our employee code of conduct makes clear to employees the actions and behaviours expected of them when representing us.

We try to maintain the highest standards of employee conduct and ethical behaviour. Line managers investigate any alleged breaches. We have a process in place for employees to make a declaration of outside interests where appropriate. This includes other paid employment.


Our recruitment processes are transparent and reviewed regularly.

This includes robust procedures in place for the vetting of new employees. This ensures they are able to confirm their identities and qualifications. We make payments directly into an appropriate, personal bank account.

Agency workers

Where the need arises to source resources from alternative agencies, we will verify their practices before accepting workers from that agency.


Through our human resources policies, we ensure we pay all employees fairly and equitably.

Business planning

Our business plans include a section on safeguarding. This makes reference to human trafficking and includes the steps services will take to manage that risk.

Training and development

We have a programme of mandatory training that all employees and members must complete. This includes eLearning Safeguarding Awareness which references modern slavery.

As part of our Community Safety Strategy, there is introductory training on modern slavery and exploitation for front line professionals. There is also Single Point of Contact (SPOC) training. This is part of our first responder role and our local authority duty with the National Referral Mechanism (NRM). An eLearning package will roll out in 2020.

Our procurement team has developed a training package for:

  • procurement exercises
  • contract management

The training highlights the potential risk of modern slavery and signs that officers should look out for.

Our due diligence processes for slavery and human trafficking


We publish our 'whistle blowing' confidential reporting policy as part of our constitution.

This encourages all its employees, and others the council deals with, who have serious concerns about any aspect of our work to come forward and voice their concerns. It lays out a process for doing so, which adheres to the Public Interest Disclosure Act 1998. This means that, if necessary, employees may make disclosures without fear of reprisal or victimisation.


We take our responsibilities to safeguard the welfare of children and vulnerable adults very seriously. We look to protect them from harm and develop, put in place and track our policies and procedures.

There is a clear pathway for:

  • all modern slavery referrals into Adult Social Care
  • all referrals into Children's Social Care
  • 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

We report information on referrals to the Safeguarding Adults Board.

Corporate complaints system

We operate a complaints procedure to deal with complaints about our services. This can be used to report community concerns which merit investigation or reporting to a partner agency.

Suppliers and those who provide services on our behalf

Our contract standing orders provide clarity on the requirements for commercial decisions. This helps to safeguard us from potential claims that put into question the integrity of the council and its employees.

Our standard contract terms and conditions include an appropriate clause placing obligations on suppliers to follow the Modern Slavery Act 2015. Where there is a risk assessment for the potential for modern slavery to occur, contract managers will seek reassurance that the supplier can detect and deter such abuse through:

  • policies
  • procedures
  • training

Training is in place to help officers understand the risk of modern slavery and what actions they should take. This includes undertaking surprise audits of a supplier’s place of work.

Partnership working

The Missing and Exploitation Hub is a multi-agency team made up of partners from:

  • Children's Social Care
  • Thames Valley Police
  • Barnardo’s
  • Health and Education

It also includes a parent worker, currently provided by Buckinghamshire Safeguarding Children Partnership. The team support victims of all forms of exploitation and can work with and sign post those in need of support up to the age of 25.

We are a member of the Safer Buckinghamshire Board. This is 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”. It reviews partnership progress in addressing issues of modern slavery and is signed up to a countywide Joint Protocol.

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

Joint protocol

The joint protocol recognises that many agendas are shared and all players have a role in safeguarding children and adults who are vulnerable to abuse, neglect and exploitation.

The Joint Protocol has been formally signed off across the:

  • Health and Wellbeing Board (HWB)
  • Safer Buckinghamshire Board (SBB)
  • Buckinghamshire Safeguarding Children Partnership (BSCP)
  • Buckinghamshire Safeguarding Adults Board (BSAB)

It aims to ensure:

  • there is clarity and agreement regarding the roles and responsibilities of different partnerships and boards in relation to safeguarding
  • that governance arrangements are clear and work is well co-ordinated, preventing duplication of effort
  • that we achieve more by working together
  • that working together has a positive impact on people and communities
  • that there is effective challenge and scrutiny of safeguarding arrangements across Buckinghamshire


The council's Cabinet Committee has approved this statement.

The statement is supported by:

  • the Buckinghamshire Safeguarding Children Partnership
  • the Buckinghamshire Safeguarding Adults Board.

We will review and update this statement annually. We will report progress and new actions to the Cabinet Committee. Where appropriate, we will also report this statement to other committees for performance monitoring and assurance purposes.