Statutory duties of the London Borough of Bexley

The London Borough of Bexley has statutory obligations under the Modern Slavery Act 2015 to respond to modern slavery and human trafficking and to safeguard residents from exploitation.

Specifically, Section 52 of the Modern Slavery Act 2015 makes the Local Authority a First Responder, which places a duty on us to identify and refer child or consenting adult victims through the National Referral Mechanism (NRM), or to notify the Home Office of non-consenting adults suspected to be trafficked, enslaved, or exploited.

This statutory duty applies to all employees at the London Borough of Bexley who come across suspected victims of modern slavery, but there are specific points of contact within the local authority who can guide staff in making referrals. These sit within the Children’s Social Care, Adult’s Social Care, and Community Safety Teams.

The local authority has overarching safeguarding duties which require us to provide the necessary care and support to at-risk and exploited people that we are aware of, even before a conclusion has been made by the Home Office regarding their status as a modern slavery victim or not. This is primarily provided by social care, though a partnership approach is necessary to provide adequate safeguarding. For example, there are Government-funded voluntary organisations who provide further support, such as Barnados and the Salvation Army.

These statutory duties have not changed. However, how we deliver against them has progressed.  The Modern Slavery and Exploitation Strategy 2023-2028 brings together strands of work relating to meeting our duties under the Modern Slavery Act (2015) and Statutory Guidance into one clear strategy and toolkit. It ensures that our response is robust. The first Strategy and Toolkit was adopted in 2019.

The primary objectives of the Strategy are to:

1. ensure the local authority does not exploit its employees, contractors or sub-contractors by having HR policies to protect employees and by risk assessing our supply chains and putting processes in place to mitigate any risks within them and offering support and awareness to our sub-contractors and commissioned services around meeting their own Modern Slavery Act 2015 obligations
2. safeguard (potential) victims and survivors of modern slavery, human trafficking, and child exploitation through social care and housing support processes. This includes adopting a multi-agency approach and utilising existing resources efficiently
3. coordinate multi-agency responses and to raise awareness of modern slavery within the community to prevent exploitation, and to ensure everyone in our community knows what role they play in tackling modern slavery. This includes utilising information we have around trends and demographics in Bexley to target those most at-risk of exploitation

To do this, we need to ensure there is a central place to hold information and evidence and ensure that this is discussed with our local strategic partnership to bring together a Bexley picture of Modern Slavery. We need to quality assure our response and ensure this is embedded into everyday activity. This is why we collate the data for referrals and notifications made and hold partnership meetings to improve efficiency, prevention and response to local trends and cases.

The Bexley modern slavery partnership includes the Local Authority, including various key departments within it, such as Procurement, Community Safety, Adult Social Care, Children’s Social Care, Trading Standards and Licencing, and Housing. It also includes our public external partners, such as the Metropolitan Police, Gangmasters and Labour Abuse Authority (GLAA), London Fire Brigade, Immigration. We also have voluntary sector members, including the Salvation Army, Children’s Society, Barnados, Human Trafficking Foundation, Rescue and Response and Stop the Traffik. This is to ensure our vision is reflective of every partner’s intelligence and of their powers to tackle modern slavery, so that we can work effectively together.

Proposed Changes

This Strategy has become a five-year Strategy to enable the local authority to set a clear outlook and demonstrate the long-term commitments that tackling modern slavery requires. Updates on progress will be provided via our annual Modern Slavery Statement.

The Strategy is being updated following changes in data and information, progress in partnership working and new tools, resources, and actions available. Key changes being:

• to annually risk assess our supply chains and produce an annual a Transparency in Supply Chains Statement to accompany our Modern Slavery Statement
• there will be no change to our existing safeguarding processes, but it reflects the increasing partnership and resources available for the purpose of safeguarding
• to deliver training to local professionals and community outreach and engagement

Supporting our Wider Objectives

Our Modern Slavery and Exploitation Strategy supports our Corporate Plan (Bexley Plan 2022-26). In particular:

Outcome 9: People and communities feel safe and inclusive

Bexley prides itself on being one of London’s safest boroughs, and that includes from Modern Slavery. This Strategy will work towards ensuring that Bexley continues to be a borough of low-risk and that requires the partnership working contained in the Strategy to ensure we respond robustly where we have concerns and to ensure we are proactive and preventing exploitation. The Strategy recognises that there are some particular vulnerabilities to exploitation, and only by having this in mind when operating can we see and respond to it.

Outcome 14: Rigorous procurement and contract management to get the best services

Many services are provided by partners and contractors on our behalf. This means that we have an obligation to ensure they provide services in a lawful and legitimate way, as we would expect of ourselves, and that they treat their own employees and contractors according to the law. We will manage our contracts in a way which ensures we identify and address risks of modern slavery in our supply chains and that we provide resources and awareness for our contractors around modern slavery and their duties. We will provide an Annual Transparency in Supply Chains Statement to demonstrate what the risks are in our supply chains and how we mitigate them.