Modern slavery is an umbrella term encompassing exploitative practices such as slavery, servitude, forced or compulsory labour and human trafficking.

This statement is pursuant to Section 54 (transparency in supply chains) of the UK’s Modern Slavery Act 2015 and sets out actions taken by Brighton & Hove City Council to address the risk of modern slavery in our operations and supply chains.

This includes ensuring that the goods and services we procure do not contribute to modern slavery in the UK and globally and protecting and safeguarding vulnerable people and workers from exploitative practices. We are committed to understanding where the risks to people being exploited lie within our own organisation and supply chains and putting in place measures to prevent and respond to cases.     

In Brighton & Hove, we are aiming to achieve a fairer city with a sustainable future. This includes a:

  • city to call home
  • city working for all
  • stronger city
  • growing and learning city
  • sustainable city
  • healthy and caring city

Our Corporate Plan for 2020 to 2023 details how we aim to create a fairer and sustainable city.    

The council has made public declarations regarding modern slavery and has engaged in collaborative forms of work at community level. We have also taken a number of steps to tackle modern slavery such as raising awareness of modern slavery to our communities, establish measures to protect vulnerable groups against exploitation, and working together to support the identification and safeguarding of victims. 

However, we have recognised the need to undertake further work in our operations and supply chains to ensure that our own activities do not contribute, cause or are linked to modern slavery practices. Brighton & Hove City Council is therefore committed to tackling this problem and being transparent in our anti-slavery activities and outcomes.  

As this is our first statement, it demonstrates how we have started responding to modern slavery risks in our operations and supply chains and some of our planned actions. We believe that tackling modern slavery requires continuous improvement and therefore we are committed to keeping track of measures that are put in place to ensure effectiveness of actions taken.  

This statement relates to the steps taken by the council during the financial year 1 April 2021 to 31 March 2022.  

Our organisational structure and supply chains 

Our Executive Leadership team provides strategic direction to the whole council which is organised into the following directorates:   

  • Economy, Environment and Culture   
  • Families, Children and Learning   
  • Health and Adult Social Care  
  • Housing, Neighbourhoods and Communities   
  • Governance, People and Resources  

Brighton & Hove City Council has partnered with East Sussex County Council and Surrey County Council to develop Orbis Procurement – a shared service partnership working together to deliver lean procurement support, shared learning to achieve excellent outcomes, and shared resource for the delivery of achieving value for money for our residents.

Collectively, we comprise of one of the largest public procurement spend in local government. Orbis Procurement service delivers a significant amount of our projects annually, and therefore its contribution to our anti-slavery activities is vital.   

The three authorities have committed to developing an approach to respond to modern slavery in our operations and supply chains. This responsibility will rest with Orbis Procurement on behalf of Surrey County Council, East Sussex County Council and Brighton & Hove City Council. The three authorities have also jointly funded the establishment of a new Senior Policy Lead on Modern Slavery role for Orbis Procurement to help design, deliver and co-ordinate our anti-slavery in supply chain activities.  

For each of the authorities where services are not procured directly by the councils, they are procured via Orbis Procurement on behalf of the Council.

This statement reports on activities related to these services. Further work will be required to map services procured directly by the council. These services are often significantly lower in value and spend and are governed by the council’s procurement and contract standing orders. Therefore, it is anticipated that such work would require longer-term assessments in collaboration with other teams working across the council. Focusing on services procured via Orbis Procurement in the short-term allows us to ensure adequate prioritisation of modern slavery risks and allocation of shared resources to respond to these risks.   

During the 2021/2022 financial year the council spent approximately £330 million with 3,902 suppliers, procured using Orbis Procurement’s services on behalf of the council.   

How this spending was distributed

£73 million was spent on corporate and business needs.

£106 million was spent on assets and infrastructure.

£152 million was spent education, health and social care.

Responsibility for anti-slavery activities in our operations and supply chains  

The responsibility for anti-slavery activities in our operations and supply chains is as follows.

Approving the modern slavery statement  

Brighton & Hove City Council (BHCC) Policy and Resources Commitee are responsible.

Signing the modern slavery statement

The Leader or the Council and Chief Executive of BHCC are responsible.

Drafting and reviewing the modern slavery statement  

The following officers and teams are responsible:

  • Orbis Procurement Senior Policy Lead on Modern Slavery   
  • Orbis Procurement Senior Leadership team   
  • BHCC representatives from:
    • Procurement
    • Legal
    • Human Resources
    • Audit
    • Safeguarding
    • Community Safety teams  

Assessment and prioritisation of modern slavery risks for services procured via Orbis Procurement on behalf of the council 

Orbis Procurement Senior Policy Lead on Modern Slavery is responsible.

Modern slavery due diligence in the supply chain for services procured via Orbis Procurement on behalf of the council

The following officers and teams are responsible:

  • Orbis Procurement Senior Policy Lead on Modern Slavery   
  • BHCC Heads of services  
  • BHCC Commissioning managers  
  • BHCC Procurement teams  
  • BHCC Contract managers   

Education and training of procurement personnel

Orbis Procurement Senior Policy Lead on Modern Slavery is responsible.

Education and training of wider council and staff  

The following officers and teams are responsible:

  • Orbis Procurement Senior Policy Lead on Modern Slavery   
  • BHCC Safeguarding and Community Safety teams  

Identifying and responding to suspected cases of modern slavery   

All BHCC staff are responsible for identifying and responding to suspected cases of modern slavery.  

Our policies in relation to modern slavery  

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

We recognise that modern slavery sits on the extreme end of the labour exploitation continuum. Therefore, we have several policies with respect to 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.   

The following are our key policies, procedures, and codes of conduct in relation to modern slavery.  

  • Council Constitution   
  • Whistleblowing Policy   
  • Sustainability and Social Value Polices  
  • Employee Code of Conduct  
  • Health and Safety Policies   
  • Recruitment Policies  
  • Grievance and Workplace Conflict Policies  
  • Equality, Diversity and Inclusion Policies   
  • Domestic Abuse Policy  
  • Trade Union Policy   

Read more about our policies and their relevance to modern slavery in the Annex.  

Modern slavery due diligence 

In addition to our existing policies which are relevant to the anti-slavery agenda, Brighton & Hove City Council has undertaken the following due diligence measures to respond to modern slavery risks within our operations and supply chain.

Anti-Slavery commitments 

In 2018 we joined the Co-operative Party Charter Against Modern Slavery. The Charter commits councils across England and Scotland to proactively vet their own supply chain to ensure no instances of modern slavery are taking place. This includes committing to take actions such as reviewing contractual spending to identify potential modern slavery risks, train procurement teams, and engaging with suppliers.

In 2020 we also signed a joint pledge on modern slavery coordinated by the Sussex Anti-Slavery Network. This pledge commits us to work proactively with local and national actors to take actions such demonstrating strong local leadership for anti-slavery initiatives and removing slave-based labour from our supply chains.

We recognise that while commitments are important, they alone cannot address modern slavery and that further practical action is needed.  

Partnership and collaboration 

In addition to our shared-service partnership through Orbis Procurement which helps to coordinate our anti-slavery approach, we are engaged in multi-agency anti-slavery partnerships. We have representatives who are part of the Sussex Anti-Slavery Network.

Members of this multi-agency partnership include:

  • West Sussex County Council
  • East Sussex County Council
  • Brighton & Hove City Council
  • Office of the Sussex Police and & Crime Commissioner
  • East and West Sussex Fire and Rescue Services
  • Sussex Clinical Commissioning Groups
  • Gangmasters and Labour Abuse Authority

The aim of the partnership includes asserting and supporting organisations’ responsibility towards tackling modern slavery, sharing intelligence and best practice, and developing preventative strategies.

The council is also part of the Brighton & Hove Anti-Slavery Network. This group also focuses on monitoring progress in addressing modern slavery and includes representatives from within the local authority (such as children’s and adult social care, housing) and organisations such as Sussex Police, Sussex Clinical Commissioning Groups and East Sussex Fire and Rescue.

While these partnerships contribute to action against modern slavery, we have recognised the need to bring a business and supply chain element to their focus. This includes co-ordinating with the network to engage with local businesses and suppliers. 

Supplier engagement

We recognise the need to ensure that modern slavery requirements are consistently implemented throughout our procurement to effectively tackle this problem.

We are developing and strengthening existing measures to engage with our suppliers on the problem of modern slavery. Such measures include reviewing modern slavery clauses in contracts and procurement materials such as tender and specification documents to ensure that the Council and our suppliers adequately respond to modern slavery risks.  

Victim support and protection

Brighton & Hove City Council recognises that having adequate safeguarding measures can help identify potential victims, support them in their rehabilitation and protect them from further victimisation.

In April 2020, we introduced the council’s Modern Slavery Referral Pathway for referring potential adult and child victims of modern slavery. There has been an increase in the number of referrals made into the National Referral Mechanism and we have received valuable intelligence related to the demographics and characteristics of victims and the type of exploitation experienced.

This information has been particularly useful due to the COVID pandemic and being able to identify potential victims and vulnerabilities such as those facing vulnerable migrant workers, adults with multiple complex needs and children forced into criminal exploitation.

Consequently, a key area of focus has been to prevent further victimisation and increased risks to exploitative practices such as labour exploitation where there are limited opportunities for victims and vulnerable people to support themselves.    

Training on modern slavery

We recognise the importance of raising awareness of modern slavery amongst our staff. We are committed to designing and delivering training to our staff, including providing targeted training to key personnel.   

We have delivered one virtual training session on modern slavery risks in supply chains staff. The training was delivered on three different slots to enable staff to attend. It lasted approximately 2 hours and focused on improving our staff’s understanding of the problem of modern slavery in supply chains.

The training, which will be distributed in phases to different teams, was first delivered to our staff working across Orbis Procurement for the three authorities. 68% of procurement staff undertook the training. This included people working in various roles such as Heads of Procurement, Procurement Specialists, Contract & Supply Specialists, and Strategic Procurement Managers. The contents of the training included:   

  • the definition of modern slavery  
  • types of modern slavery   
  • vulnerabilities to exploitation   
  • general signs of exploitation   
  • the nature and scale of slavery globally and in the UK   
  • an introduction to the UK’s Modern Slavery Act and Section 54 on Transparency in Supply Chains  
  • enablers of modern slavery in supply chains and high-risk sectors  
  • the relevance of modern slavery to the public sector   
  • different responsibilities within our organisation for tackling modern slavery   
  • the commitments of Surrey County Council, East Sussex County Council and Brighton & Hove City Council in addressing modern slavery, including planned actions

To assess our staff’s knowledge and awareness of modern slavery, we assessed a short questionnaire completed by staff before and after the training was delivered.

Of those responding to the questionnaire, there was a marked difference in their understanding of modern slavery.

Prior to the training, most respondents (56%) reported that they had a poor (knew hardly anything about modern slavery) or fair (knew a little about it, but was unsure of how it was relevant to their role) understanding of modern slavery. 42% reported that they felt they had a good understanding of modern slavery and its relevance to their role but were unsure how to embed this into their work to address it. Only 2% of respondents reported an excellent understanding for example, good understanding of the problem, its relevance to their role and how to embed anti-slavery action into their work.

Following the training, most respondents rated their understanding as either good or excellent.

We also collected feedback from staff to inform future training and materials to ensure usefulness and effectiveness of training delivered.

This is particularly important for ensuring that our staff have the knowledge, confidence, and skills to embed anti-slavery action into their work. It is anticipated that the training will be reviewed and repeated on an annual basis.   

How respondents rated their knowledge before and after training

Poor (I hardly know anything about it) 

Before training: 9%

After training: 0%

Fair (I know a little about it, but I am not sure how it is relevant to my role)  

Before training: 47%

After training: 6%

Good (I have a good understanding of modern slavery and its relevance to my role, but I am unsure how to embed this in my work) 

Before training: 42%

After training: 74%

Excellent (I have a good understanding of modern slavery, its relevance to my role and how to embed this in my work) 

Before training: 2%

After training: 21%

Looking ahead: Our plans for 2022 - 2023 

Brighton & Hove City Council is committed to ensuring that our anti-slavery approach is effective in tackling modern slavery in our operations and supply chains. Therefore, over the next financial year some of the activities we aim to undertake include:   

  • reviewing policies to consider how we can strengthen them
  • working with other stakeholders across the council to understand services procured directly by the council to support modern slavery due diligence of these activities
  • assessing and prioritising areas within our organisation and supply chains at high-risk of modern slavery
  • reviewing our procurement processes and identify areas to embed anti-slavery activities in the procurement lifecycle
  • strengthening engagement with our suppliers to address modern slavery in supply chain risks
  • designing and deliver targeted training to key roles and responsibilities within our organisation
  • developing performance indicators to measure the effectiveness of actions taken
  • publishing a modern slavery statement for the 2022 - 2023 financial year


Approval of statement 

This statement has been approved by the Policy and Resources Committee on 7 July 2022. It will be reviewed and updated on an annual basis. 

Signed by: Geoff Raw, Chief Executive   

Date: 14 September 2022  

Signed by: Phélim Mac Cafferty, Leader of the Council   

Date: 14 September 2022  

Annex: Organisational Policies  

This section outlines our policies and their relevance to tackling modern slavery.

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. 

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 Sustainable Procurement Policy sets how sustainability will be embedded into every procurement process or purchasing decision.

Our Social Value Framework also 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.   

Employee Code of Conduct  

This Code sets out the responsibilities and rights of employees when carrying out their duties. This includes encouraging employees to raise concerns confidentially 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 these six organisational values by setting out in more detail the standard of behaviour expected of you as an officer whilst you are carrying out your 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.   


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 a Dignity and Respect at Work Policy which aims promote a respectful and inclusive culture where everyone is treated with professionalism, dignity and respect and supporting a working environment and culture in which bullying and harassment, will not be tolerated.   

Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns. Additionally, as victims of modern slavery are likely to be subject to forms of intimidation and threats and degrading and humiliating conduct, the Dignity and Respect at Work Policy is particularly relevant to tackling modern slavery.

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.