For the financial year ending 2023/2024
Brighton & Hove City Council is committed to driving fairness and inclusivity, valuing diversity and challenging discrimination in all its forms. Our vision is to work alongside our partners across other public services, the private sector and our community and voluntary sector to make Brighton & Hove a city we can be proud of, a healthy, fair and inclusive city where everyone thrives. While we are working towards tackling injustice and inequality that exists within our city, we also recognise how these issues resonate on a global scale. We believe that by doing our part and achieving our missions within our locality, our efforts will generate a positive impact on a national and international scale.
Modern slavery is a heinous crime affecting millions of people worldwide and thousands here in the UK. We therefore recognise the risk of modern slavery facing vulnerable people and service-users in our city as well as workers in the supply chains supporting our activities. We are passionate about 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. While the Council is not required by law to publish a modern slavery statement, we have chosen to publish one voluntarily to demonstrate actions we have taken to support wider anti-slavery efforts.
This statement outlines key steps Brighton & Hove City Council have taken during the 2023 to 2024 financial year to mitigate modern slavery risks within our operations, the communities we serve and our supply chains.
In Brighton & Hove, we are aiming to achieve a fairer city with a sustainable future. This includes a:
Our Corporate plan for 2023 to 2027 details how we aim to create a fairer and sustainable city.
At a time when local government is facing significant challenges and uncertainties, we remain dedicated to progressing our understanding of modern slavery and implementing appropriate measures to tackle it. Due to the widespread and multifaceted nature of this issue, it is crucial that people working for and on behalf of the Council be involved in efforts to combat exploitative practices. The Council fully acknowledges the complexity and challenges involved in tackling modern slavery. This issue requires appropriate resources to understand, implement and monitor the effectiveness of various approaches. Despite the daunting nature of this problem – a heinous crime affecting 50 million people worldwide and over 100,000 in the UK, one thing is certain: We have a duty to take action. Our approach to combatting this problem is focused on securing sustained long-term efforts and we are committed to taking action to safeguard the most vulnerable members of our society.
In our previous modern slavery statements, we expressed a commitment to doing more to address risks within our operations and supply chains and outlined how we are working to progress understanding of the problem, looking more closely at our own spending to understand potential risks, and putting measures in place to strengthen our response. In the last financial year, we have continued to work on building and strengthening the foundation of our anti-slavery efforts.
This statement includes information on:
Additionally, as the Modern Slavery Act 2015 encourages public scrutiny of modern slavery statements, we have included information for reporting cases of suspected or actual cases of modern slavery.
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.
This statement relates to the steps taken by the Council during the financial year 1 April 2023 to 31 March 2024.
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, maintaining roads and providing libraries and waste management services. The Council employs approximately 4,500 staff corporately.
Our Executive Leadership Team provides strategic direction to the whole council which is organised into the following directorates:
During the 2023 to 2024 financial year the Council spent approximately £360 million with 3,816 suppliers.
Education, health & social care - £179 million
Assets and infrastructure - £100 million
Corporate & business - £81 million
Brighton & Hove City Council have partnered with East Sussex County Council and Surrey County Council to establish Orbis Procurement – a shared procurement service partnership. p. Collectively, we comprise of one of the largest public procurement spends in local government, with an expenditure circa £2 billion a year with external suppliers across the three local authorities. As we deliver a significant amount of our projects annually via our Orbis Procurement service, its contribution to our anti-slavery in supply chain activities is vital. Accordingly, this work is driven by our Orbis Procurement service for the benefit of the three authorities.
For each of the authorities where services are not procured directly by Council departments, we procure them via our Orbis Procurement service. This statement reports on activities related to these services. Further work will be required to map services procured outside our partnership and directly by Council departments. These services are often significantly lower in value and spend and are governed by the Council's Procurement and Contract Standing Orders.
Beyond work undertaken in our Orbis Procurement service to mitigate modern slavery risks in our supply chains, the Councils also have people and teams across the authorities working on addressing related concerns such as issues connected to abuse, vulnerability, safeguarding, and community and partnership
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 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. Details of these policies and their relevance to modern slavery can be found in the Annex.
During the 2023/2024 financial year, we redrafted our Supplier Code of Conduct which underscores our responsibility to ensuring that our activities do not cause, contribute, or are linked to adverse human rights impacts such as modern slavery and our commitment to engaging collaboratively and proportionally with our suppliers to deliver greater ethical and sustainable value from our relationship. We also carried out a consultation with procurement officers to understand support needed with implementing it.
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 in high-risk areas such as adults social care, construction and facilities management but acknowledge that the Council’s potential exposure to modern slavery issues is likely much greater due to the extent and nature of our activities. Identifying potential areas in our supply chain at higher risk such as these, helps us to prioritise our anti-slavery efforts.
This section of our statement reports on activities aimed at understanding and managing risks within our operations and supply chains.
The Council have 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 have a duty to notify (DtN) the Home Office to support intelligence gathering.
In 2023, 17,004 potential victims of modern slavery were referred to the Home Office.[1]
Of these, Brighton and Hove City Council referred 29 victims in our locality into the NRM. Twenty-three were children (aged 17 and under), four were adults, and two victims whose ages were not specified or unknown. Six DtN referrals were 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.
During the 2023/2024 financial year, 5 safeguarding cases reported as a modern slavery concern progressed to a section 42 safeguarding enquiry.[2] Various types of abuse were reported including emotional/psychological abuse, financial and material abuse and exploitation. The alleged harm occurred in a range of settings such as a person’s own home.
Key activities undertaken during 2023/2024 to address risks in our operations and communities include:
Regarding due diligence undertaken to tackle modern slavery in our third party spend, the Council have taken several actions through our Orbis Procurement partnership. We view compliance with the law, particular Section 54 of the Modern Slavery Act 2015[3], as the minimum expectation and are working towards more stringent due diligence measures.
Key work undertaken within the partnership in the 2023/2024 financial year include:
The work undertaken above was driven by the Council’s Senior Policy Lead on Modern Slavery, based in the Orbis Procurement team. While lessons were drawn from each authority in our partnership, we are working towards consistency across the partnership to strengthen collective efforts in tackling modern slavery and we hope to build on this year on year.
[1] Modern Slavery: NRM and DtN statistics, end of year summary 2023 - GOV.UK (www.gov.uk)
[2] This figure only reflects the cases that have been enquired upon and is not indicative of all safeguarding concerns received by the Local Authority.
[3] Section 54 of the Modern Slavery Act 2015 requires certain organisations to publish a modern slavery statement each year outlining the steps taken to address modern slavery in their operations and supply chains.
[4] Notably statutory guidance including PPN02/23, the Global Slavery Index, the Modern Slavery Policy & Evidence Centre, the Local Government Association and anti-slavery charities such as Unseen who manages the national modern slavery helpline.
[5] The organisation's structure, business and its supply chains; Its policies in relation to slavery and human trafficking; Its due diligence processes in relation to slavery and human trafficking in its business and supply chains; The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps it has taken to assess and manage that risk; Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against performance indicators; The training about slavery and human trafficking available to its staff.
[6] Existing research on modern slavery statements have reported inconsistency in the quality and content of statements produced by organisations with some only complying with the minimum requirements of the legislation.
The Council recognises performance measurement as an area for improvement and is working to strengthen how we measure our overall approach.
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 i) helping us to understand potential risks ii) ensure that we are taking action iii) understand the effectiveness of our approach and iv) 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
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.
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.
Number of reports made through the following channels:
Training of key supply chain management staff
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.
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.
Number of training delivered to staff and attendance
Commissioners and contract managers:
Procurement team:
Monitoring implementation of supplier code of conduct
A limitation with monitoring the implementation of supplier code of conduct is the lack of capacity to assess how it is used in all relevant procurements and contracts.
To ensure Code is being used in tendering activity.
Project sampling across the partnership
Too early to report on
Review active high-risk projects to understand how modern slavery considerations were embedded
Due to capacity limitations, it is not feasible to review all current projects that are potentially high-risk for modern slavery practices.
To leverage insights from current contracts to inform our handling of future high-risk projects and our overall approach to managing risks in procurement and contract management activity.
Project sampling across the partnership
During the 2023/2024 financial year, 29 projects across the Orbis Partnership with a total contract value of approximately £5 billion were reviewed by Orbis Senior Policy Lead on Modern Slavery.
Identification of projects across the partnership that may be at high-risk for modern slavery practices
This assessment is not a confirmation of risk or the appropriate approach needed to respond. In most cases, projects may require further assessment, taking into account various factors such as the complexity of the procurement, the route to market, nature and characteristics of potential risks, and opportunities and challenges to managing these. Additionally, some projects may experience delays or changes before the procurement process begins and anti-slavery measures may need to be considered at a later stage. Further there is also a risk that some projects may go unflagged. Procurement officers regular receive reminders to flag projects.
To understand Orbis partner authorities’ exposure to potential modern slavery risks and opportunities to manage these.
Number of projects across the partnership that have been flagged as potentially high-risk by procurement officers.
At the time of drafting this statement, there are 231 projects in total that have been flagged. As projects are at various stages of the tendering process, this figure represents the total number of projects presently in our project management system rather than by financial year.
The Council understands the importance of ensuring that people within our organisation have the relevant knowledge to support wider anti-slavery efforts. The Council provides several courses for staff on modern slavery.
In addition to the Council-wide training available above, during the 2023/2024 financial year, a 90-minute session on modern slavery was delivered to commissioners and contract managers and two 1-hour sessions to procurement staff. These sessions were delivered by the Council’s Senior Policy Lead on Modern Slavery in the procurement team and offered guidance on embedding modern slavery considerations throughout service delivery including discussion on determining risk, drafting tender and contract wording, and engaging with suppliers, including guidance for officers conducting site visits. The training highlighted the importance of staff in doing their part within their respective roles to support the Council’s wider anti-slavery commitments.
For further information on modern slavery and how to spot the signs that someone may be a victim, go to:
Reports of suspected or actual cases of modern slavery can be made via the following channels:
This statement has been approved by the Corporate Services Directorates Management Team on 12 July 2024. It will be reviewed and updated on an annual basis.
Signed by: Bella Sankey, Leader of the Council
Date: 10 February 2025
Signed by: Jess Gibbons, Chief Executive
Date: 10 February 2025
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 Council is committed to applying the highest standards of openness, honesty, integrity, and accountability through the services it provides. 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.
Our Sustainable Procurement Policy sets how sustainability will be embedded into every procurement process or purchasing decision.
This Code sets out the responsibilities and rights of employees when carrying out their duties.
The Council has various policies which aim to promote high standards and good practices in relation to health, safety, and welfare.
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.
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.
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.
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 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 Policy sets out the approach taken to adult safeguarding across Sussex.
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.