For the financial year ending 31 March 2025
Brighton & Hove City Council remains committed to 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 outlining the actions taken each year to tackle modern slavery risks within their operations and supply chains. While not required by the transparency provision to publish a statement, Brighton & Hove City Council recognises the important role the public sector must play in helping to address this critical issue and has voluntarily chosen to report on our activities.
This is the Council’s 2024 to 2025 statement. The structure and content of the statement remains the same as our previous statement, with sections updated to reflect key activities undertaken during the 2024 to 2025 financial year.
Brighton & Hove City Council is committed to making the city a better Brighton & Hove for all. Our 2023 to 2027 Council Plan outlines the Council’s vision to achieve this, with focus on four outcomes:
Our plan aims to ensure that the necessary support, services and infrastructure is in place so that our people, communities and local businesses can flourish. We are committed to inclusivity to ensure that our city is equitable and that everyone feels safe, included and can thrive. We are striving to ensure measures are put in place to meet the needs of both current and future generations. This includes:
Additionally, the Council is committed to a positive, respectful and values driven organisational culture. As part of this commitment, we have developed a Learning Organisation Framework to guide our journey to becoming a Learning Organisation and creating a better Brighton & Hove for all.
Our framework is built on five pillars:
These principles directly support our efforts to tackle modern slavery and broader unethical labour practices by ensuring that our staff feel empowered, included in decision-making and supported in their health and wellbeing. Poor labour practices often manifest in organisations that lack measures to protect staff from issues such as exploitation, discrimination and unsafe working conditions. These issues can create environments where unethical labour practices can thrive, and our Learning Organisation Framework helps safeguard against these risks.
At the time of writing this statement, local government is undergoing significant changes. The Procurement Act 2023 which came into effect on 24 February 2025, established a new public procurement regime aiming to improve and simplify procurement processes and make it easier for smaller businesses to contract with public sector authorities. Separately, discussions and plans around local government reform are set to transform the structure and responsibilities of local authorities, representing a significant shift in local government in half a century. These developments are a pivotal moment in local governance, impacting how services are procured, delivered and managed across our communities.
Amidst these changes, Brighton & Hove City Council remains committed to tackling modern slavery. With an estimated 50 million victims globally and over 100,000 in the UK, this is a grand challenge that is closely interconnected with broader global issues such as those highlighted in the United Nations’ sustainable development agenda. The Council is dedicated to doing our part to help foster a just transition to ensure that vulnerable populations, including residents, communities and workers at risk of exploitative practices, are not overlooked as we pursue our net-zero future.
As a local authority, we recognise that we have several roles to play to help address the problem of modern slavery. This includes safeguarding vulnerable adults and children from exploitation and harm, identifying potential victims in our role as first responders, and working to implement measures that protect workers in our operations and supply chains from modern slavery and other unethical labour practices.
Our 2024 to 2025 modern slavery statement provides an update on all six areas recommended by Section 54 of the Modern Slavery Act 2015:
The Council recognises the important role the public can play in shining a light on modern slavery practices. As Section 54 of the Modern Slavery Act 2015 encourages public scrutiny of modern slavery statements, we have included information for reporting suspected or actual cases to the relevant authorities.
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 with certain sections of the document updated as necessary.
This statement has been updated to reflect the authority’s current approach and activities undertaken in the 2024 to 2025 financial year. It relates to key steps taken by the Council between 1 April 2024 and 31 March 2025.
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 Corporate Leadership Team provides strategic direction to the whole council which is organised into the following directorates:
Brighton & Hove City Council have a shared procurement service with Surrey County Council and East Sussex County Council. Our partnership helps 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. This includes embedding policy areas such as modern slavery, social value and environmental sustainability to ensure that third party spend is aligned with government and organisational objectives and that our supply chain partners commit to ethical, fair, responsible and sustainable practices.
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 shared procurement service, its contribution to our anti-slavery in supply chain activities is vital. Accordingly, this work is driven by our procurement service for the benefit of the three authorities and our supply chains.
Beyond work undertaken in our procurement service to mitigate modern slavery risks in our supply chains, the Council also has people and teams across the authorities working on addressing related concerns such as issues connected to abuse, vulnerability, safeguarding, and community and partnership.
During the 2024 to 2025 financial year the Council spent approximately £434m with 4,325 suppliers.
| Directorate | Spending |
|---|---|
| Homes & Adult Social Care | £241m |
| Families, Children & Wellbeing | £75m |
| City Operations | £94m |
| Central Hub | £24m |
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 also recognise that modern slavery sits on the extreme end of the labour exploitation continuum. Therefore, 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, in our operations and supply chains. This includes whistleblowing, recruitment, health and safety, and grievance policies. Details of key policies and their relevance to modern slavery can be found in the Annex.
In July 2024, our procurement service published a revised Supplier Code of Conduct. The Code of Conduct outlines the Council’s expectations of suppliers with regards to ethical conduct when bidding for and delivering contracts.
Our Code is centred around three key principles: people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly and maintain high standards of integrity and professionalism in their business dealings.
Under our “People” principle, we affirm our commitment and expectation for supply chain partners to respect and uphold labour and human rights. We expect all suppliers to adhere to the principles outlined in the Code and where specific risks or opportunities are identified, we elaborate on relevant aspects of the Code in procurement and contract management activity. In June 2024, a training session on the Code was delivered to the procurement team to increase their awareness of it and its implementation.
In our last statement, we set a performance measurement to review a sample of projects to ensure that the Code was being implemented to tackle modern slavery in high-risk projects. However, this has been removed as the Code is communicated in all procurements, regardless of modern slavery risk. However, in cases where specific risks and opportunities related to modern slavery are identified in a project, further due diligence measures are implemented in addition to the general application of the Code (see section on due diligence).
As part of our broader procurement policy efforts, our procurement policy team will routinely review projects to ensure that the Code is communicated to all suppliers and that they are committed to adhering to its principles.
As a public sector body, we recognise the risk of modern slavery facing vulnerable people and service-users in our community, as well as workers in the supply chains supporting our activities. We also acknowledge that modern slavery is an issue that is prevalent in the UK. While we have an ambition to work with local supply chains, the risk of slavery still exists as the unfortunate reality is that no supply chain is entirely free of modern slavery or unethical labour practices.
Modern slavery can take place at any stage of a supply chain, from the extraction of raw materials to the delivery and use of a final product while people delivering and receiving services can be subjected to exploitative practices by perpetrators internal and/or external to an organisation.
To aid our understanding of risks and inform our due diligence approach, we regularly consult and communicate up-to-date information on high-risk goods and services within the UK and beyond. 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 exposure to modern slavery issues is likely much greater due to the extent and nature of our activities.
The risk of modern slavery in our procurement activity and supply chains is reviewed at a category and project level. Procurement officers are encouraged to flag projects that fall within our prioritised categories with regular guidance issued by our Senior Policy Lead on Modern Slavery (SPL-MS), based in the procurement team on mitigating potential risks. Our SPL-MS also has visibility of projects and directly supports the embedding of modern slavery requirements in those where policy-related risks or opportunities have been identified. This means that we can ensure that modern slavery and unethical labour considerations are built into our tendering activity, identify areas to improve, and assess other key projects that fall outside our prioritised categories but nevertheless carry an element of risk in the supply chain.
In our procurement activity, we often prioritise our due diligence on projects based on risk characteristics such as industry type, the nature of the workforce (such as reliance on low skilled or agency workers), and complexity of business model and supply chain (such as sub-contracting arrangements) and opportunities to manage risks.
Due to the activities and services we undertake and deliver as a local authority, we expect the type of risks we are likely to encounter to remain consistent and unlikely to vary significantly.
This section of our statement reports on activities aimed at understanding and managing risks within our operations and communities and our supply chains.
The Council has 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 a 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 has a duty to notify (DtN) the Home Office to support intelligence gathering.
In 2024, 19,125 potential victims of modern slavery were referred to the Home Office.
Of these, Brighton & Hove City Council referred 29 potential victims into the NRM. Of the 29 potential victims, 26 were children (aged 17 and under). Two DtN referrals were also made.
In the last year, Brighton & Hove City Council continued to take part in a national pilot to develop approaches on decision-making concerning children who have been identified as victims of modern slavery and exploitation.
With regards to adult safeguarding, Section 42 of the Care Act requires local authorities to make enquiries, 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. The Care Act 2014 includes modern slavery as a type of abuse, as well as being a serious crime, therefore, managing cases of modern slavery is closely linked to safeguarding adults procedures.
A section 42 duty is triggered when three requirements of the Care Act have been met. This is when an adult: has care and support needs, is experiencing or is at risk of abuse or neglect, and as a result of those care and support needs is unable to protect themselves from the risk or experience of abuse or neglect.
During the 2024 to 2025 financial year, 6 safeguarding cases reported as a modern slavery concern progressed to a section 42 safeguarding enquiry. This figure only reflects the cases that have been enquired upon and is not indicative of all safeguarding concerns received by the Local Authority.
During the 2024/2025 financial year, our shared procurement service continued to maintain the Councils’ collective efforts to combat modern slavery in our supply chains. Key due diligence work undertaken across our procurement partnership in the 2024/2025 financial year included:
The Council continue to have the following training available to all staff on our e-learning platform.
Overview of Modern Slavery
This is a 1 hour and 30-minute e-learning course which provides an understanding of modern slavery and the Council’s procedure for working with people that may have experienced modern slavery or human trafficking. The course contains two e-learning modules. The first module provides a brief overview of modern slavery and requirements around greater transparency to tackle modern slavery. The second module provides guidance on the Council’s Modern Slavery Pathway Procedure for working with victims and includes information on referring potential victims into the NRM.
Introduction to Modern Slavery in Supply Chains
This is a 60-minute e-learning course designed by the Council’s Senior Policy Lead on Modern Slavery in the procurement service to help staff in supply chain management roles understand the unique issue of modern slavery in supply chains. It includes information on key findings of the Global Slavery Index 2022 in relation to forced labour in supply chains, the current legislative landscape, the International Labour Organization’s Indicators of Forced Labour, high-risk sectors for forced labour, examples of cases within the UK and public sector responsibility for addressing modern slavery risks within our supply chains.
In addition to the training available above, during the 2024 to 2025 financial year, a one hour training session on responsible contracting was delivered to 54 procurement and contracting staff on developing appropriate contract terms and conditions – including drafting contract KPIs and quality requirements, and lessons learned from current projects that can help inform our broader due diligence approach to managing modern slavery risks.
This session was delivered by the Council’s SPL-MS. The procurement policy team also delivered a one hour training session to procurement staff to launch the revised Supplier Code of Conduct. The session aimed to improve staff’s understanding of the purpose of the Code of Conduct, how it should be used and what it is aiming to achieve.
Our general approach to tackling modern slavery, particularly within our supply chains, is heavily informed by existing research, best practices, and statutory guidance. Research on modern slavery statements often report that one of the areas organisations tend not to report on are indicators to measure effectiveness of anti-slavery efforts. The Council therefore recognises this as an area for improvement and is working to strengthen how we measure our overall approach. As aforementioned, a challenge the Council faces with tracking actions to tackle modern slavery and consequently their effectiveness, is the number of activities and correspondence undertaken in this area by different people, teams and services across the authority, particularly those that handle concerns such as safeguarding whose work captures modern slavery issues alongside others.
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 helping us to:
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
Procurement team:
Review active high-risk projects to understand how modern slavery considerations were embedded
Due to capacity limitations, it is not feasible to assess tender materials for all projects previously awarded that may present a high-risk of modern slavery.
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 2024/2025 financial year, 20 projects across the Orbis Partnership with a total contract value of approximately £595 million 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 348 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.
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 Leadership Team on 25 September 2025. It will be reviewed and updated on an annual basis.
Signed by: Bella Sankey, Leader of the Council
Date: 1 October 2025
Signed by: Jess Gibbons, Chief Executive
Date: 25 September 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 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. It also includes a specific section on modern slavery which requires Council officers to have regard to the risk of unethical labour practices in the supply chains of goods, services and works that being procured.
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.
Our Environmentally Sustainable Procurement Policy sets how sustainability will be embedded into every procurement process or purchasing decision. Relatedly, our Social Value Framework 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.
This Code sets out the responsibilities and rights of employees when carrying out their duties. This includes encouraging employees to report concerns 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 organisational values by setting out in more detail the standard of behaviour expected of officers whilst carrying out their 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.
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.
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 an Anti-bullying, Harassment and Victimisation Policy which aims to assist in maintaining a supportive, inclusive, and respectful working environment where unacceptable behaviour is easily identified, challenged, and stopped.
Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns.
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.
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.
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.
The Policy sets out the approach taken to adult safeguarding across Sussex. The Procedures explain how agencies and individuals should work together to put the Sussex Safeguarding Adults Policy into practice. They have been updated in accordance with the Care Act 2014 and the Care and Support Statutory Guidance, and should be read in conjunction with these.
This policy and procedures provide an overarching framework to ensure a proportionate, timely and professional approach is taken, and that adult safeguarding is co-ordinated across all relevant agencies and organisations. This is essential for the prevention of harm and abuse.
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.
The development of the procedures manual is one of the core functions of the safeguarding partners in their role to coordinate local work to safeguard and promote the welfare of children. The procedures encourage close working between agencies to facilitate early intervention in a supportive way to meet the needs of children and their families.
The Council believes that its supply chain plays a vital role in making a positive contribution to its communities and society. Procuring in an ethical, fair, responsible and sustainable way which allows us to work with successful bidders to align with our policy objectives is a priority.
The Council's Supplier Code of Conduct embeds these policy objectives and provides a detailed expectation of our supply chain. We expect our suppliers and their supply chains to follow three key principles which focus on people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly, maintaining high standards of integrity and professionalism in their business dealings.