Modern Slavery Act Statement

Introduction

This statement applies to the Health Research Authority (HRA) and is made pursuant to section 54(1) of the Modern Slavery Act 2015, PPN 02/23 Tackling Modern Slavery in Government Supply Chains, and statutory guidance Transparency in supply chains: a practical guide.

The HRA strongly supports the government's objective of eradicating modern slavery in all its forms and eliminating this abhorrent crime. We recognise our ethical responsibility to actively combat these practices and support victims, and we are dedicated to ensuring that our business operations and supply chains are completely free of any form of exploitation, including servitude and forced or compulsory labour. We endeavour to uphold the highest ethical and labour standards in all that we do.

About the HRA

The HRA’s mission is to protect and promote the interests of patients and the public in health and social care research, working with partners across the UK.

The HRA provides a UK-wide research review system, co-ordinated across the regulators in the four nations, streamlining governance and promoting good practice across health and social care research. The HRA’s staff enable collaboration to streamline the set-up and review of research, to provide specialist advice, guidance and learning and to support the HRA’s committees and advisory groups.

Further information about the HRA is available on our website.

Organisational structure

The HRA is an arm's-length body (ALB) of the Department of Health and Social Care (DHSC). We are governed by a Board comprised of five non-executive directors, including the chair, and three executive directors. As part of our commitment to openness and transparency, Board meetings are held in public and Board papers and minutes are available on the our website.

Our employment policies and workplace initiatives

Our employment policies and procedures are regularly reviewed to ensure compliance with current legislation and best practice. These policies provide guidance and advice to staff and managers and are accessible to all staff via our intranet.

NHS terms and conditions and values

To ensure fairness, we adopt NHS national pay, terms and conditions of service. We also uphold the NHS values and behaviours that staff are expected to comply with, with all candidates expected to demonstrate these attributes as part of the recruitment selection process.

Staff equality networks

To promote human rights, equality and diversity and avoid discrimination against any staff, potential staff, members, partners, service users or anyone that deals with us in any way, we have a number of staff equality networks who get together regularly to share experiences and ideas, and to have a voice in our strategic equality, diversity and inclusion work. These networks include:

• REACH (race, ethnicity and cultural heritage)
• Disability
• LGBTQ (lesbian, gay, bisexual, transgender, queer or questioning)+ Allies
• Faith and other beliefs
• Age
• Mental health,
• Working Parents and Carers

These networks help to ensure that barriers to accessing services and employment are identified and removed, and that no person is treated less favourably on the grounds of their race, ethnicity, religion or belief, age, gender, marital status, trans status, disability, sexual orientation, mental health status, caring responsibilities or socio-economic background.

Staff Voices

Our group of elected staff representatives and appointed managers, meet to discuss issues that may impact HRA staff and raise questions, concerns, and ideas on behalf of colleagues. The reps meet with the senior management team every two months. All members of staff are welcome to observe meetings.

UNISON and MiP

The HRA has a partnership agreement with UNISON (the country’s largest trade union representing staff in the NHS) and Managers in Partnership (MIP) and has members in all HRA offices. The partnership agreement commits the HRA, UNISON and MiP to working together to deliver the HRA’s core objectives and to improve the working lives of its employees.

Whistleblowing

Our freedom to speak up (raising concerns) policy and procedure sets out the guiding principles and process for ensuring that reports that would have previously been called 'whistleblowing' are dealt with in a fair, timely and consistent way and that staff have the confidence to report concerns without fear.

Diversity and inclusion

To ensure all staff have a good understanding of diversity and inclusion, they are required to undertake mandatory training in this area. Ongoing learning opportunities and resources are also provided. We regularly review and track progress on promoting and supporting diversity and inclusion. This includes monitoring trends in our workforce data and using Equality Impact Assessments (EIA) to inform the development of policies, processes and the services we provide.

Dignity and respect

In line with our commitment to equality and human rights, the HRA has developed a suite of resources and guidance, alongside our dignity and respect policy, which set the tone for our organisational culture.

A summary video is embedded in our staff and community induction so that everyone understands HRA expectations.

Our supply chains and assessment of current risk

We have mapped our direct supply chains and have assessed our overall risk of modern slavery as low. The HRA does not currently procure from suppliers in high-risk industries. However, we are committed to continuous monitoring and improvement and will seek opportunities to implement additional risk mitigation measures in line with best practice.

Our core procurement category areas comprise of information technology and digital services, professional and consultancy services, and general corporate services, such as finance, human resources administration, travel, facilities and estates.

Identifying and managing risks in both procurements and existing contracts

We have adopted Procurement Policy Note 05/19: Tackling Modern Slavery in Government Supply Chains and updated training for the commercial team.

All commercial team members are required to have completed the ‘Government Commercial College training on Tackling Modern Slavery in Supply Chains’. This training supports staff in understanding how to identify modern slavery and how to tackle it effectively in supply chains, both in existing contracts and new procurement activity.

As part of our due diligence, all new suppliers must complete and return a new supplier questionnaire detailing their business structure, policies, and practices, including those related to ethical / anti-slavery, equal opportunities, diversity, health and safety, quality assurance and sub-contracting. This information helps the HRA identify potential risks and areas of concern before establishing a business relationship and ensures that only suppliers who meet our ethical standards are onboarded.

Our standard contract is based on the Government Legal Department (GLD) Short Form Contract. This includes a requirement for suppliers to adhere to the HM Government Supplier Code of Conduct, including compliance with the Modern Slavery Act.

We also use Government framework agreements, particularly the Crown Commercial Service (CCS) frameworks, to procure common goods and services. The CCS Public Sector Contract terms and conditions include a Corporate Responsibility Schedule (Joint Schedule 5), which also requires suppliers to meet the standards set out in the HM Government Supplier Code of Conduct; specifically to include anti-slavery and human trafficking provisions in its contracts, implement policies and procedures to identify and prevent modern slavery, and prepare an annual modern slavery statement. We understand that this schedule is being updated to make it more flexible and effective in how it can be applied. In turn this will benefit and enable the HRA to request reports from suppliers which detail the steps they have been taking to tackle modern slavery risk (even in market sectors which are considered to be low risk).

Commitment to supporting victims of modern slavery in our supply chains

If the HRA identifies modern slavery in our supply chains, we will address this immediately, in a manner proportionate and appropriate to the circumstances.

We will do this by working collaboratively with the supplier and in accordance with the terms of the contract to address the issues that have been identified. This is to avoid leaving the victims more vulnerable and at risk by terminating the contract immediately. Where possible an action plan will be put in place to improve the position of the workers involved and ensure such issues do not arise in future.

Next steps

Our next steps are:

1. We understand that new regulations and tools are being developed by the Secretary of State for Health and Social Care with a view to eradicating slavery and human trafficking from NHS supply chains. The HRA will ensure that it understands and take steps to comply with its obligations under the new regulations.
2. We will continue to ensure that the commercial team is trained and kept updated on ethical procurement best practice, including tackling modern slavery.
3. We will consider where it might be appropriate to further strengthen our risk identification and due diligence measures by mandating, where appropriate, new and existing suppliers to complete the Modern Slavery Assessment Tool.
4. We will carry out a comprehensive review of our procurement processes to identify if there are any additional measures we should put in place to further help identify and manage modern slavery risk at each stage of the process; from pre-procurement planning and early market engagement to specification, selection, award, and contract management.

Review of effectiveness

This statement will be reviewed and updated on an annual basis.

Approval and review

The HRA Board approved this statement at its meeting on Wednesday 20 November 2024.