1. Introduction
1.1 This statement sets out our actions to understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business or our supply chains. This statement relates to actions and activities during the financial year 1 April 2025 to 31 March 2026.
1.2 As part of local government, both as an employer and purchaser of a wide range of goods, services and works, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking. In addition to our responsibility as an employer, we also acknowledge we have a duty as a council to notify the Secretary of State of suspected victims of slavery or human trafficking as introduced by section 52 of the Modern Slavery Act 2015.
1.3 The council is absolutely committed to preventing slavery and human trafficking in our corporate activities and to ensuring that our supply chains are also free from slavery and human trafficking in line with Clause 54 of the 2015 Modern Slavery Act and subsequent government guidance and best practice.
2. Modern Slavery Act 2015
Read the Modern Slavery Act 2015.
3. Our organisation’s structure, our business and our supply chains
3.1 The council is a local authority, which provides a wide range of statutory and discretionary services for its residents, businesses, visitors and partners. The council only operates within the United Kingdom. Whilst the risk of slavery and human trafficking within our organisation and supply chains is considered low; we remain vigilant and will manage any risks presented.
From an organisational perspective, it is recognised that modern slavery is a crime that is prevalent within the UK, across many industries and as such, it is a risk that the council takes seriously. However, rather than this risk being looked at in isolation, modern slavery is managed alongside a range of other risks that must be dealt with as part of our business activities (for example, implementing responsible procurement and contracting, safeguarding of children and vulnerable adults, health and safety, etc.).
There is no typical victim of modern slavery. Victims are men, women and children of all ages, ethnicities and nationalities and cut across the population. However, it is normally more prevalent among the most vulnerable or within minority or socially excluded groups.
We have determined that there are no areas of our business that are considered to be at high risk of slavery or human trafficking. However, the kinds of situations where people could be in forms of modern slavery include forced labour, deception or abuse of vulnerability for the purpose of exploitation may include:
- men or women held in domestic servitude who never go out and perhaps shows signs of physical abuse
- men or women working in fields for example, fruit picking and living in caravans or substandard housing
- men or women working in small groups on casual manual labour such as block paving and tarmacking
- women working in pop-up brothels and massage parlours, often in small residential dwellings that regularly move around
- hand car washes
- nail bars
- hotels and restaurants
- factories and warehouses
- manufacture and sale of counterfeit goods
- men and women working in social care settings
Where people may be subject to sexual or domestic exploitation or abuse, forced to work long hours for little or no pay in poor conditions under verbal or physical threats of violence to them or their families or subject to criminal exploitation.
Risks specific to North Yorkshire have been identified as follows:
- criminal exploitation with links to County Lines (drug transportation across county borders); which for adults may include the cuckooing of their addresses and children being targeted and utilised to run drugs for adult dealers
- cold callers offering roofing, driveway, gardening and other house maintenance work
- hand car wash stations
- nail bars
- shops selling illegal vapes and tobacco
- sales of counterfeit goods online and at markets/car boot sales
- restaurants and takeaways
- food processing warehouses
- online sexual exploitation of children
- social care settings
These risks are key priorities for multi-agency safeguarding children, adults and community partnerships. Please see section 6 below.
3.2 Our structure is shown on our website here.
North Yorkshire is a place with a strong economy and a commitment to sustainable growth that enables our citizens to fulfil their ambitions and aspirations. The overall population is expected to increase from 618,100 (2019) to 651,804 by 2043. Within this increase, the population is projected to become substantially more aged.
3.3 The Council Plan sets out the council’s vision, ambitions and priorities for the next four years, as well as the approach we will take to achieve them.
The plan addresses the exciting opportunities to transform services, drive innovation and improve outcomes, but also the many significant challenges ahead due to the impact of rising costs and huge demand for our services.
Here is a brief summary of what the plan entails:
Our vision: We want to harness the power of North Yorkshire’s natural capital, unique communities and businesses, continuously improving our services to enable a good quality of life for all.
The plan is based around four key themes (each with supporting priority actions):
- support thriving places and empowered communities that live, work, visit and do business in North Yorkshire
- develop more sustainable and connected places across North Yorkshire
- ensure the people of North Yorkshire are safe, healthy and living well
- maximise the potential of North Yorkshire’s people and communities
Supported by the following overarching ambition: strong innovative council, with local customer-led services.
Our aim is to be the ‘most local large council’; therefore, locality working is another key element of our Council Plan. The plan outlines our four pillars of locality working:
- local services and access
- local accountability
- local action
- local empowerment
3.4 Our organisation
The council protects our own employees from becoming victims of modern slavery, through fair and robust recruitment practise, pay and conditions, and having support mechanisms in place such as access to whistleblowing, and an employee assistance programme.
Our regulatory services and corporate partnerships with other public sector community safety organisations and enforcement agencies, enables us to share and act upon intelligence to prevent, reduce and successfully prosecute criminal activity whilst providing support to those affected by labour exploitation in our communities.
National Referral Mechanism (NRM)
The council is committed to supporting the identification and protection of victims of modern slavery and human trafficking. Through the National Referral Mechanism (NRM), the UK's framework for the identification and support of potential victims, the council acts as a First Responder and works collaboratively with safeguarding partners to ensure that concerns are reported and appropriate support pathways are accessed. Staff are trained to recognise the signs of exploitation and understand the procedures for making referrals and safeguarding individuals at risk.
3.5 Our supply chains
Procurement at the council is a centralised function and spends around £880m with approximately 7,000 suppliers each year. Our procurement activity is focused around three main categories of spend: People, Place and Professional Services.
- people
- place
- professional services
People
The people procurement team includes contracts for older people, adults with disabilities, mental health services, education, children and families and public health.
Place
The place procurement team is focused on highways and major schemes, waste, energy construction and schools.
Professional
The professional procurement team includes contracts for finance, technology, insurances, integrated passenger transport and food.
The Procurement and Contract Management Service takes the lead on tackling modern slavery in our supply chains, although there is recognition that responsibility and effort permeates and extends throughout the organisation, particularly in those areas more susceptible to modern slavery.
Our procurement activity complies with the council’s procurement and contract procedure rules, the wider Procurement Regulations 2024 and the Modern Slavery Act 2015.
Our category management approach helps identify at risk markets and supply chains.
To comply with the Modern Slavery Act 2015, we:
- ensure our professional and technical ability tender questions within the procurement sourcing process require a bidder to evidence their compliance with the Modern Slavery Act if they are a relevant commercial organisation as defined by Section 54 of the Modern Slavery Act 2015. Any bidder who fails to evidence their compliance with the required legislation shall be excluded from participating further in the tender process
- bidders who have been convicted of certain modern slavery offences under the Modern Slavery Act within the last five years must be excluded from our procurements, unless they can demonstrate that they have taken measures to remedy the failures and prevent recurrence
- companies who bid and who have failed to meet their legal obligations in the last three years risk being excluded from public procurements, unless they can demonstrate that they have taken measures to remedy the failures and prevent recurrence
- incorporate contract term clauses that specify the supplier’s contractual obligation concerning modern slavery
- any supplier engaged by us to undertake the supply of goods, works or services is contracted to do so in line with any relevant safeguarding, equality and diversity code of conduct, and whistleblowing policies
- report any suspected or known incidents of slavery/trafficking to the relevant Police Authority, and the Public Health, which are the direct link with the Serious and Organised Crime Unit, and Modern Slavery Partnership for York and North Yorkshire. Under Section 52 of the Modern Slavery Act 2015, Local Authorities are under a duty to notify the Home Office if they identify a potential victim of modern slavery
Whilst we are aware that modern slavery can occur much closer to home, some of the global sourcing activity presents the highest risk to human rights within the supply chains we use. We procure items such as stationery, arts and crafts, sport and early years products through our Public Sector Buying Organisation, Yorkshire Purchasing Organisation. Some of these items are sourced direct from overseas suppliers with a number of products classified as globally sourced from factories across China, Taiwan and Thailand. Yorkshire Purchasing Organisation have put in place a robust procurement and audit process. Ethical audits to the Ethical Trade Initiative Base Code as a minimum are requested as part of the tender process and Yorkshire Purchasing Organisation request factories are re-audited at least every three years, 95% of Yorkshire Purchasing Organisation globally sourced products are sourced from a factory that has been ethically audited to a satisfactory standard.
Within our procurement and contract management service, we already have many staff who hold or are working towards a professional qualification from the Chartered Institute of Procurement and Supply. The Chartered Institute of Procurement and Supply have a wide range of eLearning modules available for members including the Ethical Procurement and Supply which we encourage all staff to complete. This training covers three topics: environmental procurement; fraud, bribery and corruption; human rights.
The procurement and contract management service are also required to complete the Government Commercial Function, Tackling Modern Slavery in Supply Chains training. This eLearning raises awareness of how more sustainable and ethical outcomes can be achieved through ethical procurement. Internal training and guidance are provided to staff who are responsible for sourcing around working with the Modern Slavery Act. The council is also committed to raising awareness by collaborating with similar organisations to discuss issues relating to Modern Slavery.
In 2025 to 2026 the procurement and contract management service developed a modern slavery risk assessment which aligns to Government Procurement Policy Note PPN009 and must be completed for every above threshold procurement. The assessment supports the council in determining if the procurement is at high, medium or low risk of modern slavery with associated actions:
Medium risk:
- request suppliers to agree to the Supplier Code of Conduct
- request a copy of their Modern Slavery Statement (PSQ)
High risk:
- require suppliers to agree to the Supplier Code of Conduct
- request a copy of Modern Slavery Statement (PSQ)
- include a mandatory Conditions of Participation/Tender Question re Modern Slavery
- contract management - ensure ongoing monitoring throughout the contract
A Supplier Code of Conduct, reflecting the Procurement Policy Notes (PPN009) and Cabinet Office guidance has been developed and introduced. Ensuring a consistent approach, demonstrating alignment to the national agenda and standardise the messaging to suppliers working in our supply chains
The council is aware of several of our supply chains struggling with recruitment and retention and the risk that this poses to the continued safe delivery of services, plus a potentially heightened risk in supply chains due to this scarcity of labour.
A significant area of spend for the council is in relation to Adults Social Care. With an aging population demand for these services is increasing. There is a growing concern about modern slavery within this sector across the UK. The Homecare Association which represents domiciliary care providers has reported a rise in new companies registering as the Care Quality Commission and concerns linked to the exploitation of workers.
The Care Quality Commission has also spoken out about modern slavery now being a feature of the UK's social care market.
Acknowledging the potential exploitation of this area, the council has taken steps to improve our due diligence and support the market including:
- understanding if any of the workforce is international as part of our onboarding conversations to the council's approved provider list
- undertaking a review of existing terms and conditions to bolster requirements for Providers to notify the council if there is a change in sponsorship status
- as part of the council’s assurance process, Quality Assurance Officers and Quality Improvement Officers undertake onsite visits to care settings
- utilise our wider networks across the region which includes other Local Authorities; the Local Government Association; the Independent Care Group; Health partners etc
- as part of our work with the care sector to transform services, we are keen to adopt the principles of the Ethical Care Charter, the overriding objective of which is to establish a minimum baseline for the safety, quality and dignity of care by ensuring employment conditions which:
- a) do not routinely short-change people and;
- b) ensure the recruitment and retention of a more stable workforce through more sustainable pay, conditions and training levels
- as part of the Yorkshire and Humber International Recruitment partnership the council’s recruitment team:
- provide support and guidance to care providers helping them understand their sponsorship responsibilities and adopt ethical international recruitment practice
- support care sector employers recruit domestic and international workers to help meet workforce shortages, reducing pressures
- provide a ‘matching service’ to migrant workers whose employer has had their sponsorship licence revoked, helping workers find new compliant, ethical sponsored work in the care sector
- provide advice and guidance to migrant workers to help them understand their rights and encourage reporting of unethical experiences
- work in partnership with Home Office, UKVI, North Yorkshire Police, GLAA and Department for Health and Social Care to share intelligence, report concerns and stamp out unethical international recruitment practice
- as part of the Yorkshire and Humber Strategic Procurement Group (SPG) an Ethical Procurement group has been established which includes a focus on modern slavery. This group has identified that construction and health and social care sectors have the highest risk
- review Modern Slavery Partnership and their role in Modern Slavery mitigation
4. Our policies in relation to slavery and human trafficking
We review our policies and procedures on an ongoing basis to ensure they remain compliant and fit for purpose. The following policies and procedures are considered to be key in meeting the requirements of the Modern Slavery Act 2015.
4.1 Safeguarding
We embrace our responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and adults at risk. We have comprehensive Safeguarding Policies which all staff and councillors are required to work within. We work within multi-agency partnerships to protect and safeguard people, in particular these key partnerships are the Safeguarding Adults Board, the Safeguarding Children’s Board, the North Yorkshire and York Modern Slavery Partnership and the Health and Wellbeing Board.
4.2 Recruitment
Our recruitment processes are transparent and reviewed regularly. They include robust procedures for vetting new employees, which ensures they are able to confirm their identities and qualifications. To comply with the Asylum, Immigration and Nationality Act 2006, all prospective employees supply evidence of their eligibility to work in the UK. References are also secured.
All managers are required to complete mandatory safer recruitment training.
4.3 Agency workers
We currently source our agency workers through one supplier. This supplier complies with the Modern Slavery Act 2015 and our employment and safeguarding policies. Our contract ensures compliance with the Act throughout the agency supply chain. For instance, we can view identification documents, references and disclosure and barring certificates for agency workers; this helps us ensure that the person introduced by the agency is the person completing the assignment and we have transparency in the payment of agencies and agency workers.
4.4 Pay
We operate a Job Evaluation Scheme to ensure that all employees are paid fairly and equitably in a nationally agreed pay framework. Equal pay is evaluated and governed by the Corporate Pay and Reward Group in partnership with trade unions.
4.5 Employee code of conduct
Our Employee Code of Conduct makes clear to employees the actions and behaviours expected of them when representing the council. We strive to maintain the highest standards of employee conduct and ethical behaviour and breaches are investigated and appropriate action taken.
4.6 Whistleblowing
We encourage all our employees, customers and other business partners to report any concerns related to the direct activities or the supply chains of the council. Our whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.
5. Due diligence
With numerous categories of spend, we have a wide range of supply chains each with individual characteristics, covering goods, works and service-based supply chains. We therefore identify the areas of high risk to human rights and act accordingly.
Our category sourcing strategies highlight those spend areas, markets and supply chains which present the greatest risk of modern slavery abuses. These plans form the basis of our procurement approach.
During 2025/26 the council will be embedding contract management deep dives, part of this assessment will look at the risk of modern slavery within the supply chain.
This is now an established quarterly process which reports to the Corporate Procurement Board.
Modern Slavery is captured under the contract risk management section of the deep dive process.
The council, in its position as a member of the Yorkshire and Humber Strategic Procurement Group and the National Advisory Group for Procurement, will continue to encourage collaboration amongst local authority procurement services in the region, to share best practice and learning, seeking to improve the response of the region as a whole.
6. Staff training and learning
We have a programme of training and learning to ensure staff are well equipped to perform well within their roles. Modern Slavery training is available to all staff, it enables officers particularly in community facing roles to identify and know how to report suspected incidents of abuse and neglect, including modern slavery and trafficking.
Any manager of a service where safeguarding knowledge is required, for instance, dealing with members of the public who may have vulnerabilities, must complete statutory and mandatory training.
We also work in partnership with a wide range of agencies to prevent abuse and neglect, to detect and report occurrences and to support victims. As part of this, we ensure appropriate reference to Modern Slavery and human trafficking.
This includes our work as part of:
- Safer North Yorkshire, formerly known as the North Yorkshire Community Safety Partnership
- our multi-agency Safeguarding Children’s Board
- our multi-agency Safeguarding Adults Board
- our Health and Wellbeing Board
- North Yorkshire Police Disruption Panel
7. Approval
This statement has been approved and it will be reviewed and updated annually.
Richard Flinton
Chief Executive
North Yorkshire Council
Cllr Carl Les OBE
Leader of the Council
North Yorkshire Council