The NHS has a significant role to play in combatting modern slavery and supporting victims. But to do this we need to ensure that staff understand that modern slavery exists, and we need to ensure that staff are confident and able to both recognise the signs and indicators of both victim and perpetrators and know what to do.

From 1 November 2015, specified public authorities have a duty to notify the Secretary of State of any individual identified in England and Wales as a suspected victim of slavery or human trafficking, under Section 52 of the Modern Slavery Act 2015.

 https://www.modernslaveryhelpline.org/   

What is Modern Slavery?

Slavery is a violation of a person’s human rights. It can take the form of human trafficking, forced labour, and bonded labour, forced or servile marriage, descent-based slavery and domestic slavery. A person is considered to be in modern slavery if they are;

  • Forced to work through mental or physical threat
  • Owned or controlled by an “employer”, usually through mental or physical abuse
  • De-humanised, treated as a commodity or sold or bought as “property”
  • Physically constrained or has restrictions placed in their freedom of movement

Our Organisation

 

The Trust fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS has to play in both combatting it and supporting victims. In particular, we are strongly committed to ensuring our supply chains and business activities are free from ethical and labour standards abuses. This report describes the actions the Trust are taking to prevent any form of modern slavery or human trafficking.

Summary of key issues 

Addressing modern slavery is a moral imperative for NHS organisations, reflecting a commitment to human dignity, ethical practice, and the protection of vulnerable individuals. In line with the Modern Slavery Act 2015, NHS bodies are required to publish an annual statement detailing the steps taken to prevent slavery and human trafficking within their operations and supply chains.

This obligation ensures transparency and accountability in procurement and workforce practices. The statement highlights key measures including staff awareness, safe recruitment, and robust safeguarding protocols.

Trust policies and procedures demonstrate the support the organisation’s commitment to ethical standards, human rights, and the protection of vulnerable individuals.

Modern Slavery and Human Trafficking Act 2015 Annual Statement

August 2025 to July 2026

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and applies to Surrey and Sussex Healthcare NHS Trust.

Organisational structure and purpose Surrey and Sussex Healthcare NHS Trust:

Surrey and Sussex Healthcare NHS Trust is one of the region's busiest providers of healthcare serving a population of 744,000.

We run East Surrey Hospital in Redhill, where we have more than 700 beds and provide acute and complex services. In addition, we provide a range of outpatient, diagnostic and less complex planned services at The Earlswood Centre, Caterham Dene Hospital, Crawley Hospital and Horsham Hospital.

We are a major local employer, with a diverse workforce of around 5,500 staff providing healthcare services to a growing population of some 744,000 people.

Last year we had:

  • 496,538 outpatient appointments
  • 51,327 planned admissions
  • 3,817 births
  • 48,341 emergency admissions
  • 124,805 ED attendances

Organisational policies

The Trust has internal policies and procedures in place that assess, identify and respond to any concerns in relation to the potential for modern slavery or human trafficking.

The Trust Safeguarding policies include information on modern day slavery/human trafficking with clear guidelines on how to identify, ensure patient safety and escalate using the agreed processes.

The procedures states that staff should report incidents of all types and this includes concerns regarding modern slavery and human trafficking via the safeguarding route. All staff have access to the Trust Safeguarding Adults Service for support and guidance when they are concerned about modern day slavery or human trafficking. The Trust has a ‘Freedom to Speak Up – Raising a matter of concern’ policy which details how staff can raise any concerns that they may have confidentially. This can be through a Freedom to Speak Up email inbox, or through a conversation with the Freedom to Speak Up Guardian, who will provide support to the individual raising a concern. Staff are provided with this information at corporate induction.

Current initiatives

The Trust fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role the NHS has to play in both combatting it and supporting victims. In particular, we are strongly committed to ensuring our supply chains and business activities are free from ethical and labour standards abuses. Steps taken to date include:

  1. Procurement

Our Trusts procurement policy regarding modern slavery is based on the below key principles:

  • Zero tolerance: we maintain zero tolerance towards modern slavery, refusing any engagement with suppliers involved in forced labour or exploitation that we are aware of.
  • Legislative compliance: we adhere to all modern slavery laws, including the UK Modern Slavery Act, and ethical conduct is part of our procurement processes
  • Supplier engagement: we communicate our ethical expectations to suppliers, requiring compliance with our modern slavery policy through codes of conduct and contractual obligations
  • Risk assessment: assess and mitigate modern slavery risks, considering factors like location, industry sector, and procurement activities.
  • Training and awareness: we educate staff on identifying signs of modern slavery and the importance of ethical sourcing, ensuring a vigilant approach to procurement practices
  • Continuous improvement: we continuously review and enhance our policies and practices to strengthen our anti-slavery efforts and maintain alignment with best practices

Our procurement approach follows the Cabinet Office Procurement Policy Note 02/23: ‘Tackling Modern Slavery in Government Supply Chains’ to identify and manage risks in both new procurement activity and existing contracts.

  • Pre-procurement and specification: identify the risk of modern slavery to the contract to establish if modern slavery can be factored into the specification, ensuring that the approach taken is proportionate based on the risks identified
  • Selection stage: consider the mandatory and discretionary exclusion grounds as set out in the Standard Selection Questionnaire, and if these can be supplemented with additional questions for medium / high risk contracts, whilst not creating barriers to participation by SMEs/VCSEs
  • Award stage: apply the standard criteria in the Social Value Model, ensuring these sufficiently take account of the risk of modern slavery and any specification requirements, whilst taking a proportionate approach
  • Contract conditions: apply NHS Standard Terms and Conditions which require suppliers to comply with relevant legislation

​​​​​​​​​​​​​​​​​​​​​Supply chain

To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain:

  • The Trust adheres to the National NHS Employment Checks / Standards (this includes employees UK address, right to work in the UK and suitable references)
  • The Trust has systems to encourage the reporting of concerns and the protection of whistleblowers
  • Other contracts are governed by standard NHS Terms and Conditions in which suppliers warrant that there is no slavery or human trafficking in its supply chains and they must notify the Trust if they become aware of any actual or suspected incidents of slavery or human trafficking in its supply chains
  • The Trust request all suppliers to comply with the provisions of the UK Modern Slavery Act (2015), through agreement of our ‘Supplier Code of Conduct’, purchase orders and tender specifications. All of which will set out our commitment to confirming there is no modern slavery or human trafficking related to Trust service provision
  • The Trust upholds professional codes of conduct and practice relating to procurement with the procurement sourcing staff required to be members of the Chartered Institute of Purchasing and Supply (CIPS) and MCIPS qualified

All procurement activities are in line with the NHS England Modern Slavery Statement and NHS Supply Chain Modern Slavery Statement.

NHS England » NHS England modern slavery and human trafficking statement

Modern Slavery Statement 2024

Staffing clinical and non-clinical

We continue to support all Trust staff to have knowledge commensurate with their roles in relation to modern slavery and human trafficking. Human trafficking and modern slavery are safeguarding related topics and staff awareness is raised when receiving safeguarding training together with access to additional resources being available on the modern slavery web page.

  • All clinical staff receive ‘All Age Safeguarding training’ and will therefore have awareness of modern slavery and how to raise a safeguarding referral if they had concerns. Modern slavery and human trafficking is a crime and every individual working in the NHS has a role in keeping present and potential future victims of modern slavery and human trafficking safe.
  • We ensure that all Trust staff have access to safeguarding training so that vulnerable victims are responded to appropriately.
  • We ensure the safeguarding procedures document includes up to date information on modern slavery and human trafficking.
  • We identify which contracts are at high or medium risk of modern slavery based on industry type, complexity of supply chain, the nature of the workforce, context in which the supplier operates, type of commodity and supplier location. Work with the suppliers on high and medium risk contracts to mitigate the risks through contract management.
  • Bank workers are recruited under the same requirements as substantive employees following safer recruitment processes. Agency staff are only recruited from agencies that are on approved NHSEI frameworks.

Effective action taken to address modern slavery – performance indicators

The Trust is committed to the protection of vulnerable people and has zero tolerance for modern slavery and human trafficking. Any identified concerns regarding modern slavery and human trafficking are escalated as part of the organisational safeguarding process.

All members of staff have a personal responsibility for the successful prevention of slavery and human trafficking with the procurement department taking responsibility for overall compliance.

Key Performance Indicators in order to support the Trust’s tolerance to address modern slavery:

  • Supplier compliance rate – this reflects the effectiveness of the hospital's efforts in ensuring ethical sourcing practices and combating modern slavery. A 100% compliance rate indicates a stronger commitment to human rights and labour standards throughout the supply chain
  • Staff training and awareness –this ensures our staff demonstrate an understanding of modern slavery risks, reporting procedures, and ethical sourcing practices following training sessions. All Trust staff have access to safeguarding training commensurate with their roles so that vulnerable victims are responded to appropriately. Training compliance is set at 85% as is the local ICB agreement
  • Annual review - The Trust reviews its Modern Slavery and Human Trafficking Statement on an annual basis and presents it at the Board of Directors.