Modern slavery and human trafficking statement

Statement of commitment

The Health Services Safety Investigations Body (HSSIB) has a zero-tolerance approach to modern slavery and human trafficking and is committed to maintaining effective systems and controls to help prevent it from occurring within the organisation or its supply chains.

This statement comprises the slavery and human trafficking statement of HSSIB in accordance with Section 54 of the Modern Slavery Act 2015.

HSSIB is committed to acting ethically and with integrity in all its activities. We have a zero-tolerance approach to modern slavery and human trafficking and are committed to maintaining effective systems and controls to help prevent it from occurring within the organisation or its supply chains.

We recognise that modern slavery is a serious crime and a violation of fundamental human rights. It can take many forms, including slavery, servitude, forced or compulsory labour and human trafficking. We are committed to identifying and addressing the risks of modern slavery and promoting responsible and ethical business practices.

Organisational structure

HSSIB is an independent organisation that carries out patient safety investigations across England. Our investigations seek to improve patient safety by identifying opportunities for learning and making recommendations to reduce the risk of future harm.

We complete multiple investigations each year through a team of skilled investigators and support staff who bring experience from healthcare and other safety-critical industries, including aviation, law, military service and human factors.

Patient safety investigations

Our investigations aim to improve patient safety by:

• Supporting the involvement of patients, families and carers in healthcare.
• Supporting healthcare staff to carry out their roles and care for patients safely.
• Creating safer healthcare environments and processes.
• Making healthcare services more efficient.
• Sharing best practice and innovations in patient care.

Our patient safety investigations look at concerns across the NHS in England and in independent healthcare settings where safety learning could also help to improve NHS care. We can also be directed to investigate a patient safety concern by the Secretary of State for Health and Social Care.

We listen to people to understand patient safety concerns and experiences. These patient safety insights help us to decide what we investigate.

We do this in several ways:

• Direct contact with patients and families.
• Direct contact with NHS and healthcare staff.
• Access to patient safety incident reporting systems.
• Regular contact with national organisations.
• Regular contact with organisations that represent patients.

Governance and accountability

HSSIB is committed to ensuring that modern slavery considerations are embedded within our governance framework.

Responsibility for overseeing HSSIB's approach to preventing modern slavery rests with the Business Services Directorate, working with colleagues responsible for procurement, human resources, governance and compliance.

This statement is reviewed annually and supported by associated procurement, recruitment and speaking up arrangements. The statement is agreed by HSSIB's Board before publication.

Risk assessment

HSSIB considers the risk of modern slavery occurring within its directly employed workforce to be low due to the nature of our work, recruitment controls and employment practices.

However, we recognise that modern slavery risks may arise within the wider supply chains that support our operations. Potential areas of risk may include:

• Technology and digital supply chains.
• Outsourced professional services.

We continue to review our procurement and supplier management arrangements to identify, assess and mitigate potential risks associated with modern slavery.

Procurement and supply chains

HSSIB is committed to ensuring that modern slavery and human trafficking do not take place within our supply chains.

Our procurement activities include a Pre-Qualification Questionnaire (PQQ) which includes a mandatory exclusion question regarding the Modern Slavery Act 2015. Any suppliers who declare that they do not comply with the legislation will be excluded or disqualified from the procurement process.

When procuring goods and services, HSSIB applies NHS Terms and Conditions and relevant government procurement requirements, which require suppliers to comply with applicable legislation.

In addition, HSSIB has regard to relevant government guidance and procurement policy notices relating to tackling modern slavery in public sector supply chains. We expect suppliers, contractors and commercial partners to demonstrate the same high standards of ethical conduct that we apply within our own organisation.

Where appropriate, we seek assurance that suppliers have suitable policies, procedures and controls in place to prevent modern slavery and human trafficking.

Due diligence

HSSIB undertakes due diligence activities that are proportionate to the nature and scale of its operations. These activities include:

• Applying procurement controls during supplier selection processes.
• Using contractual terms that require compliance with relevant legislation.
• Verifying the identity and right-to-work status of employees and workers.
• Investigating concerns raised through established reporting channels.
• Reviewing relevant organisational policies and procedures on a regular basis.

We continue to consider opportunities to strengthen our due diligence arrangements and supplier oversight processes.

Recruitment

HSSIB takes a robust approach to recruitment and employment practices to help protect workers from exploitation.

We communicate directly with candidates throughout recruitment processes and confirm the details of all employment offers.

We have rigorous procedures in place for the vetting of new employees and workers and ensure that we are able to confirm their identity, their right to work in the United Kingdom and that they are paid above the National Living Wage directly into a personal bank account.

All employees and workers are required to meet with someone from HSSIB in person and provide us with their original Right to Work in the United Kingdom documentation for certification and verification. For any employee or worker with a work permit or visa, we carry out regular audits and management of these documents to ensure they remain valid. All new corporate starters are required to complete an induction which includes information and training on the company policies.

When using employment agencies, we work with reputable providers and seek assurance regarding their recruitment and employment practices.

Policies and reporting concerns

HSSIB maintains policies and procedures that support its commitment to preventing modern slavery and promoting ethical working practices.

Raising a Matter of Concern Policy

We encourage all our employees, workers, contractors and others working on behalf of HSSIB to raise concerns about any aspect of our operations or supply chains that could indicate the presence of modern slavery, human trafficking, exploitation or unethical working practices.

Our Raising a Matter of Concern Policy is designed to make it easy for employees and workers to make disclosures, without fear of retaliation. The policy encourages people to raise concerns directly with their line manager, if this is possible. Alternatively, other internal routes are available, such as contacting the HR team, as well as the senior leadership team, non-executive directors on the HSSIB Board and our Speaking Up Champion. The policy also contains contact details of external organisations should an employee wish to seek independent advice on a concern that they may have.

In addition, the HSSIB Guidance for Raising a Matter of Concern, the Health Assured Whistleblowing Helpline, the in-house Equality Diversity and Inclusion Working Group and the Freedom To Speak Up Champions scheme give platforms for employees to highlight and raise concerns regarding poor working practices.

Bribery and Fraud Policy

HSSIB recognises that weak governance, bribery and corruption can contribute to environments where exploitation and modern slavery may occur. Our Bribery and Fraud Policy sets clear expectations regarding ethical conduct and applies to employees and associated persons working on behalf of HSSIB.

Training and awareness

HSSIB promotes awareness of modern slavery through induction arrangements, policy communications and organisational learning.

Employees are made aware of:

• The signs and indicators of modern slavery.
• How concerns can be reported.
• The support available to individuals raising concerns.
• HSSIB's expectations regarding ethical conduct and compliance.

Additional awareness may be provided to colleagues involved in procurement, contract management, recruitment and governance activities where relevant.

Monitoring effectiveness

HSSIB is committed to monitoring the effectiveness of the measures it has in place to prevent modern slavery.

We assess our approach through:

• Annual review of this statement.
• Periodic review of relevant policies and procedures.
• Monitoring concerns raised through speaking up and whistleblowing mechanisms.
• Review of procurement and supplier assurance processes.
• Governance oversight and management review arrangements.

The organisation will continue to evaluate opportunities to strengthen its approach to identifying and mitigating modern slavery risks.

Continuous improvement

HSSIB recognises that tackling modern slavery requires ongoing vigilance and continuous improvement.

During the coming year, we will continue to:

• Review modern slavery risks within our supply chains.
• Maintain appropriate supplier due diligence arrangements.
• Promote awareness amongst employees and workers.
• Review relevant policies and governance arrangements.
• Update this statement annually to reflect developments in legislation, guidance and organisational practice.