The UK government is committed to eradicating the crime of modern slavery both domestically and abroad. Since the publication of the first modern slavery statement in 2020, concerted action across government has ensured that risks of modern slavery in our supply chains are diligently identified and addressed.
Under the Modern Slavery Act 2015, the UK became the first country to require organisations to publicly report on the steps they are taking to prevent modern slavery in their operations and supply chains.
The procurement policy note 02/23: tackling modern slavery in government supply chains (PPN 02/23) details the requirements that in-scope organisations of this PPN must take to ensure modern slavery risks are identified within their procurement activities, and how these risks should be managed in government supply chains. In-scope organisations of PPN 02/23 are central government departments, executive agencies, non-departmental public bodies and, notably, NHS bodies. The regulations and guidance have been drafted to align to the PPN 02/23.
It is the government’s view that the NHS has a significant role to play in combatting modern slavery through taking steps to ensure that NHS supply chains and business activities are free from ethical and labour standards abuses.
The Health and Care Act 2022 introduced 2 duties relating to modern slavery in supply chains within the health service.
The first, at section 47, required the Secretary of State to undertake a review of modern slavery in NHS supply chains. The report was presented to Parliament in December 2023, making the recommendation for the Secretary of State to continue implementing modern slavery regulations.
Section 81 of the Health and Care Act 2022 inserted section 12ZC into the National Health Service Act 2006 (the NHS Act 2006) for the Secretary of State for Health and Social Care to make such regulations as the Secretary of State thinks appropriate with a view to eradicating the use in the health service in England of goods or services that are tainted by slavery and human trafficking. The intention is that the regulations will impose broad legal duties in relation to modern slavery and procurement. For clarity, the regulations will only apply to public bodies conducting procurement activity in England.
These duties will be imposed on public bodies procuring goods or services for the purposes of the NHS, and they will sit alongside guidance, which will set out the detail of how the duties can best be complied with. Public bodies will have to have regard to any relevant guidance issued by NHS England in carrying out their duties under the regulations.
We are inviting public bodies, suppliers and interested members of the public to give us their views on the proposed regulations. The consultation is seeking views on a wide range of considerations including:
- how the regulations will be implemented
- the impact of the regulations on tackling modern slavery
- how frameworks and dynamic markets (as defined within the Procurement Act 2023) should assess and manage modern slavery risks
- how public bodies want to be supported to implement these new duties
The consultation period will close at 11:59pm on 13 February 2025. Please review the full consultation page, draft guidance and draft statutory instrument before completing this survey.
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