The Care Quality Commission (CQC) defines safeguarding as:
Protecting people’s health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect.
The Trust agrees with the CQC’s assertion that safeguarding is fundamental to high-quality health and social care. Our safeguarding policies strive to protect and promote the welfare of children, young people and young adults. Robust and effective practice is reliant upon a workforce which is knowledgeable, confident and equipped with the skills to deal with the fundamental process and procedures when concerns arise relating to patient safety. The Safeguarding Team is committed to embedding sound safeguarding systems, processes and practice for children, young people and adults, which are implemented across the Trust and has set key objectives to deliver a safe environment in which statutory functions and CQC requirements are met. Provision of expert advice, support and guidance in relation to safeguarding matters is available Trust-wide in addition to safeguarding training which is tailored to individual roles and responsibilities, facilitating a workforce which is aware of their safeguarding responsibilities and obligations. In addition they are developing closer working relationships with partner agencies and safeguarding boards within the county to improve understanding and delivery of the Trust’s role in joint operation of policies and statutory obligations. (CA 1989, CA 2004 sec 11).
We at The Dudley Group NHS Foundation Trust take our safeguarding responsibilities very seriously. We work closely with other agencies within Dudley and the Black Country to ensure a seamless, co-ordinated approach to both adults and children in our care, and to the children of adults in our care.
Modern slavery and Human Trafficking Statement 2023/2024
Modern slavery is the recruitment, movement, harbouring or receiving of children, women, or men using force, coercion, abuse of vulnerability, deception, or other means for the purpose of exploitation.
Individuals may be trafficked into, out of, or within the UK. They may be trafficked for several reasons, including sexual exploitation, forced labour, domestic servitude and organ harvesting.
Section 54 of the Modern Slavery Act (2015) requires all organisations to set out the steps it has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains, and in any part of its own business.
This statement sets out actions taken by The Dudley Group NHS Foundation Trust to minimise risks associated with modern slavery and human trafficking and demonstrate that the Trust has effective systems in place to prevent slavery and human trafficking.
Organisations, Structure and Business
The Dudley Group NHS Foundation Trust provides a comprehensive range of hospital and adult community services to the population of Dudley, Stourbridge and the surrounding towns and villages. Located in the heart of the Black Country area it covers a population of around 450,000 people in mainly urban areas. The Trust provides the full range of secondary care services and some specialist services for the wider populations of the Black Country and West Midlands region. The Trust also provides specialist adult community-based care in patients’ homes and in more than 40 centres in the Dudley Metropolitan Borough Council community, with services commissioned by The Black Country Integrated Care Board. We operate across three main sites these being Russell’s Hall hospital, Corbett Outpatient Centre, and Guest Outpatient Centre.
Working with suppliers and due diligence
The Trust acknowledges responsibility under the Modern Slavery Act (2015) and will ensure transparency within the organisation. The Trust has well established and robust procurement procedures and can provide assurances that suppliers operate to the same high ethical standards and code of conduct.
The Trust has previously written to all suppliers and advised them of our commitment to ensuring appropriate Modern Slavery practice, with all purchase orders directing suppliers to the Trust’s Supplier Code of Conduct which also reiterates this requirement. The Supplier Code of Conduct is available on the Trust’s website and the buyer profile for the Trust in the “Find It in The Black Country” system. Where the Trust advertises tenders directly, additional provisions are built into the Trust’s procurement and tendering processes to ensure Suppliers are compliant with the requirement of the Act.
The Trust procures approximately 60% of its procurement spend through national and regional framework agreements. Framework bodies have made the Modern Slavery Act (2015) a priority by requesting disclosure of statements from suppliers as well as issuing human trafficking policies that suppliers must comply with. For any arrangements that are advertised locally by the Procurement department in either Contracts Finder or the Official Journal of the European Union, there is a pass/fail question that asks potential suppliers whether they comply with the Act. Should any non-compliance be identified, this would be reviewed, and it is likely that the supplier would be removed from the process. Furthermore, for all other procurements and purchase orders the NHS Terms and Conditions of Contract are referenced, which include a section ensuring compliance with the Act. The Trust carry out annual internal audit on financial control as part of their audit plan. The audit includes a statutory compliance element which includes the modern slavery and human trafficking act requirements.
To identify and mitigate the risks of modern slavery and human trafficking in our own business, the Trust has established robust recruitment procedures, details of which are found in the Trust Employment Checks Policy.
The Trust recognises that all staff, in clinical or non-clinical roles, have a responsibility to consider issues regarding modern slavery and human trafficking, and to incorporate their understanding of these issues into their day-to-day activities.
Modern slavery is incorporated within the Trust’s Policy for Safeguarding Adults and the Trust Policy for Safeguarding Children. Information and guidance for staff encountering cases of modern slavery and/or human trafficking is also available on the Trust Safeguarding Hub pages. In addition, modern slavery and human trafficking is referenced within the Safeguarding Children and Adult mandatory training from Levels 1-3, which applies to all staff employed by the Trust.