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Modern Slavery Statement 2026

Audience: General public

Type: Human Resources

NHS Humber Health Partnership Modern Slavery Statement

1 April 2025 to 31 March 2026

1. Introduction

The Modern Slavery Act 2015 requires organisations to publish an annual Modern Slavery Statement on their website within six months of the end of the financial year (i.e., for the Trust this would require the statement to be published by 30 September).

With reports of modern slavery victims increasing year on year and an estimate of more than 130,000 people being trapped in modern slavery, costing the UK £33 billion per year, it is imperative that the Trust/Group continues to be committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

This statement sets out the steps that the Trust has taken over the financial year 1 April 2025 to 31 March 2026 to ensure that slavery and human trafficking is not taking place in any part of its business or supply chains and covers the following:

  • Organisational structure and business
  • Policies in relation to slavery and human trafficking
  • Due diligence and managing risks in the Trust’s business and supply chains
  • Training and performance indicators

2. Organisational Structure and Business

Northern Lincolnshire and Goole NHS Foundation Trust (NLaG) operate out of three hospital sites in Grimsby, Scunthorpe and Goole and one main community site in Scunthorpe. The Trust is one of the biggest employers in the region with nearly 8,000 members of staff. The Trust has an annual income of circa £559m.

Hull University Teaching Hospital NHS Trust (HUTH) is a large acute NHS Trust situated in Kingston upon Hull and the East Riding of Yorkshire. The Trust employs over 10,000 staff, has an annual income of circa £909m and has two main sites: Hull Royal Infirmary and Castle Hill Hospital. Outpatient services are also delivered from locations across the local health economy area.

Further details regarding the Trust’s business and structure can be found in the Annual Report and Accounts 2024/25, available on the Trust website.

  • Note the NLaG and HUTH Annual Reports for 2025/2026 are not currently available.

3. Policies in Relation to Slavery and Human Trafficking

The Group has several policies to support staff in relation to modern slavery, including:

  • Freedom to Speak Up Policy for the NHS
  • Group Conflict Resolution Policy
  • Domestic Abuse Guidance/Policy
  • Raising Concerns at Work Policy (HUTH)
  • Equality, Diversity and Inclusion in Employment Policy (HUTH)
  • Raising Concerns via:
    • Zero Tolerance to Racism Framework
    • Zero Tolerance to Ableism Framework
    • Zero Tolerance to LGBTQIA Discrimination Framework

The Trust publishes a broad range of safeguarding policies and factsheets, for both service users and staff, which include:

  • Safeguarding Adults Policies
  • Safeguarding Children Policies.

Any new campaigns/policies in relation to modern slavery are published on the Group intranet.

All Trust policies go through a robust consultation and ratification process and are available on the Group’s internal website.

4. Due Diligence Processes in the Trust’s Business and Supply Chains

Due Diligence in Business

The Group is committed to preventing slavery and human trafficking in corporate activities and ensuring that workers are not exploited, that they are safe and that relevant employment (working hours etc.), health and safety, human rights laws and international standards are adhered to.

To support staff, the following steps are taken:

  • All staff are employed on employment contracts which comply with UK law
  • Pre-employment checks are undertaken on all workers directly and non- directly employed by the Trust (e.g., employees, agency staff, contractors, volunteers, students, and trainees on work experience etc.)
  • All staff undertake mandatory safeguarding training, which covers modern slavery
  • As an equal opportunities’ employer the Trust is committed to creating an inclusive working environment for all staff, which enables staff to feel confident that they can raise concerns without any risk to themselves via several avenues, including a Freedom to Speak up Guardian.
  • A comprehensive range of modern slavery and safeguarding information for service users and staff is available for staff on the Trust intranet
  • All active agencies who supply staff to the Trust are asked to provide assurance that they are compliant with the Modern Slavery Act 2015 on an annual basis
  • Modern slavery is a term used that includes any form of human trafficking, slavery, servitude or forced labour, as set out in the Modern Slavery Act 2015
  • Modern slavery is widespread and can go unnoticed in our daily lives. Victims may face physical violence or coercion and may be forced into overwhelming debt. Additionally, they may have their passports taken away and be threatened with deportation. To safeguard against this, the Trust is constantly seeking ways to support and protect staff and service users from modern slavery and human trafficking. Some of the steps taken to achieve this include:
  • Participation in the Humber Modern Slavery Partnership (HMSP) Strategic Board, a network of over 60 organisations in the Humber region dedicated to preventing and combating modern slavery.
  • Participation in the North East Lincolnshire Modern Slavery Partnership, a local network aimed at raising awareness of modern slavery.
  • Incorporating modern slavery into mandatory safeguarding adults training.
  • Sharing knowledge and information, including providing access to training across the Trust through the intranet.
  • Monitoring the number of concerns raised to the Trust safeguarding adults’ team regarding exploitation and/or modern slavery. While these numbers are low, they show that staff understand of this aspect of safeguarding.
  • Collaborating with individuals to ensure that the principles of Making Safeguarding Personal are followed. Support and referrals should be consent-based and involve the person’s input.
  • Professionals should also consider child trafficking and the possibility of the child or young person being used in different forms of exploitation such as child sexual exploitation, fraud, forced marriage, criminal activity such as pick pocketing, cannabis cultivation or domestic servitude. The consequences of such involvement can have both short- and long-term consequences for the child, including guilt and confusion.
  • The safeguarding children team raise awareness of the issue of modern slavery, child criminal exploitation (CCE) and child sexual exploitation (CSE) in their safeguarding children training.
  • The safeguarding children team are active members at Multi Agency Child Exploitation (MACE) meetings and at National Referral Mechanism (NRM) meetings following completion of safeguarding referrals to Police and Children Social Care.

Due Diligence in Supply Chains

The Group contracts with suppliers through relevant procurement frameworks and is part of the Humber and North Yorkshire Procurement Collaborative (HNYPC) which is a shared collaborative procurement and logistics service. The HNYPC Modern Slavery Statement can be seen in Appendix 2.

The only local procurement activities which may fall outside of the HNYPC are the use of local providers by our estates department but they are working with the HNYPC to standardise approaches to all their procurement activities.

5. Training and Performance Indicators

Compliance with the Trust’s modern slavery agenda is measured by reviewing the number of staff who have completed the following mandatory courses/eLearning packages (which include modern slavery):

  • Safeguarding Adults
  • Safeguarding Children

As of June 2026, 89% of NLaG staff and 91% of HUTH staff are compliant with the required safeguarding training.

The Safeguarding training and advice:

  • Modern Slavery is included with the safeguarding adults and children training
  • The safeguarding adults and children’s teams are available Monday / Friday 9.00 – 5.00pm to offer advice, support, and information to staff if they have concerns about identification of modern slavery and how to make appropriate referrals to safeguard adults and children.
  • Gaining Respect and Finding Trust team) in children social care deliver bespoke training to wards and departments within the Trust which covers modern slavery, child criminal exploitation and child sexual exploitation.

6. Summary

The Trust continues to be committed to preventing modern slavery and human trafficking in any part of its business or supply chains. The Trust is committed to:

  • Continuing to educate staff on the importance of preventing modern slavery and to meet the obligations under the national modern slavery agenda
  • Monitoring and reviewing ongoing modern slavery legislation and best practice
  • Obtaining assurances from main suppliers/agencies etc. that they comply with the Modern Slavery Act 2015 and record and monitor these as required
  • Reviewing Trust policies and including references to modern slavery where appropriate.

Trust Board has considered and approved this statement and will continue to support the requirements of the legislation.


Appendix 2

Humber and North Yorkshire Procurement Collaborative Modern Slavery Statement

Foreword

Modern slavery remains one of the greatest challenges of our time. It can affect children and adults across the world and can exist within complex, multi-tier supply chains, including those used by public sector and healthcare organisations.

The supply chains within the health system are varied, complex and far reaching. It is not enough to state a zero-tolerance approach. HNYPC is committed to supporting the partner Trusts to identify, prevent and manage modern slavery and human trafficking risks through procurement, contracting and contract management activity.

This 2026 statement reflects the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025, NHS England guidance, PPN 009, and the updated HNYPC Procurement Policy. It introduces clearer risk rating criteria (low/medium/high), mandatory risk assessment before tender publication, formal record keeping on Atamis, enhanced contract management obligations (KPIs, audit rights, improvement plans), and defined escalation routes for modern slavery concerns. These changes ensure compliance with the new NHS Procurement Regulations and align HNYPC with national good practice.

HNYPC will continue to work with suppliers, framework providers and partner Trusts to apply a proportionate, risk-based approach to modern slavery risk. This includes clearer controls around risk assessment, due diligence, Atamis record keeping, contract management and escalation where concerns are identified.

This statement is our commitment to support the partner Trusts in taking reasonable and proportionate steps to reduce the risk of modern slavery and human trafficking in NHS procurement and supply chains.

Introduction

The Modern Slavery Act 2015 requires certain organisations to publish an annual Modern Slavery Statement setting out the steps taken during the financial year to prevent slavery and human trafficking in their own business and supply chains.

The National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 come into force on 17 May 2026. The Regulations apply to public bodies procuring goods or services for the purposes of the NHS in England and require modern slavery risk to be assessed and addressed through reasonable and proportionate steps.

The Humber & North Yorkshire Procurement Collaborative (HNYPC) is a shared collaborative procurement and logistics service supporting Hull University Teaching Hospitals NHS Trust, Northern Lincolnshire and Goole NHS Foundation Trust and York and Scarborough Teaching Hospitals NHS Foundation Trust.

HNYPC supports the partner Trusts with procurement, contracting and supply chain activity. HNYPC is not a separate statutory body in its own right; this statement therefore supports the partner Trusts’ wider assurance position and should be read alongside relevant partner Trust policies and procedures.

This is a Modern Slavery and Human Trafficking Statement. It is not a standalone policy. It is supported by the HNYPC Procurement Policy, including Section 18: Modern Slavery Act 2015 and NHS Modern Slavery Regulations 2025, and by relevant safeguarding, recruitment, whistleblowing, procurement, contract management and supplier management arrangements across the partner Trusts.

The three NHS Trust Chief Executives have overall accountability for this statement. This statement covers the period from 1 April 2026 to 31 March 2027 and sets out the forward controls HNYPC will apply from 2026/27 in light of the new NHS procurement requirements.

The statement covers the following:

    • Organisational structure, business and spend;
    • Policies and procedures in relation to slavery and human trafficking;
    • Risk assessment and due diligence in procurement and supply chains;
    • Procurement actions, contract management and Atamis record keeping;
    • Training and awareness raising;
    • Working with partners and framework providers;
    • Priorities for 2026/27.

    Structure, Business and Spend

    HNYPC is a shared collaborative procurement and logistics service supporting Hull University Teaching Hospitals NHS Trust, Northern Lincolnshire and Goole NHS Foundation Trust and York and Scarborough Teaching Hospitals NHS Foundation Trust.

    Collectively, the partner Trusts deliver a wide range of acute, community and specialist healthcare services across Humber and North Yorkshire. The Trusts employ thousands of staff and hold a significant portfolio of commercial contracts across clinical and non-clinical categories.

    The main categories of expenditure include medical and surgical consumables, medical and surgical equipment, estates and facilities, digital solutions, professional services and other goods and services required to support healthcare delivery. Some of these categories may carry increased modern slavery risk due to labour intensity, complex supply chains, manufacturing locations, subcontracting arrangements or known sector risks.

    Suppliers that meet the criteria under section 54 of the Modern Slavery Act 2015 are expected to publish their own modern slavery statements. Their own activities are not covered by this HNYPC statement, but their approach to modern slavery may be considered as part of proportionate supplier due diligence.

    HNYPC does not knowingly enter into business with any organisation, in the UK or abroad, which supports or is found to be involved in slavery, servitude, forced or compulsory labour, or human trafficking.

    What is Modern Slavery & Human Trafficking?

    Modern slavery can take many forms, including human trafficking, slavery, servitude, forced or compulsory labour, bonded labour, forced or servile marriage, descent-based slavery and domestic servitude.

    Modern slavery involves the recruitment, movement, harbouring or receiving of children, young people or adults through force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation. Any apparent consent is not relevant where a person has been coerced, deceived or exploited.

    In a procurement context, modern slavery risk may arise in direct suppliers, subcontractors, labour providers, manufacturing sites, logistics arrangements or lower tiers of the supply chain. The risk may be higher in categories that are labour intensive, low margin, geographically dispersed or dependent on complex international supply chains.

    Modern Slavery Policies

    The HNYPC Procurement Policy requires procurement activity to be undertaken in a way that supports transparency, equal treatment, non-discrimination, proportionality, value for money, public benefit, integrity and appropriate record keeping.

    Section 18 of the HNYPC Procurement Policy has been updated to reflect the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025, NHS England guidance on tackling modern slavery in NHS procurement and PPN 009: Tackling Modern Slavery in Government Supply Chains.

    The Procurement Policy requires modern slavery risk to be considered during procurement planning, supplier selection, evaluation, contract award and contract management. Identified risks, mitigations and contract management requirements must be recorded in the relevant procurement documentation and retained on Atamis as part of the procurement record.

    This statement should be read alongside relevant partner Trust policies and procedures, including safeguarding, recruitment, whistleblowing, standards of business conduct, procurement, contract management and supplier management arrangements.

    HNYPC uses standard NHS terms and conditions and relevant framework terms where appropriate. These include contractual obligations requiring suppliers to comply with applicable legislation, including requirements relating to modern slavery and human trafficking.

    Commitment

    HNYPC is committed to supporting the partner Trusts to identify, prevent and manage the risk of modern slavery and human trafficking in procurement activity, contracts and supply chains.

    By publishing this statement, HNYPC confirms its commitment to:

    • support compliance with the Modern Slavery Act 2015 and relevant NHS procurement requirements;
    • reflect the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 in procurement and contract management activity;
    • have regard to NHS England guidance and PPN 009 where applicable;
    • make suppliers aware of HNYPC’s expectations in relation to modern slavery and ethical supply chains;
    • apply a proportionate, risk-based approach to supplier due diligence and contract management;
    • record modern slavery risk assessment, decisions and mitigation on Atamis where relevant;
    • escalate concerns through senior procurement, governance, legal, safeguarding and/or contract management routes where appropriate.

    Risk Assessment and Due Diligence

    Modern slavery can affect virtually any industry or country. HNYPC will therefore target action where the risk of exploitation is most severe, salient and strategic, taking account of the nature of the goods or services, the sector, country of origin, supply chain complexity, labour intensity, subcontracting arrangements and any known risk intelligence.

    Modern slavery risk should be assessed on a proportionate basis and recorded as low, medium or high risk. Higher-risk procurements may require enhanced due diligence and additional contract management controls.

    The Procurement Lead or Category Manager responsible for the procurement is responsible for ensuring that modern slavery risk is considered and recorded at the appropriate stage of the procurement process.

    Where a risk is identified, the proposed mitigation must be proportionate and reflected in the relevant procurement documentation, including the Procurement Strategy, sourcing plan, Contract Award Recommendation Report, award report and/or contract management plan as appropriate.

    Due diligence may include supplier declarations, supplier self-assessment questionnaires, review of supplier modern slavery statements, supply chain mapping, review of policies and procedures, additional questions for higher-risk categories and contract management reporting or KPIs.

    Modern slavery risk should not be treated as a one-off procurement question. Where the risk profile requires it, the risk should continue to be monitored during contract management through review meetings, supplier reporting, evidence checks, audit rights, improvement plans or escalation where concerns are not addressed.

    Modern slavery risk should be reassessed where there is a material change in the contract or supply chain. This may include a change in supplier, subcontractor, country of origin, manufacturing location, sourcing model, product specification, service delivery model, contract scope or where new risk intelligence becomes available.

    Procurement Actions

    HNYPC will embed modern slavery considerations into procurement and contract
    management activity in line with the updated HNYPC Procurement Policy.

    A modern slavery risk assessment should normally be completed before publishing a tender notice or inviting suppliers to participate in a competitive procurement; before awarding a below-threshold contract where no tender notice is published; before establishing a framework agreement or dynamic market; and before using a framework, dynamic market or other route where HNYPC is responsible for the procurement decision and modern slavery risk remains relevant.

    Where modern slavery risk is identified, reasonable and proportionate steps may include:

    • supplier declarations and due diligence questions;
    • review of supplier modern slavery statements, policies and procedures;
    • supply chain mapping or additional information for higher-risk categories;
    • use of exclusion grounds where there is sufficient evidence of modern slavery or human trafficking offences;
    • inclusion of modern slavery obligations in tender documents and contract terms;
    • evaluation questions where relevant and proportionate to the subject matter of the contract;
    • contract management checks, KPIs or reporting obligations;
    • escalation to senior procurement, legal, safeguarding or governance colleagues where concerns are identified.

    A record of the modern slavery risk assessment, decision-making, mitigation and any contract management requirements must be retained on Atamis as part of the procurement record. This supports compliance with section 98 of the Procurement Act 2023, audit requirements and the partner Trusts’ wider governance responsbilities

    Where modern slavery concerns are identified before or after contract award, the matter must be escalated to the appropriate senior procurement, governance, legal, safeguarding and/or contract management colleagues. Depending on the nature and severity of the concern, action may include further supplier clarification, enhanced due diligence, a supplier improvement or remediation plan, additional monitoring, use of contractual remedies, suspension or termination where appropriate.

    Where relevant and proportionate, HNYPC will support the use of good practice tools, including risk mapping, supplier self-assessment questionnaires, supply chain mapping or tier visibility summaries, contract clauses, KPIs and annual reporting of key actions, risks, improvements and remediation outcomes through this statement.

    Training and Awareness Raising

    HNYPC will support relevant training and awareness for procurement, commercial and contract management staff so that modern slavery risks are identified, recorded and managed consistently across procurement activity.

    Relevant procurement staff are encouraged or required, depending on role, to complete appropriate ethical procurement training, including CIPS Ethical Procurement and Supply training and relevant Government Commercial Function or NHS training where applicable.

    The partner Trusts provide safeguarding training for staff, and modern slavery concerns should be escalated through established safeguarding, Freedom to Speak Up, whistleblowing and line management routes where relevant.

    HNYPC will continue to raise awareness of modern slavery risks through procurement guidance, policy updates, contract management conversations and proportionate support to procurement leads and contract managers.

    Working with our Partners

    HNYPC uses national and public sector framework agreements, including NHS Supply Chain arrangements, where appropriate. NHS Supply Chain operates a Supplier Code of Conduct and undertakes supplier assurance activity across its arrangements.

    Where a framework agreement, dynamic market or NHS Supply Chain route is used, procurement leads may take account of modern slavery due diligence undertaken by the framework owner or central purchasing body.

    However, use of a framework does not automatically remove the need to consider local risk, the nature of the goods or services, and any additional proportionate steps required. HNYPC must still consider whether the local requirement, supplier, product, service, supply chain or contract management arrangements create any additional modern slavery risk that requires local mitigation or recording.

    HNYPC will continue to work with NHS Supply Chain, Crown Commercial Service, regional procurement partners, framework providers and the partner Trusts to share intelligence, good practice and assurance in relation to modern slavery risk.

    Priorities for 2026/27

    HNYPC is committed to delivering the following priorities:

    • Align this statement with the updated HNYPC Procurement Policy and Section 18 modern slavery requirements;
    • Apply the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 in procurement and contract management activity where relevant;
    • Reflect NHS England guidance and PPN 009 in procurement documentation,
    • due diligence and contract management practice;
    • Record modern slavery risk assessments, decisions, mitigations and contract management requirements on Atamis where relevant;
    • Use low, medium and high risk rating to support proportionate due diligence;
    • Strengthen escalation routes for modern slavery concerns, including procurement, governance, legal, safeguarding and contract management input where appropriate;
    • Develop practical good practice tools, including risk mapping, supplier self-Assessment questions, contract clauses, KPIs and reporting prompts;
    • Review higher-risk categories and consider additional supplier due diligence where proportionate;
    • Support training and awareness for procurement and contract management staff;
    • Review and refresh this statement annually through the appropriate governance route.

    Publishing the Statement, Governance & Review

    The HNYPC Modern Slavery and Human Trafficking Statement will be published through the appropriate HNYPC or partner Trust route.

    The statement will be reviewed annually and updated to reflect changes in legislation, NHS England guidance, procurement policy and HNYPC governance arrangements.

    The three Trust Boards or appropriate governance routes will consider and approve the statement and continue to support the requirements of the legislation and relevant NHS procurement requirements.

    This statement should be read alongside the relevant partner Trust safeguarding, recruitment, procurement, whistleblowing, contract management and supplier management policies and procedures.

    Associated Documents

    This Statement should be read in conjunction with the following policies, procedures and guidance: