Annual Report 2022

In 2018, Isle of Anglesey County Council committed to the Welsh Government's Code of Practice for Ethical Employment in Supply Chains.

We committed to continuously improving our practices to identify and eliminate any slavery in our business and supply chains.

We will act ethically and with integrity in all our business relationships. Isle of Anglesey County Council’s corporate safeguarding policy brings together key areas of safeguarding, mainstreaming the reporting of modern slavery and supporting victims within our safeguarding systems and processes.

Employees across the organisation have confirmed that they have read and accepted the policy.

What we have done

The last two years proved to be challenging, with the county council responding directly to the COVID-19 pandemic in partnership with other public services, employers and the community. The focus was on maintaining essential service provision, whilst protecting the health and well-being of citizens and the workforce. The impact, pressures, and challenges remained, despite the continued roll out of the vaccination programme.

Our whistle blowing policy empowers staff to raise concerns without fear reprisals or disadvantage. The policy also applies to contractors/agency staff. It also covers suppliers and those providing services under a contract to the council, which is delivered within the council’s own premises.

We have esured that 82% of our staff (who have access to e-learning) have completed the modern slavery module in order to increase their awareness and understanding of modern slavery and human rights abuses (including human trafficking).

We have played our part in regional and national anti-slavery agenda. We have a specialist healthy relationships officer, equipped with the skills and knowledge to safeguard children at risk and support their affected families.

Alongside our partners, who form the multi-agency exploitation panel, we have protected children and young people who are at risk or who are being harmed through sexual and criminal exploitation.

We have made referrals to the Nation Referral Mechanism(NRM) when appropriate ensuring that individuals receive appropriate support.

We have collaborated closely with relevant public agencies to ensure there was thorough planning, preparation, and deployment of new border control arrangements post Brexit.

We have provided guidance to support the application of safeguarding considerations within our procurement and contract management work.

During 2022 and 2023

We plan to:

• continue to build upon our commitments in our procurement and contract management strategy to ensure that ethical practices are mainstreamed in the procurement process and in the way we manage contracts
• provide training on the code of practice to relevant officers to improve their knowledge and practice in terms of ensuring that we are not employing, or using contractors who are not acting lawfully

Good practice examples

Social care

An annual due diligence exercise is undertaken. All newly tendered social care contract terms include requirements that the providers comply with the provisions of the National Minimum Wage Act 1998, the Modern Slavery Act 2015 and the Immigration, Asylum and Nationality Act 2006.

Contracts stipulate that subcontracting can only happen with prior agreement with us.  We are able to verify the suitability of the subcontracting arrangement.  

Contracts clearly states that providers must agree to work to the following legislative requirements, which help support the prevention of modern slavery.

• National Minimum Wage Act 1998 and Regulations 1999
• Working Time Regulations 1998 and 1999
• Public Interest Disclosure Act 1998 (Whistle Blowing)
• Part V Police Act 1997
• Employment Rights Act 1996
• Rehabilitation of Offenders Act 1984
• The Provision and Use of Work Equipment Regulations (1998) (ISBNO-7176-0414-4) are available from the Health and Safety Executive
• National Association for the Care and Resettlement of Offenders (NACRO) leaflet

Contract monitoring arrangements are in place to ensure compliance.

During any tender process, applicants are asked to describe how they would improve the economic, social and environmental well-being of the Isle of Anglesey and how the organisation would be working with community development and engagement. A narrative would be included to illustrate what sort of response we would expect and this would include a commitment to understanding and preventing modern slavery. 

Financial checks are undertaken and scrutinised. The applicant must provide a clear breakdown of submitted rate – this offers us some reassurances that staff receive a minimum wage, along with sick pay, holiday pay, pensions and so on. 

Housing services – Housing Support Grant Programme

During the procurement of these services applicants are expected to evidence:

• what steps they have taken taken or plan to take to tackle modern slavery and human rights abuses within the organisation and their supply chains
• that they are not subject to any ongoing investigations or charges in relation to modern slavery and/or human rights abuses
• that they provide training on modern slavery and human rights abuses for their staff involved in supply chain management
• safe workforce practice
• ensure that at their workers are aware of their rights
• all workers have the right to work in the UK
• al workers have employment contracts in place
• all workers paid in line with relevant national pay rates (these are the national minimum/living wage rates in the UK)

There are robust contract management and monitoring arrangements in place, including a comprehensive service review on a three-year basis. 

An annual due diligence exercise is undertaken.