Modern Slavery Statement 2025-26

This Modern Slavery Statement is made in response to the requirements of Section 54 of the Modern Slavery Act 2015 (the Act).

“Modern slavery” refers to the exploitation of individuals for personal or commercial gain. It can take many forms including trafficking of people, sexual exploitation, forced labour, and servitude.

The City of Bradford Metropolitan District Council’s ethos disallows modern slavery in all forms and is committed to implementing processes to prevent and eradicate it. We are committed to working transparently, collaboratively, and responsibly with our partners and suppliers to promote fair treatment, protect vulnerable people, and ensure ethical and lawful practices throughout all areas of our activity.

This statement covers the financial year 2025-26 and addresses what measures we have in place to reduce the risk of modern slavery taking place in our supply chains and what improvements can be made to monitor the Council’s suppliers and supply chains.

Organisational structure, business and supply chains

The City of Bradford Metropolitan District Council delivers a wide range of essential public services covering areas such as public health, adult social care, highways and waste, parks and neighbourhoods and procurement of goods and services. These services, and others, support residents across the district, particularly the most vulnerable and possibly at risk. From safeguarding children and adults, preventing homelessness, supporting employment and skills, and maintaining safe, healthy communities, our work places us in a position of trust and responsibility.

We take our responsibility to protect vulnerable people seriously and are committed to preventing modern slavery and human trafficking. In accordance with the Modern Slavery Act 2015, the Council will notify the Secretary of State where there are reasonable grounds to suspect an individual may be a victim of slavery or human trafficking.

Modern Slavery Policies

The Council has a range of organisational policies and practices in place to prevent, identify and respond to modern slavery risks within its operations and supply chains. We have robust employment policies ensuring employees are treated fairly and protected from exploitation.

All staff receive a written contract and statement of terms and conditions and have the right to join trade unions and staff networks. In our recruitment process right to work checks are carried out and when contracted suppliers are used, they are compelled to comply with anti-slavery and human trafficking legislation.

Employee Code of Conduct

Internal Council policies provide expectation for employees to act in accordance with the high standards of behaviour set out in the Employee Code of Conduct. All employees are expected to apply the Council’s Values to all aspects of their behaviour and conduct at work. All employees are expected to comply with the law relating to their work and general conduct. Any breaches of the Code of Conduct or other rules will be investigated and action taken as necessary.

Whistleblowing

The Council is committed to the highest standards of openness, probity and accountability. All employees, Elected Members, agency staff, volunteers, and contractors working for the Council who are concerned about modern slavery in the Council can access the Council’s Whistleblowing Procedure. Members of staff who raise concerns, based on a reasonable belief, under the Whistleblowing Procedure will be protected from dismissal, victimisation or detriment because they have made a disclosure. Council employees also have access to one of our recognised trade
unions to report any concerns.

Safeguarding Adults Policies and Procedures

The Council’s Adult Social Care services use this as their core safeguarding policy and includes any safeguarding responses to modern slavery identified within the Council as per responsibilities set out under the Care Act (2014).

Management of Risk

During the 2024-2025 financial year, the Council contracted with 12308 suppliers, the majority from within the EU, with a total spend of ~£1.26bn (£1,256,793,641.80). The Council exercises a meticulous practice of due diligence to ensure each supplier we enter business with of these sectors is of the standard the Council expects.

High risk areas in the Council’s supply chain, where people could fall prey to Modern
Slavery include:

• Low wage, often part-time, term-time, or seasonal service contracts such as:
• • Cleaners, caterers, refuse workers and other such facilities workers
  • Customer service workers
  • Security guards
  • Gardeners
  • Care, such as ASN, SEN, and social health care workers
• Construction
• Areas where there is often forced/child labour overseas, including:
• • Textiles
  • IT and electronic equipment
  • Goods using minerals that are mined in areas of conflict

As of 2022, procurers and contract management officers within the Corporate Procurement Service undertake training annually to understand the impact of modern slavery through the Chartered Institute of Procurement and Supply (CIPS)’s online course on Ethical Procurement and Supply. Additionally, all Officers managing contracts at the Council must undertake the Government Commercial College assessment in Contract Management Fundamentals course, which includes
elements of ethical awareness.

Due Diligence and Management of Risk in Procurement Activities Contracts are awarded in accordance with the Council’s specific requirements in adherence to the Equality Objectives and Equality Plan, Health and Safety at Work Plan, and departmental risk management policies. Bidders are strictly required to adhere to the Council’s outlined requirements with regards insurance and GDPR policies. Without such ability to complete the mandatory questionnaire, the Bidder cannot proceed.

The Procurement Service has expanded their initial pre-contract documents to include questions wherein prospective suppliers answer questions relating to their supply chains and how susceptible they are to the direct or indirect effects of modern slavery. They are provided the opportunity to evidence the due diligence processes they will or have adopted to prevent it. This is included within the questions in tenders for all, not only those considered high-risk categories.

Commitments for 2025-26

Research

The Council will conduct research on the high-risk supply chain areas identified above and design a comprehensive plan. This plan will concentrate on how we will engage with key suppliers going forwards, with aim to learning what their current action plan is to eliminate modern slavery in their sub-contracts.

The Council will also consider how due diligence can be continued throughout the contract as part of good contract management, not just as part of a tendering process. With regards the current terms and conditions of contract, The Procurement Service will revisit these pre-existing terms, amending where necessary, thereby ensuring that modern slavery is appropriately covered.

The Council will ensure compliance with the Government guidance with regards transparency in supply chains. This requires the Council’s Procurement Service to act with due diligence when reviewing both prospective and existing suppliers. The Government outlines the following specifications for suppliers to provide annual statements regarding efforts to abolish modern slavery within their supply chains:

• are a body corporate or a partnership (described as an “organisation” in this
  document), wherever incorporated
• carry on a business, or part of a business, in the United Kingdom
• supply goods or services
•  have an annual turnover of £36 million or more

In accordance with section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015, it is a requirement for all organisations within the above criterion. Organisations whose annual statements fail to meet the Council’s standards for business will be subject to further review. Such measures will also allot for the Council to review their own internal practices and open discussion for further improvement to its current standards for future contractors.

Future Considerations

The Council will explore how best to train staff on all aspects of Modern Slavery, including whether it should be carried out internally or by an external specialist organisation.

Monitoring and Review

The Council will need to consider how to monitor and audit suppliers / contractors in
the high-risk categories above in the longer term.

Training

The Council will plan to provide an online e-learning module on modern slavery and human trafficking, which would be made available to all staff to provide a level of awareness regarding modern slavery.

Publishing an Annual Modern Slavery Statement

In accordance with section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015, the Council will publish an Annual Modern Slavery statement. This will ensure absolute transparency with regards:

1. Organisation structure and supply chains
2. Policies in relation to slavery and human trafficking
3. Due diligence processes
4. Risk assessment and management
5. Key performance indicators to measure effectiveness of steps being taken
6. Training on modern slavery and trafficking

The Council will endeavour to publish its annual statements going forwards and will provide a copy of the statement in writing to any organisation or individual who requests one within 30 calendar days of receiving the request.

Signed for and on behalf of City of Bradford Metropolitan District Council

Name: Dr Lorraine O’Donnell

Position: Chief Executive

Date: 29, January 2026