Agenda item


            The Committee considered the following report and approved the accompanying Modern Slavery Act Transparency Statement for 2020/21 and the suggested actions to be taken forward by Council Departments:


“1.0      Purpose of Report/Summary of Main Issues


1.1             The purpose of this report is to set out for Committee approval a corporate action plan to meet the obligations of the Modern Slavery Act, 2015, including the updating of the annual Transparency Statement.


2.0       Recommendations


2.1       The Committee is asked to:


                                                         i.          agree to the proposed actions based on the NILGA guidelines, which are to be taken forward by various Departments; and


                                                        ii.          approve the updated annual Transparency Statement.


3.0       Main Report


3.1       Background


3.1       The Modern Slavery Act 2015 aims to address slavery and trafficking by enhancing support and protection for victims, giving law enforcement the tools needed to target today’s slave drivers and ensuring perpetrators can be severely punished. It also includes a provision to encourage organisations to ensure their supply chains are slavery-free, known as the Transparency in Supply Chains arrangements (‘TISC’).


            Key Issues


3.2       The Council has voluntarily published an annual Modern Slavery Transparency in Supply Chains statement on our website since 2015. This sets out what an organisation has done to ensure there is no modern slavery in their supply chains or any part of their business. This year, the annual Transparency Statement has been significantly refreshed by Commercial and Procurement Services to reflect current guidance on its content and layout. An updated version for 20-21 is set out in Appendix 1 belowand will be published well before the deadline of October 21. Please note that due to business pressures in Governance and Compliance Services the update of last year’s statement was delayed.


3.3       In July 2018, the Home Secretary undertook an independent review of the MSA and made recommendations, one of which was to strengthen Section 54 by extending the requirement to publish Modern Slavery Statements to government and the public sector.


3.4       In July 2019, the UK Government launched a consultation on measures to strengthen the TISC arrangements, and recently published its proposals on how it plans to take this work forward. Many of the proposed changes will require legislative change which the UK Government hopes to take forward later in 2021. The proposed changes will see a strengthening of the TISC arrangements for commercial businesses, and will, for the first time, extend them so they apply to the public sector.


3.5       The Northern Ireland Department of Justice conducted a consultation exercise, which closed in May 2021, relating to the extension of the TISC arrangements to the public sector in Northern Ireland.


3.6       In accordance with Section 12 of the Human Trafficking and Exploitation (Criminal Justice and Support for Victims) Act (Northern Ireland) 2015, the Department of Justice publishes an annual Modern Slavery Strategy. The most recent Modern Slavery Strategy for 2019-2020 is the third strategy published by the Department of Justice and a consultation on the 2021/22 Modern Slavery Strategy recently took place. The purpose of the strategy is to raise awareness of modern slavery offences and so reduce the threat from, the vulnerability to, and the prevalence of, modern slavery in Northern Ireland.


3.7       In May 2020, NILGA published a guide for Councils with the Northern Ireland Strategic Migration Partnership (NISMP), (a multi-agency, cross-party and cross-departmental body working to reflect the regionally specific needs of Northern Ireland in the development and implementation of UK immigration policy).  The guide was also produced in partnership with the Department of Justice and the UK Independent Anti-Slavery Commissioner. It sets out some actions which councils can take to tackle modern slavery specifically:


1.      Provide Modern Slavery Awareness Training for all council personnel in public facing services (Lead: Corporate HR / Commercial and Procurement Services / Governance and Compliance Services);


2.     Designate a point of contact to report modern slavery concerns and raise awareness of modern slavery among communities (Lead: City and Neighbourhood Services);


3.      Establish clear procurement guidelines (Lead: Commercial and Procurement Services); and


4.      Collaborate with other councils and agencies (Lead: All Directors)


3.8       The suggested actions for councils are outlined in Appendix 2 below, which also includes a summary of the guidance from NILGA and a suggested lead within the Council for each action.




3.9       Governance and Compliance Services will co-ordinate an annual report on progress to be brought to committee.


            Financial and Resource Implications


3.10      This will involve staff from City and Neighbourhood Services, Legal Services, Governance and Compliance Services, Commercial and Procurement Services, Corporate HR and Marketing and Corporate Communications.


            Equality or Good Relations Implications/Rural Needs Assessment


1.11          Any equality, good relations or rural needs implications will be identified using the council’s usual screening process.”



Appendix 1


Modern Slavery Act Transparency Statement for the period

1st April, 2020 to 31st March, 2021




The Modern Slavery Act 2015 (the “Act”) places specific responsibilities on organisations to ensure slavery and human trafficking does not exist within their supply chains, and in any part of their own businesses.  Organisations need to demonstrate accountability through transparency to protect workers, adults and children from abuse and exploitation.


The Council is committed to improving practices to prevent slavery and human trafficking.  The Council expects suppliers, partners and third parties to adhere to the same values and principles to combat slavery and human trafficking.


This statement is made pursuant to section 54(1) of the Act and constitutes Belfast City Council’s slavery and human trafficking statement for the financial year ending 31st March 2021.


Our structure and our supply chains


The Council is the local authority for the Belfast area with responsibility for a wide range of services including local planning, economic development, tourism, street cleaning and parks, leisure and waste management.


The Belfast Agenda is the community plan that the whole city is working towards.  Our vision is that by 2035 Belfast will be a city

·        Where everyone benefits from a thriving and prosperous economy

·        That is welcoming, safe, fair and inclusive for all

·        That is vibrant, attractive, connected and environmentally sustainable

·        Where everyone experiences good health and wellbeing and

·        Where everyone fulfils their potential


Our political governance structure is set out below:



The Council procured goods, works and services from circa 2,400 suppliers during the last financial year with a supply chain mostly based in the UK and Ireland.


The Council has a responsibility to prevent slavery and human trafficking within its supply chain and in any part of the organisation. As the customer, the Council makes clear to our suppliers, and those wishing to do business with us, what is expected of them.


The Council’s tender process require all tenderers to provide confirmation that they are compliant with the Act. They are also required to confirm their subcontractors and suppliers comply with the Act.


Our policies in relation to slavery and human trafficking


The Council has the following policies or procedures in place, related to mitigating the risks of slavery and human trafficking:




We recognise our responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and vulnerable adults.  Our child safeguarding procedures are well established; our current focus is on underpinning how we take care of adults and the reporting system.


Equality and Diversity


We are committed to Equality and Diversity and actively seek to eradicate discrimination and inequality when developing services and when goods and or services are provided on the Council’s behalf.  To this end we have developed an internal toolkit which integrates equality and diversity into everything we do from policy development to service planning and delivery.


We are an Equal Opportunities employer and welcome applications from all sections of the community.   We are a Lead Partner and Member of Excellence of Employers for Disability NI with members of our recruitment team being accredited as “Disability Positive”.  We have a dedicated helpline for any applicants who require reasonable adjustments or whose first language is not English.  We appoint strictly on the merit principle and our recruitment processes require the completion of relevant pre-employment checks which include eligibility to work in the UK and the uptake of suitable references, where required.

We operate a job evaluation scheme to ensure all employees are paid fairly and equitably.


Raising Concerns


We encourage workers to raise any concerns that they may have and there are established arrangements in place for handling these.  Externally, members of the public and customers can use our Corporate Complaints Compliments and Comments procedure to report concerns.


Fraud and Bribery

We are committed to protecting the public money we look after and to making sure that the opportunity for fraud, bribery or any other financial impropriety is reduced to the lowest possible risk.  We have policies and procedures to manage the risk of fraud, bribery and other financial impropriety, including arrangements for prevention and detection as well as arrangements for reporting and investigation.


Code of Conduct


We expect all employees and Councillors to demonstrate the highest standards of conduct and ethical behaviour. We require all Councillors and Senior Managers to submit declaration of interests to record and declare personal and pecuniary interests.


Due diligence in assessing modern slavery risk in operations or supply chains


The Council’s Commercial and Procurement Services team have recently introduced Category Management. A Category Management structure within the team enables greater transparency in the identification of risks associated with modern slavery on a category basis.


Risk Assessment and Management


All new suppliers, for new or extended applicable contracts, are assessed as part of the Council’s tendering process to ensure that they meet the requirements of the Act.


We commit to reviewing and updating our contract terms and conditions to ensure that they are compliant with the Act.


The Commercial and Procurement Services team completed CIPS Ethical Procurement training achieving the professional standard of CIPS Corporate Ethics kite mark for the service.


We commit to developing a new safeguarding policy that will go out for consultation in 2021.


Key performance indicators to measure effectiveness of steps being taken


We will communicate this policy to our staff to make them aware of the issue and the Council’s obligations.


The Northern Ireland Department of Justice is expected, at some point, to announce guidance on the new duty to report incidences of modern slavery. This may require further training and guidance being issued to staff.


Training on modern slavery and trafficking


The Commercial and Procurement Services team commit to retaining the professional standard of CIPS Corporate Ethics during 2021.  Further Council officers involved in procurement activity will also be selected for this training.


This statement was approved by the Corporate Management Team of Belfast City Council on 31st August, 2021.


Signed on behalf of Belfast City Council by:




John Walsh

City Solicitor and Director of Legal and Civic Services



Appendix 2





NILGA Guidance

Suggested Lead

Estimated deadline

1.     Provide Modern Slavery Awareness Training for all council personnel in public facing services.





·        The Department of Justice and the Department of Finance’s Construction and Procurement Delivery can advise on TISC (Transparency in Supply Chains) training for public sector and council procurement leads.


·        The guidance provides a list of voluntary and community sector organisations which can advise on modern slavery and provide training.


NILGA’s suggested next steps for Councils:

·        Deliver training for public sector procurement leads in respect of transparency in supply chains.

·        Accessing “Train the trainer” sessions for Councils shared by the Department of Justice to provide Councils with the tools to deliver their own inhouse training on Modern Slavery. (The Train the Trainers session will be built into NILGA’s Regional Training Programme and further information will follow on an ongoing basis as appropriate).


·        Using Training Materials for Council Staff, available from the Department of Justice and PSNI. (In April 2019, the Department of Justice and the PSNI wrote to all local Councils CEOs to offer training materials for staff on modern slavery concerns15.)














Commercial and Procurement Services –

N Bohill






Corporate HR – C Sheridan / Governance and Compliance Services –

S Williams





External provider to deliver approved training.

March 2023

2.     Designate a point of contact to report modern slavery concerns and raise awareness of modern slavery among communities.


Councils should designate a lead officer or team who can act as a point of contact and expertise on the issue. Council Community Planning, Good Relations or Policing and Community Partnerships (PCSP) teams are ideally placed to fulfil this role. A Lead Officer from either one of these teams could be nominated as the “go to” person for other officers or council workers who have concerns that modern slavery may be happening in certain businesses or in the community.


·        A council protocol for reporting suspicions of modern slavery should be developed.


·        Community Planning Partnerships should be harnessed to share information and to raise awareness of modern slavery with communities and the drive to eradicate it.


·        PCSPsare a key council resource in the drive to eradicate modern slavery in Northern Ireland. Intelligence which can be disclosed by the PCSP should be shared with the lead person / team in the council appointed as the “go to” for modern slavery concerns.



City and Neighbourhood Services –

 R Black


Nicola Lane to take the lead on this element of the action plan and act as the conduit in terms of Good Relations and PCSP. 


To be agreed, at the relevant time, how we will embed / promote through the Community Planning Structures, SCP and PCSP/DPCSP’s.



March 2023

3.     Establish clear procurement guidelines




The modern slavery transparency statement required to be published by the Council under Section 54 of the MSA must include the steps the Council has taken during the financial year 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 or; that the organisation has taken no steps in the financial year.


·        Transparency in supply chains is a process of continuous improvement. As stipulated in government guidance, the government expects organisations to build on their statements year on year


·        Guidance and resources include: Transparency in Supply Chains etc. A practical guide; Council Transparency Statements Portal; TISCReport Transparency Map; LGA’s Tackling Modern Slavery Guide


NILGA’s suggested next steps for Councils:


·        Taking account of any further government developments on proposals to extend the scope of Section 54 (TISC).


Commercial and Procurement Services –

N Bohill











4.     Collaborate with other councils and agencies

Opportunities for collaboration include:


·        All-Council Professional Officers Groups (e.g. the Environmental Health Professional Officers Group, the Local Government Safeguarding Network and the Planning Professional Officers Group);



·        Cross-council project collaboration (e.g. arc21); and



·        Council collaboration with the private sector: e.g. for Economic Development teams to provide guidance to new and existing businesses in their districts on developing modern slavery transparency statements to enhance their competitiveness when bidding for new, or when renewing goods / services contracts.



All Directors to raise with relevant officers



Supporting documents: