Modern slavery and human trafficking statement

Steps we take to prevent modern slavery in our business and supply chains

Modern slavery is a heinous and often hidden crime, and the impact can be devastating for the victims. Modern slavery can be broadly grouped into four categories but is not limited to:

  • sexual exploitation: this includes sexual abuse, forced prostitution and the abuse of children for the production of child abuse images or videos
  • domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties
  • labour exploitation: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and retail businesses that reply on cash payments (for example nail bars and car washes)
  • criminal exploitation: this can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shoplifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker
  • other forms of exploitation include organ removal, forced begging fraud, marriage, and illegal adoption

Essex County Council (ECC) recognises its responsibility to take a robust approach to modern slavery and human trafficking. To demonstrate this ECC has conducted an Internal Audit on Modern Slavery to support a proactive approach to managing its Modern Slavery risk exposure. 

This annual statement sets out ECC’s actions to understand all potential modern slavery risks related to our activities and to put in place steps to eliminate acts of modern slavery and human trafficking within our business and in our supply chains, sub-contractors and partners. ECC is committed to preventing modern slavery and human trafficking in all its activities, and to ensure our supply chains are also free of this. 

The publication of this Annual Statement is part of that commitment and highlights our activities to address this. 

Organisation's structure

ECC governs the non metropolitan county of Essex in England.   At the time of the 2021 census, it served a population of 1,503,300, (excluding Southend and Thurrock) which makes it one of the largest local authorities in England. 

As a non-metropolitan county council, responsibilities are shared between districts (including boroughs) and in many areas also between civil parish (including town) councils. We provide county-wide services including:

  • schools
  • roads
  • children's social care
  • adult social care
  • Trading Standards
  • Youth Offending Service

Decisions about the way we run our services are taken by the 75 councillors that are elected every 4 years. The 75 councillors come from different political parties, and some have different roles in the decision-making process.

Our business


We have a number of policies and procedures in place that aim to ensure modern slavery does not occur in our business:

  • robust recruitment policy and process which are compliant with UK employment legislation, the process includes several pre-employment checks, for example 'right to work' document checks, referencing and understanding any employment gaps. DBS checks are undertaken for relevant posts
  • mandatory corporate governance training, (which includes the employee code of conduct, how we behave, and Equality and Diversity), defines the responsibilities and standards required for all who work for and on behalf of us including interims, agency workers and employees seconded to other organisations
  • whistle blowing: reporting knowledge or suspicion of modern slavery through our whistleblowing procedures and hotline which ensures that staff or members can raise their concerns confidentially without fear of reprisal. For those staff unable to raise their concern with anyone within the council they can contact Ethics Point, Ethics Point is an independent external whistleblowing provider that delivers our Speak up! service

Safeguarding vulnerable adults and children

We have responsibility to develop, implement and monitor policies and processes to safeguard the welfare of vulnerable adults and children and work within multi-agency partnerships to protect and safeguard people.

Staff awareness e-learning training for staff which supports the Modern Slavery Act, such as, Essex Social Care Academy (ESCA) – An Introduction to Modern Slavery and Human Trafficking, Child Trafficking and Slavery Human Trafficking, Modern Slavery Spotting the Signs and What you should Do Human Trafficking, is available to all of our staff.

In addition the Essex Safeguarding Children Board E-Learning exploitation training which covers both children and vulnerable adults. 


Procurement consists of three front facing teams, People, Place and Corporate. Across these teams the total value of all managed contracts is £7.2 billion with over 694 suppliers managed.

Procurement supply chains

Our procurement activity complies with the Council’s Procurement Rules and the wider Public Contract Regulations 2015.  To support our Category Management approach to minimise market risks concerning modern slavery within our large and complex supply chain, we have implemented a Modern Slavery Risk Assessment Tool.  Where the category is assessed as higher risk, we will consider whether a wider verification of modern slavery risks is required across the supplier base and whether further supply chain mapping is appropriate.  

To comply with the Modern Slavery Act 2015, we have:

  • updated our professional and technical ability tender questions within the procurement sourcing process. The questions require a bidder to evidence their compliance with the Modern Slavery Act if they are a relevant commercial organisation as defined by Section 54 of the Modern Slavery Act 2015. Any bidder who fails to evidence their compliance with the required legislation shall be excluded from participating further in the tender process
  • incorporated within our standard contract terms clauses that specify the Supplier’s contractual obligation concerning Modern Slavery
  • any supplier engaged by us to undertake the supply of goods and or services is contracted to do so in line with our following policies: Safeguarding, Equality and diversity code of conducts, Whistleblowing

These policies are key to ensuring that staff employed by our supply chain have appropriate channels to report any incidents of slavery and human trafficking.

We have recently reviewed and updated our contract management processes and guidance with a relaunch in April 23. 

The objective of the review was to identify approaches that would improve our processes to enable the identification and management of risks in relation to modern slavery and human trafficking. Possible ways of doing this could include: 

  • increasing openness, transparency and efficiency in the management of supply chains
  • improving ability to identify strengths, weaknesses, opportunities and threats in supply chains
  • improving communication with suppliers
  • enhancing relationships with suppliers

One such approach is to (if appropriate and proportionate) introduce annual audits on suppliers to ensure compliance with the contract agreement. A Contract Compliance Audit Template has been developed within our Contract Management Tool and is currently being tested with full roll out planned by Autumn 2023.  As part of the Contract Compliance Audit Process suppliers with an annual turnover of over £36m are requested to confirm that they have updated their Modern Slavery Statement within the last 12 months. Where feasible, and where justification for further investigation is identified, further audits can be completed. 

The outcome of this will inform how we can continue to review how modern slavery is incorporated into the contract management process. 

We have added to all relevant workflows a requirement for one contract management meeting per year to have an agenda item covering Modern slavery.   This can be used as an opportunity to remind suppliers of the actions they can take to seek to reduce the risk of Modern Slavery. 

The Modern Slavery agenda item should cover: 

  • whether the supplier has audited and risk assessed their own supply chain
  • if they have carried out these processes, what the main findings were
  • whether there are any areas of risk that we need to be aware of that the provider is looking into
  • if the provider has not carried out any of these steps, plans for when they intend to do so
  • whether there are updates from the supplier's Modern Slavery Statement that may impact on the contract

We are also exploring how we can capture information that will enable us to have effective oversight of modern slavery risks.  This could take the form of KPIs that might include the following: 

  • all suppliers confirming their adherence to the Modern Slavery act 2015
  • all relevant suppliers will need to evidence the publication of their Modern Slavery Statement
  • annual monitoring of modern slavery risks with suppliers and internal functions which informs gap analysis and reflective action log and programme
  • percentage of suppliers reporting that all their staff have completed modern slavery training


The Procurement Induction Pack given to all new members of the Procurement Team sign-posts staff to available training on The Modern Slavery and Human Trafficking Act 2015.  This has included the internal ESCA E-Learning and external training.  Going forward it is intended that training on Modern Slavery will be mandatory for all new team members, training options for non-procurement staff is being reviewed. Established members of the team are required to complete the CIPS Ethical Procurement Module on an annual basis.  A Procurement Training Playlist has been created which includes Modern Slavery and PREVENT Learning modules. 

Finding help

If you or someone you know is being or has been exploited or you are unsure if someone is in need of help, assistance and advice is available:

Further information

This statement will be reviewed on an annual basis, which will take place on or before 1 April 2024.

This statement will be also be published on the Government ‘Modern Slavery Statement Register’ which went live on the 6 May 2021.

This statement has been signed by Kevin Bentley Leader of the Council and Gavin Jones, Chief Executive Officer of Essex County Council.

Further information on modern slavery can be found on GOV.UK.