Ministerial foreword
The UK government is committed to eradicating the crime of modern slavery both domestically and abroad. Since the publication of the first modern slavery statement in 2020, concerted action across government has ensured that risks of modern slavery in our supply chains are diligently identified and addressed.
In April 2022, the Health and Care Act 2022 came into force, introducing significant reforms in the administration and delivery of health and care services in England. Section 47 of the act mandates a comprehensive review by the Secretary of State for Health and Social Care to assess the potential risks of slavery and human trafficking within NHS supply chains.
This ensuing review, undertaken by NHS England and NHS Supply Chain Coordination Limited scrutinised 1,361 suppliers. It encompassed around 600,000 products, including approximately 30,000 cotton-based items.
This review marks an important step in our ongoing commitment to eradicate modern slavery from our healthcare system. A collaborative, multi-faceted approach is necessary, involving not just government departments but also healthcare providers, suppliers, and other stakeholders. The actions we take following this review will be instrumental in safeguarding the integrity of our health system and working towards eradicating exploitation and human rights abuses from our supply chains.
Furthermore, it is essential to foster a culture of awareness and responsibility across all sectors, not just within healthcare. This necessitates a broader engagement across the economy and wider society to amplify the message that modern slavery is an intolerable breach of human rights.
The findings and recommendations of this review provide a clear roadmap for action. As we move forward, our focus will be on implementing these recommendations robustly and effectively, while continuously seeking ways to strengthen our approach. The fight against modern slavery is a moral imperative, and it is one that the UK government remains steadfastly committed to.
Executive summary
An estimated 50 million people live in modern slavery across the world. Modern slavery exists in every country, including the UK, with instances of forced and child labour documented within the supply chain of the health and social care sector.
The Health and Care Act 2022 requires the Secretary of State for Health and Social Care, with the support of NHS England, to conduct a review of modern slavery risk in healthcare supply chains and propose legislation to eradicate the use of goods or services tainted by slavery or human trafficking. This report contains the outcomes of that review.
The review represents a snapshot in time, covering around 60% of the NHS spend on medical consumables procured through NHS Supply Chain at the supplier level. Risk ratings drawn from the government’s Modern Slavery Assessment Tool (MSAT), and international risk data reflects previous indications of risk, with 21% of suppliers identified as high risk, and surgical instruments, gloves, gowns, uniforms, and face masks identified as the 5 highest risk products. More significantly the review identified the limitations of the available risk data, the reliance on supplier submissions, the complexity of risk identification and the need to increase supply chain transparency.
Establishing regulation that sets out how to address the risk of modern slavery through the procurement process is needed to embed modern slavery due diligence in the procurement process. Implementation of the regulations should be supported by the development of NHS guidance. This will enable the NHS to use its extensive buying power more effectively to eradicate modern slavery. It is not presently possible to avoid high risk suppliers completely.
Improving modern slavery risk identification and management will require a standardised and consistent approach to minimise the burden on suppliers and NHS staff. Building risk assessment data into the health family’s e-commerce system will enhance due diligence practices throughout the procurement lifecycle. Supported by capacity building of both the supply chain and staff.
It is also important to recognise the wider benefits to the NHS of enhanced supply chain understanding, with the potential to improve the quality of products supplied and resilience of supply.
While the scope of the new regulations will be limited to healthcare supply chains, modern slavery exists in all government supply chains and the adoption of a cross government approach would optimise resources further.
Date: 4 January