Modern Slavery Transparency Statement (Financial year: 2025/2026)

1. Introduction

Great Yarmouth Borough Council (the Council) is committed to preventing modern slavery and human trafficking in all its operations and supply chains. This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and outlines the steps taken to identify, prevent, and address risks of slavery and trafficking.

The Council recognises that it has a responsibility to take a robust approach to slavery and human trafficking. In addition to the Council's responsibility as an employer, it acknowledges its duty as a Council to notify the Secretary of State of suspected victims of slavery or human trafficking as introduced by section 52 of the Modern Slavery Act 2015. In doing so the Council works in close partnership with the Police and Voluntary, Community, Faith and Social Enterprise (VCFSE) partner organisations.

The Council is absolutely committed to preventing slavery and human trafficking in its corporate activities and to ensure that its supply chains are free from slavery and human trafficking. The following are practices in place in relation to the introduction of the Modern Slavery Act.

2. Corporate Plan

Our Corporate Plan promotes safer, stronger communities and prioritises protecting vulnerable individuals. Responsibility for modern slavery compliance sits with the Executive Leadership Team, supported by HR, Procurement, and Safeguarding Leads.

The Council's Corporate Plan states its aim to support and develop the people it employs, growing their knowledge and skills, now and for the future. Specific aims include:

...to continue to develop our partnership approach to early intervention and preventative services to support our most vulnerable residents including preventing homelessness.

and 

...to maintain a capable and competent workforce with structured career and succession planning, aimed at retaining employees and enhancing our reputation as an employer of choice.

Great Yarmouth Borough Council is part of the Great Yarmouth Health and Wellbeing Partnership (HWP) working in collaboration with statutory agencies, non-statutory partner organisations and community VCFSE partners in the borough. The HWP's Great Yarmouth Locality Strategy sets out the four overarching priorities of the HWP's work which includes Tackling Vulnerability and Exploitation:

 ... [To] increase awareness within our communities of issues and risks to aid early detection and gain trust through seeing, listening, hearing and working with communities to ensure support for direct action.

3. Organisational Structure and Supply Chains

The Council provides a wide range of services to residents and businesses, including housing, waste management, leisure, and community safety. We procure goods, works, and services from external suppliers. We recognise that certain areas of our work - such as agency staffing, construction, and contracted services - present higher risk.

4. Policies and Procedures

The Council reviews its policies on a regular basis with input from customers, employees, managers, trade unions, management team, and elected members. This ensures the Council's policies and procedures remain compliant and fit for purpose. The following policies and procedures are key in meeting the requirements of the Modern Slavery Act:

• Procurement and Commissioning Strategy - includes modern slavery clauses and risk assessments for suppliers
• Employee Code of Conduct - sets ethical standards for staff behaviour
• Recruitment Policy - robust identity checks, right-to-work verification, and direct payment to personal accounts
• Agency Worker Controls - engagement only with reputable, vetted agencies
• Whistleblowing policy - confidential reporting channels for concerns
• Safeguarding Policy - protects children and adults at risk, with clear referral procedures and multi-agency working

5. Employee and Elected Members' Code of Conduct

The Council's employee Code of Conduct, as set out in Article 45 of the Constitution, our Values and Behaviours and Member Code of Conduct make clear to employees and elected members the actions and behaviours expected of them when representing the Council. The Council strives to maintain the highest standards of employee conduct and ethical behaviour.

6. Recruitment and Use of Agency Workers

The Council's safeguarding policies and recruitment processes are transparent and reviewed regularly. These include robust procedures in place for the vetting of new employees and ensures they are able to confirm their identities, and they are paid directly into an appropriate, personal bank account. The Council uses only reputable employment agencies to source labour and verifies the practices of any new agency it is using before accepting workers from that agency.

7. Whistleblowing

The Council encourages all its employees, customers and other business partners to report any concerns related to the direct activities or the supply chains of the Council. The Council's whistleblowing procedure is designed to make it easy for employees to make disclosures, without fear of retaliation.

8. Safeguarding Integration

Our safeguarding approach is person-centred and aligned with Norfolk Safeguarding Adults Board and Norfolk Safeguarding Children Partnership. Key measures include:

• Designated Safeguarding Lead for oversight
• mandatory safeguarding training for staff and elected members (Councillors)
• clear referral routes for suspected abuse, neglect, exploitation, or trafficking
• partnership working with police, health, and voluntary sector organisations

The Council embraces its responsibility to develop, implement and monitor policies and procedures to safeguard the welfare of children and vulnerable adults and protect them from harm.

9. Training and Awareness

All staff receive safeguarding training, which includes recognising signs of exploitation. Additional modern slavery and human trafficking awareness training is being rolled out for high-risk service areas (e.g., housing, procurement). Internal communications and workshops raise awareness across departments.

10. Actions Taken in 2025/26

• reviewed procurement templates to include modern slavery clauses
• delivered safeguarding and exploitation awareness sessions to frontline staff
• strengthened whistleblowing procedures and promoted reporting routes
• engaged with regional anti-slavery networks to share best practice

11. Commitments for 2026/27

• enhance supplier due diligence and contract monitoring
• expand modern slavery training to all staff and elected members
• introduce risk-based supplier assessments using national tools
• increase awareness through internal campaigns and external partnerships
• continue annual reviews to ensure continuous improvement

12. Monitoring and Review

This statement has been approved by the Executive Leadership Team and will be reviewed annually. It will be published on the Council's website in accordance with statutory requirements.