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Transparency in supply chains statement 2020/21

This statement sets out the steps taken during 2020/21 by Kent and Medway Fire and Rescue Authority and is published in accordance with section 54(1) of the Modern Slavery Act 2015 and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015.

Introduction

Kent and Medway Fire and Rescue Authority (the authority) is committed to respecting, protecting, and championing the human rights of all who come into contact with our service, including our employees, supply chain workers, customers and local communities. We have zero tolerance of modern slavery, and it is therefore totally unacceptable in our organisation and supply chains. We welcome the increasing momentum towards mandatory human-rights due diligence and are therefore fully committed to supporting the government tackle modern slavery, which is an important element of our approach to delivering our Service

We accept our responsibility to be more transparent; to find and resolve problems; to review our procurement practices regularly; and to collaborate with others to protect the rights of workers, particularly those who are most vulnerable to abuses such as modern slavery.

About the authority

Customer is at the heart of everything we do. Our customer promise sets out what everyone is entitled to expect from us:

Everyone at Kent Fire and Rescue Service works together as one team to keep the people of Kent and Medway safe. Our promise sets out our commitment to all our customers as we work with them to create a safer future for Kent and Medway:

  • To provide excellent services
  • To provide personalised and accessible services
  • To maintain your trust
  • To work with you and to keep improving.

We pride ourselves on the importance that we place on respect, equality, diversity and inclusivity in everything that we do. That's why it is so important to us that neither we, nor any of our suppliers ever knowingly take part in any form of modern slavery.

We are committed to acting ethically, with integrity and we're committed to putting effective processes and procedures in place to prevent any form of modern slavery taking place within our Service and supply chains. We're committed to making sure our Customers, our teams and employees of our suppliers are safe and treated fairly. We only intend on sourcing from suppliers who share this same commitment.

We have 1,550 members of our team across an estate of 55 stations, a training centre, control centre and service headquarters within the area of Kent and Medway. We also have around 50 volunteers available to support customers.

Despite the pandemic, our services remained accessible for all customers and we undertook over 10,000 safe and well visits over the last year.

COVID-19 pandemic

The COVID-19 pandemic has brought unprecedented challenges for the fire and rescue services in terms of provision of personal protective equipment consumables needed to protect our front-line and our customers against the deadly virus. We took the lead role in sourcing this for all public agencies in Kent and Medway, as well as nationally for all fire and rescue services. A key element of the due diligence undertaken when sourcing personal protective equipment has been transparency in terms of modern slavery risks and mitigations, and building resilience within trusted supply chains to ensure social protection systems are in place for all workers within a high risk market in terms of modern slavery challenges.

Working with our strategic supplier, offshore supply chain sourcing has been managed in terms of modern slavery through the following process:

  • Initial vetting of factory profiles -- ethical, environmental, financial, quality - vetting of all certifications in line with the Ethical Trading Initiative Base and the Modern Slavery Act.
  • On-site audit of factories against the data has been provided as a result of initial vetting undertaken by the supplier's offshore agents.
  • Ongoing surveillance both onsite and through reviewing documents they update via the supplier's offshore agents.

Our supplier's offshore agents have played a critical role in helping us maintain standards in regards to modern slavery during the pandemic due to limitations on British citizens travelling abroad. Best use has been made of modern technology, with video conferencing enabling us to live-stream at the factories to be able to review the working conditions ahead of any investment decisions.

We recognise our responsibility and influence as a public service dedicated to keeping our customers and communities safe and we therefore must ensure that the long-term impacts of the pandemic on the personal protective equipment /garment industry, which pose a threat to the protection of workers human rights, is monitored and mitigated.

Our sourcing map

Our average annual spend with third parties is £20m and we currently source a variety of goods and services from 28 countries worldwide.

List of countries we source goods and services from

  • United Kingdom
  • Austria
  • Bangladesh
  • Belgium
  • Brazil
  • Canada
  • Chile
  • China
  • Croatia
  • Czech Republic
  • France
  • Germany
  • Italy
  • North Macedonia
  • Morocco
  • Netherlands
  • New Zealand
  • Pakistan
  • Poland
  • Republic of Ireland
  • Romania
  • Slovakia
  • Spain
  • Sweden
  • Taiwan
  • Turkey
  • USA
  • Vietnam

Due diligence and assessment of suppliers

As part of our efforts to monitor and reduce the risk of slavery and human trafficking occurring within our supply chains we have enhanced our minimum requirements contained within our criteria of supplier assessment which form the core of our supplier selection process. We have started to adopt this approach for all our projects that source from high risk markets.

We now expect our suppliers to sign up to the Modern Slavery Assessment Tool, regardless of whether the supplier is a relevant organisation as defined by Section 54 of the act or not. We act reasonably and proportionately with our request to do so and will ensure that small and medium sized enterprises are not disadvantaged by our requirements, but are given support to help raise awareness.

This will enable our suppliers to have:

  • mapping and transparency on all parts of their supply chain;
  • identification of any risks within their supply base and strategies in place to mitigate this risk.

We also seek assurances regarding specific modern slavery training provided to staff within the organisation; require confirmation that workers receive all the necessary equipment, tools, any uniforms and personal protective equipment free of charge in order for them to perform their role; that their workers are aware of their rights to freely leave and seek other employment; demonstration of fair working practices; and to disclose any ongoing investigations or charges that they are aware of in relation to modern slavery or human rights abuses within their own organisation or throughout their supply chain(s).

Audit and risk assessment

The authority's approach to risk assessment comprises of both initial, and ongoing desk-based research, supply chain mapping, and auditing and stakeholder engagement. It is fair to say that, whilst we are mindful of the limitation of audit, working with our Tier 1 suppliers, it is a critical enabler in the discovery and management of modern slavery risks throughout our supply chains.

As we have gone further down our supply chains, we have also encountered challenges. This has included the time it takes to map supply chains several tiers down, and reluctance from entities further down the chain to undertake additional due diligence at the request of a customer several steps removed and where our purchasing power may be small.

Given the high risk, we have predominantly focussed on the clothing category to pilot our enhanced approach to due diligence, which includes personal protective equipment, uniforms, ceremonial wear and specialist personal protective equipment (for specific incidents such as wildfire and water rescue).

All of our Tier 1 suppliers have signed up to the tool, and have started to make incremental improvements on their initial score. One particular supplier is now conducting a bigger study within their supply chain and using the recommendations from the tool to assist them in their engagement with their supply chains.

All Tier 1 suppliers for this category have been engaged with in regards to looking at one item offered via our contracts in order to undertake a block-chain approach to establishing traceability of the item, which will track the final product back to source/raw material state. This will identify the processes or gates the product will go through in order to provide 100% transparency and identify areas of modern slavery risk.

Policies

We are committed to the highest standards of openness, honesty and accountability. As such, the following policies have been developed or updated in relation to slavery and human trafficking:

  • Modern slavery policy
  • Speak up policy

  • Transparency policy

  • Safeguarding policy:
    Guidance Document C27 -- How to raise a safeguarding concern.
    Guidance Document C28 -- Safeguarding Terms and Definitions.

  • Recruitment and selection policy

In the event that a modern slavery risk is identified, our Modern Slavery Policy provides links to comprehensive statutory guidance to ensure that the appropriate action is swiftly taken.

Learning and development

Our front line:

Our safeguarding Manager has undertaken 'Stop the Traffik' train the trainer training and has since successfully delivered this to all Safe and Well Officers, Building Safety Teams, Designated Safeguarding Officers and call handlers as well as Station Managers who will be attending Community Safety Unit meetings for their local area.

As the authority is not a first responder for safeguarding we have introduced a checklist for all designated safeguarding officers to use when dealing with calls from members of our teams requesting advice when they have concerns for modern slavery and trafficking. The purpose of this is to gather as much information as possible while crews or colleagues are at the incident so that we can share this information swiftly with our police partners as we are well aware that tracing people can be an incredibly difficult task once potential victims have been identified.

All of our teams:

Modern day slavery also features in the newly written safeguarding children and adults e-learning package which is now live and rolled out for all new starters and will be rolled out as refresher training.

Our intranet has a refreshed modern day slavery page where all members of our teams can find information on signs and symptoms and how to process and raise a safeguarding concern.

Commercial and procurement:

Our clothing and PPE category manager has attended the Chartered Institute of Procurement and Supply (CIPS) course on Modern Slavery in the Supply Chain. Sessions with the wider team to share learning and ideas have since taken place to maximise the training opportunity.

The team also participate in webinars to learn from keynote speakers regarding real-life modern slavery cases, along with local government sessions to share experiences and best practice across Government agencies.

Collaboration and stakeholder engagement

Partnerships are integral for the authority in addressing modern slavery risks. Key organisations and initiatives we partner with are:

Table showing organisations we partner with to address modern slavery risks
 Partner  Who  Issues/Areas of work  Working together
Stop the Traffik

 

Registered charity building a global picture of human trafficking hotspots and trends through information sharing and collaboration.

 

To build resilience into communities, and to encourage appropriate response and reporting.

 

Providing training  and support to KMFRA Safeguarding Manager

 

The Salvation Army

 

24/7 support

 

Modern Slavery Helpline available 24/7.

 

Support provided via the helpline if concerns are identified and further advice needed.

 

Gangmasters and Labour Abuse Authority

 

Non-Departmental Public Body set up to protect vulnerable and exploited workers.

 

Investigate reports of worker exploitation and illegal activity such as human trafficking, forced labour and illegal labour provision, as well as offences under the National Minimum Wage and Employment Agencies Acts.

 

Point of reference for knowledge, skills and experience in terms of all aspects of human rights abuse.

 

Police

 

Emergency services partner

 

First responders for modern slavery issues

 

Sharing of information if detected to help trace individuals.

 

Modern Day Slavery and Human Trafficking Co-ordinator provided training to our Designated Safeguarding Officers and Head of Commercial and Procurement

UK Fire and Rescue Services

 

Fire and Rescue Sector

 

Sharing of information and learning

 

Sharing of model template for Modern Slavery Policy for adoption sector-wide.

 

Proposal for 2021/22

We understand that the approach to modern slavery will require ongoing assessment of our service and supply chains - minimising the risk of its occurrence. We'll work towards reducing the risk within our business in the coming year. To do this, the aim is to address the following key areas and report progress in the next statement:

Learning and development - maintaining compliance while reviewing and making improvements to our learning materials

Risk mitigation - develop a modern slavery risk and incident management process for our commercial and procurement team. Once completed, training of the new agreed process shall be provided to relevant stakeholders. We shall also introduce specific modern slavery contract terms to our standard terms and conditions.

Audit compliance - continued improvements to our ethical audit programme compliance and monitoring

Learning and development

We'll continue to focus on making sure we raise awareness across everyone that works for us by rolling out our adult safeguarding e-learning, which includes content on modern slavery. This is mandatory for all new starters. Compliance is recorded using our learning management system. Learners are required to renew this learning every two years.

All of our teams:

Modern slavery to be included within the main areas of safeguarding training to be rolled out to all staff. Specific roles will determine whether members of our teams receive level 2, 3 or 4 training, i.e, call handler level 2, designated safeguarding officer level 4. This is evidenced in our safeguarding policy.

The training plan is scheduled to start October 2021 and will be reviewed annually.

Our front line:

Our safeguarding manager and education manager shall be attending the National Fire Chief Council's train the trainer session on fire service bespoke safeguarding. This shall then be rolled out to all relevant staff.

Commercial and procurement:

The entire commercial and procurement team shall undertake the CIPS Ethical Procurement and Supply E-Learning, and will also sign up to the CIPS Corporate Code of Ethics and Ethics statement, which means that we shall be listed on the CIPS Corporate Ethical Register and will observe the conditions of use of the CIPS Corporate Ethics Mark as defined in the CIPS Corporate Ethical Procurement. It is crucial that we can evidence our commitment to ethical practice, professionalism and accountability.

Continue to participate in webinars to expand our learning and exposure to actions taken and lessons learned from real-life cases found within supply chains.

Audit and risk assessment

We will continue to work on our approach to address the challenges that we have encountered with disclosure throughout our supply chains and will report transparently where we find them. We will engage in collaborative work to bring greater influence on challenging areas of our supply chains. We will also ensure that our Tier 1 suppliers arrange for site inspections of their supply chains, working to an agreed audit methodology that ensures assessment of modern slavery risks and takes into account the approach taken with our strategic partner during the pandemic.

Risk mitigation

We'll develop the modern slavery incident management process. We'll provide communications and engagement to all relevant stakeholders once the process receives approval and add appropriate references into the training plan.

We shall further enhance the obligations on our suppliers by introducing modern slavery compliance clauses in all of our standard terms and conditions. We shall warrant that when it comes to modern slavery, they take steps to investigate and identify issues relating to the Modern Slavery Act and will notify us immediately if they become aware of any issues within their supply chains.

We'll work with our Tier 1 suppliers to ensure that they are committed to providing training to workers and their local suppliers on modern slavery risks and compliance.

We will continue our work with our high risk Tier 1 suppliers to map their supply chains to understand where there the highest risk of slavery is.

Assessment of effectiveness

The next year will undoubtedly see a continuation of the many challenges as the impacts of COVID-19 are felt across many of our supply chains and communities. Transparency in our supply chains is a fundamental aspect of our approach to continuous improvement in our procurement practices and is something that we will continue to prioritise. With issues as complex and hidden as modern slavery, it becomes even more important to shine a light on the problem areas if we are to address them effectively. By working with our Tier 1 suppliers to map our supply chains and sharing information within our sector and beyond, we make it more likely that issues will be identified and addressed.

We are focussed on delivering our commitments to the protection of human rights, worker voice and empowerment. We will continue to assess, develop and extend our approach to modern slavery across all aspects of our service and we will continue to collaborate with our partners to reduce risks of modern slavery wherever they occur.

Signed

Nick Chard -- Chair -- Kent and Medway Fire and Rescue Authority

Ann Millington -- Chief Executive -- Kent Fire and Rescue Service

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