Modern Slavery Statement for the financial year ending 2025 to 2026

Introduction

Surrey County Council remains committed to ensuring that public money is spent responsibly and our activities and those working on behalf of the authority are conducted in an ethical, responsible and sustainable manner.

Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 requires certain organisations to publish an annual modern slavery statement outlining the actions taken each year to tackle modern slavery risks within their operations and supply chains. While not required by the transparency provision to publish a statement, Surrey County Council recognises the important role the public sector must play in helping to address this critical issue and has voluntarily chosen to report on our activities. This is the Council’s 2025/2026 statement. The structure and content of the statement remain the same as our previous statement, with sections updated to reflect key activities undertaken during the 2025/2026 financial year.

Modern slavery is a heinous crime, with an estimated 50 million victims worldwide and over 100,000 here in the UK. As a local authority, we recognise that we have several roles to play to help address this problem. This includes safeguarding vulnerable adults and children from exploitation and harm, identifying potential victims in our role as first responders, and working to implement measures that protect workers in our operations and supply chains from modern slavery and other unethical labour practices.

As part of the Council’s Organisation Strategy for 2023 to 2028, we are committed to fostering a sustainable economy that benefits everyone, tackling health inequalities, enabling a greener future and nurturing empowered and thriving communities. Our Community Vision for Surrey outlines the aspirations and hopes of our residents, Council staff, businesses, universities and organisations from the public, voluntary, community and faith sectors across the county.

We aim for everyone in Surrey to feel safe and have access to opportunities in education, skills development and employment and appropriate care and support to help them reach their full potential. This is key to ensuring that everyone feels included in our community. We strive for Surrey to be a place where everyone feels at home, where our businesses prosper, effective infrastructure is in place and where the environment is clean, safe and green. Our work is underpinned by our overarching ambition to ensure that no one – both current and future generations - is left behind.

At the time of writing this statement, local government in Surrey is undergoing a significant transformation which will make the system simpler, more connected, and better able to meet local needs. From April 2027, the existing county council and 11 district and borough councils will be replaced by two new unitary councils – East Surrey and West Surrey. While preparations are underway for these changes, the Council will maintain its efforts to mitigate risks of modern slavery in our supply chains.

Our 2025/2026 modern slavery statement provides an update on all six areas recommended by Section 54 of the Modern Slavery Act 2015:

our organisation structure and supply chains
policies in relation to modern slavery
risk assessment
due diligence measures
how we measure our performance, and
training available to our staff

The Council recognises the important role the public can play in shining a light on modern slavery practices. As Section 54 of the Modern Slavery Act 2015 encourages public scrutiny of modern slavery statements, we have included information for reporting cases of suspected or actual cases to the relevant authorities.

Due to the complex and ubiquitous nature of modern slavery, there are different people, teams and local partnerships working to address it and related concerns such as issues around vulnerability and safeguarding. Consequently, it is challenging to document all activities including training, support and correspondence. Therefore, this statement may not fully reflect all actions taken by the authority, but it provides insight into key activities with certain sections of the document updated as necessary.

This statement has been updated to reflect the authority’s current approach and activities undertaken in the 2025/2026 financial year. It relates to key steps taken by the Council between 1 April 2025 and 31 March 2026.

Our organisation structure and supply chains

Surrey County Council provides a range of services to over 1.2 million residents in Surrey including providing social care to children and the elderly, maintaining roads and providing libraries and waste management services. The Council employs approximately 8,554 staff corporately.

Our Corporate Leadership Team provides strategic direction to the whole Council which is organised into the following directorates:

Resources
People and Change
Adults, Wellbeing and Health Partnerships
Children, Families and Lifelong Learning
Place
Community Protection and Emergencies

At the time of drafting this statement, Surrey County Council have a shared procurement service with East Sussex County Council and Brighton & Hove City Council. However, in early 2026, following a review of the service through respective governance routes, all three Councils have agreed to move towards a sovereign operating model, enabling services to better support their individual strategic priorities.

The measures outlined in this statement to address modern slavery risk, particularly those within our supply chain, were carried out through the inter authority agreement. Despite this agreement coming to an end, the Council remains committed to tackling this issue and will continue to build on work undertaken and lessons learned during the partnership.

Beyond work undertaken in our procurement service to mitigate modern slavery risks in our supply chains, the Council also has people and teams across the authorities working on addressing related concerns such as issues connected to abuse, vulnerability, safeguarding, and community and partnership.

During the 2025 to 2026 financial year the Council spent approximately £1,433m with 5,911 suppliers.

Item	Expenditure
Education, health & social care	£833m
Assets and infrastructure	£442m
Corporate & Business	£158m

Policies in relation to slavery and human trafficking

Surrey County Council recognises the importance of policies to communicate our commitments and expectations of our staff, suppliers, and those who we do business with, to effectively address modern slavery. We also recognise that modern slavery sits on the extreme end of the labour exploitation continuum. Therefore, we have several policies, procedures, and codes of conduct with respect to abuse, fair labour and employment conditions that work to prevent and respond to a range of issues, including modern slavery, in our operations and supply chains. This includes whistleblowing, recruitment, health and safety, and grievance policies. Details of key policies and their relevance to modern slavery can be found in the Annex.

Risk assessment

As a public sector body, we recognise the risk of modern slavery facing vulnerable people and service-users in our community, as well as workers in the supply chains supporting our activities. We also acknowledge that modern slavery is an issue that is prevalent in the UK. While we have an ambition to work with local supply chains, the risk of exploitation still exists as the unfortunate reality is that no supply chain is entirely free of modern slavery or unethical labour practices.

Modern slavery can take place at any stage of a supply chain, from the extraction of raw materials to the delivery and use of a final product while people delivering and receiving services can be subjected to exploitative practices by perpetrators internal and/or external to an organisation.

To aid our understanding of risks and inform our due diligence approach, we regularly consult and communicate up-to-date information on high-risk goods and services within the UK and beyond. Regarding modern slavery concerns in services we provide and the communities we serve, we recognise vulnerable service-users including children, young people, and vulnerable adults. Within our supply chains, we recognise risks in our third party spend.

Risk assessment of exploitative labour practices is embedded in our day-to-day procurement activity and is carried out on a project-by-project basis. This is primarily a desk-based exercise and led by our Senior Policy Lead on Modern Slavery in our Procurement's Policy Team, supported by the Strategic Procurement Team. The frequency of these assessments ensures that due diligence is applied consistently across high-risk categories and in new procurements where risks may be less familiar. We consider risks to workers involved in delivering the core service, and over the past financial year have started taking action to understand and address risks affecting workers further down the supply chain, such as those carrying out cleaning, repair, and maintenance roles to support the delivery of core services.

Our approach to risk assessment draws on a broad range of sources and considers risks across the spectrum of labour exploitation, recognising that the lines between unethical labour practices and modern slavery can often be blurred, with poor labour practices risk escalating to labour exploitation if not addressed.

To support our risk assessment, we draw on a range of sources. Key sources include, but are not limited to:

Statutory guidance – Such as Procurement Policy Note 009: Tackling Modern Slavery in Government Supply Chains, which provides direction for commercial and procurement professionals
Research publications – including UK and international research on modern slavery and global resources such as the Global Slavery Index
Industry reports – which progress our understanding of sector-specific risks, trends, and issues.
Parliamentary reports: including findings and recommendations from parliamentary inquiries and committees.
Non-Governmental Organisation reports: which provide valuable frontline perspectives and evidence on exploitation risks.

Given the large number of procurements delivered, risk assessment helps us to identify projects to prioritise for due diligence. When assessing risks there are numerous characteristics that are taken into consideration such as the industry type, nature of the workforce, and business and supply chain model. The highest risk areas include construction, adult social care, facilities management, cleaning, waste management, and certain projects that support transition to a low carbon economy, such as those involving solar panels. Common risk factors in these sectors include complex supply chains, extensive subcontracting, reliance on agency labour, and the vulnerability of low‑paid or marginalised workers.

In our risk assessment we also give consideration not only to our exposure to modern slavery, but opportunities to manage those risks. To fully understand project specific risks, close engagement is often required between the Senior Policy Lead on Modern Slavery, service stakeholders (such as commissioners and contract managers), and procurement officers.

Due to the activities and services we undertake and deliver as a local authority, we expect the type of risks we are likely to encounter to remain consistent and unlikely to vary significantly, however, incorporating risk assessment into our day-to-day procurement processes ensures that we are able to capture projects with new or emerging risks.

Due Diligence

This section of our statement reports on activities aimed at understanding and managing risks within our operations and communities and our supply chains.

Our operations and communities

The Council has numerous legal responsibilities to protect and safeguard vulnerable adults, children and young people. Under the Care Act 2014 we have a duty to safeguard adults with care and support needs. We also have a duty under child protection legislation, notably the Children Act 1989, the Children Act 2004 and the Children and Social Work Act 2017 to safeguard children and young people in need in our local area.

Surrey County Council is also first responder organisation. This means we have a responsibility to refer potential victims into the National Referral Mechanism (NRM). This is the government's framework for identifying and supporting potential victims of modern slavery. Under section 52 of the Modern Slavery Act 2015, we have a statutory duty to notify the Home Office of potential victims of modern slavery that we come across.

Adults who give their consent and child victims can be referred into the NRM. Where a potential adult victim has not consented to a referral, the Council still has a duty to notify (DtN) the Home Office to support intelligence gathering.

In 2025, 23,411 potential victims of modern slavery were referred to the Home Office.

Of these, Surrey County Council referred 40 potential victims into the NRM. All 40 potential victims were children (aged 17 and under). Three DtN referrals were also made.

With regards to adult safeguarding, Section 42 of the Care Act requires local authorities to make enquires, or ask others to do so, if they believe an adult with care and support needs is at risk of abuse or neglect in their area and to find out what, if any, action may be needed to protect them. The Care Act 2014 includes modern slavery as a type of abuse, as well as being a serious crime, therefore, managing cases of modern slavery is closely linked to safeguarding adults procedures.

A section 42 duty is triggered when three requirements of the Care Act have been met. This is when an adult: has care and support needs, is experiencing or is at risk of abuse or neglect and as a result of those care and support needs is unable to protect themselves from the risk or experience of abuse or neglect.

During the 2025 to 2026 financial year, 6 safeguarding cases reported as a modern slavery concern progressed to a section 42 safeguarding enquiry. This figure only reflects the cases that have been enquired upon and is not indicative of all safeguarding concerns received by the local authority.

Our supply chains

As the authority delivers hundreds of projects annually, we rely on a range of risk management “pinpoints” and internal systems to identify and address risks in our procurement activity. We continued to maintain our efforts to combat slavery in our supply chains and in the last financial year have focused on strengthening our approach to managing risks in our tendering activity. Key due diligence work undertaken during 2025-2026 included:

Project resourcing: The Procurement service’s Policy Team reviews requests made by Procurement Partners and Strategic Procurement Managers for resources (such as a Procurement Specialist) to support projects. This review is undertaken on a weekly basis to identify projects that may need input from the Senior Policy Lead on Modern Slavery. When a project is flagged, an automated email is sent to the project lead instructing them to engage with the policy lead. This process ensures that the policy lead is engaged once formal procurement activity begins.
Procurement forward plan: The Procurement Data and Analytics team provide the Senior Policy Lead on Modern Slavery with a weekly updated report of projects, including those that have been recently added to our project management system. Projects have several filters applied, such as limiting to those that are Active or Pending and due to mobilise within the next 24 months. The policy lead uses this forward plan to track progress of projects and engagement with procurement leads to ensure management of modern slavery and unethical labour risks where required.
Collaboration and engagement: Our Senior Policy Lead on Modern Slavery has regular meetings with members of the Strategic Procurement Team to discuss project scopes and potential risks. As projects can be at different stages, they engage regularly to ensure the policy lead is kept updated on projects as they progress. Procurement officers also connect the policy lead with other key stakeholders such as consultants, commissioning teams, and framework managers to discuss risks and due diligence measures.
Procurement activity: Where a project is recognised as high-risk and there is an opportunity for risk management, the Senior Policy Lead on Modern Slavery is on hand to embed appropriate due diligence requirements in tendering activity. This includes supporting market engagement (such as communicating risks and expectations to the market), establishing specification requirements, drafting technical questions and reviewing award criteria, and advising on contract terms and conditions (which are reviewed and signed off by the legal team). The policy lead also supports the evaluation and moderation of modern slavery questions as the subject matter expert. Where a framework is being used for a high-risk project, the policy lead reviews existing framework materials, including terms and conditions, to understand what considerations around modern slavery were built into it and explores ways to strengthen these in call offs.
Procurement reporting: Modern slavery is included in our procurement report to ensure that it is part of our documentation and decision making. Procurement officers are responsible for completing the report and documenting engagement with the policy lead and any modern slavery requirements and actions taken in the procurement.
Training: Regular training continues to be delivered to the procurement service to keep them up to date on approaches to managing modern slavery risks (see next section on training).
Preparing for new regulations: The Council has taken several measures to prepare for the National Health Service (Procurement, Slavery and Human Trafficking) Regulations 2025 and associated guidance that entered into force May 17, 2026. This included: attending webinars delivered by the Department of Health and Social Care and NHS on implementing the regulations; issuing comms to procurement staff via our internal intranet to raise awareness of the regulations; presenting the regulations and requirements at our Strategic Procurement Team meeting; and reviewing existing systems and internal guidance for procurement to support implementation
Additional procurement checks: In addition to the above, other checks typically undertaken within the procurement service for projects at risk of modern slavery and unethical labour practices include: reviewing past activity and checking procurement materials to understand what actions, if any, were taken to manage risks; assessing sector and supply chain risks and the market’s response (e.g. reviewing Modern Slavery Statements); considering the urgency and contract length of projects to determine what is feasible to implement during tendering and the contract lifecycle; and confirming route to market and appropriate actions to manage risks – for example, if using a framework, engage with the framework manager to identify opportunities to strengthen requirements in call offs/mini competition.
Reporting: Published a modern slavery statement outlining activities undertaken to tackle modern slavery during the 2024 to 2025 financial year on our website and on the Government’s modern slavery registry.

In addition to the above, the Council has also engaged in collaborative work to address modern slavery in high-risk activities. In September 2025 the Council collaborated with experts from Surrey Heartlands, Skills for Care, and Surrey Police to deliver a session to care providers, with the aim of raising awareness of modern slavery and broader labour exploitation risks in the adult social care sector, reinforcing the importance of a multi-agency partnership in safeguarding vulnerable individuals.

Training

The Council continue to have the following training available to all staff on our e-learning platform.

Human Trafficking and Modern Slavery

This is a 45-minute e-learning course which offers an understanding of modern slavery and the scope of the problem in the UK. It includes information on what modern slavery is, key pieces of legislation dealing with modern slavery, spotting the signs that someone may be a victim, how to respond, and how to get potential victims help and refer them into the NRM.

Introduction to Modern Slavery in Supply Chains

This is a 60-minute e-learning course designed by the Council's Senior Policy Lead on Modern Slavery in the procurement service to help staff in supply chain management roles understand the unique issue of modern slavery in supply chains. It includes information on key findings of the Global Slavery Index 2022 in relation to forced labour in supply chains, the current legislative landscape, the International Labour Organization's Indicators of Forced Labour, high-risk sectors for forced labour, examples of cases within the UK and public sector responsibility for addressing modern slavery risks within our supply chains. This training was developed to ensure consistency in training received for staff working in procurement as well as others in operational roles.

In addition to the training available above, during the 2025-2026 financial year, two knowledge-share training sessions, lasting between 1 hour and 1.5 hours, were delivered by Procurement’s Policy Team, including the Senior Policy Lead on Modern Slavery, to the service. These sessions focused on the National Procurement Policy Statement (NPPS) which sets out central government’s strategic priorities for public procurement and how contracting authorities can support their delivery. The NPPS requires all contracting authorities to have regard to these priorities when exercising their functions relating to procurement and where it is relevant to the subject matter of the contract and it is proportionate to do so. Having regard means that contracting authorities must consider whether the procurement can contribute to achieving one or more of the policy objectives stated in the NPPS in a manner that is appropriate, proportionate and relevant and take steps to address this where it can. The NPPS requires the Council to consider issues such as fair working conditions and ensure that suppliers are committed to safe and healthy working conditions and actively working to tackle modern slavery and human rights violations and comply with employment law and other legal obligations. The first session delivered to the Procurement service aimed to raise awareness on the NPPS, its importance, and how to have regard to its priorities when undertaking a procurement. The second session explored the priorities in greater depth and outlined the Policy Team’s approach to ensuring that these and the Council’s own priorities are reflected in our service offer and procurement activity. This included: a brief refresher on modern slavery; a reminder of what we are trying to achieve in relation to modern slavery risk management; the factors that influence and shape this work; how projects are prioritised for modern slavery due diligence; and examples of how modern slavery considerations have been embedded.

Key performance indicators to measure effectiveness of steps being taken

Our general approach to tackling modern slavery, particularly within our supply chains, is heavily informed by existing research, best practices, and statutory guidance. Research on modern slavery statements often report that one of the areas organisations tend not to report on are indicators to measure effectiveness of anti-slavery efforts. The Council therefore recognises this as an area for improvement and is working to strengthen how we measure our overall approach. As aforementioned, a challenge the Council faces with tracking actions to tackle modern slavery and consequently their effectiveness, is the number of activities and correspondence undertaken in this area by different people, teams and services across the authority, particularly those that handle concerns such as safeguarding whose work captures modern slavery issues alongside others.

The indicators below have been drawn from and inspired by external guidance and demonstrate what our organisation believes is feasible for us to monitor at this stage in our journey to managing modern slavery risks. These indicators support our anti-slavery efforts by i) helping us to understand potential risks ii) ensure that we are taking action iii) understand the effectiveness of our approach and iv) identify areas that require improvement. We will monitor and report on our indicators on an annual basis in our modern slavery statements.

What we are measuring	Challenges/limitations	Why we are measuring it	How we are measuring it	2025/2026
Potential cases of modern slavery	Reports of potential cases of modern slavery can be made through various channels within the local authority and the process for addressing different types of concerns may differ. As a result, the number of cases that have been reported in this statement may not reflect all potential cases or concerns received by the local authority.	Identifying cases not only ensures that potential victims have access to necessary support, but also gives us insight into the risks we may encounter as an authority, vulnerabilities within our community, operations, and supply chains, and our overall response to these challenges.	Number of reports made through the following channels: Our whistleblowing helpline Adult safeguarding enquires NRM (end of year summary 2023 statistics)	Whistleblowing: 0 Adult Safeguarding (s42 enquiry): 6 NRM: 40 referrals & 3 DtN
Training of key supply chain management staff	Despite the availability of Council-wide training on our e-learning platform, the authority recognises the importance of providing regular and targeted training for our staff. However, it can be challenging to require this type of training due to the large number of staff members who have various roles and responsibilities. Additionally, staff may have access to training (both internal and external) provided by their teams or services. As a result, the training reported may not accurately reflect all staff members who have accessed modern slavery training.	Targeted training ensures that staff responsible for key aspects of service delivery are equipped with the necessary knowledge and skills to address modern slavery within their specific roles.	Number of training delivered to staff and attendance	Procurement Number of sessions: 2 Number of attendees: Session 1: 50 Session 2: 44
Review active high-risk projects to understand how modern slavery considerations were embedded	Due to capacity limitations, it is not feasible to review all current projects that are high-risk of modern slavery practices and engagement with suppliers.	To leverage insights from active procurements and current contracts to inform our handling of future high-risk projects and our overall approach to managing risks in procurement and contract management activity.	Project sampling	During the 2025/2026 financial year, 7 active projects with a total contract value of £158m

What we are measuring

Challenges/limitations

Why we are measuring it

How we are measuring it

2025/2026

Potential cases of modern slavery

Reports of potential cases of modern slavery can be made through various channels within the local authority and the process for addressing different types of concerns may differ. As a result, the number of cases that have been reported in this statement may not reflect all potential cases or concerns received by the local authority.

Identifying cases not only ensures that potential victims have access to necessary support, but also gives us insight into the risks we may encounter as an authority, vulnerabilities within our community, operations, and supply chains, and our overall response to these challenges.

Number of reports made through the following channels:

Our whistleblowing helpline

Adult safeguarding enquires

NRM (end of year summary 2023 statistics)

Whistleblowing: 0

Adult Safeguarding (s42 enquiry): 6

NRM: 40 referrals & 3 DtN

Training of key supply chain management staff

Despite the availability of Council-wide training on our e-learning platform, the authority recognises the importance of providing regular and targeted training for our staff. However, it can be challenging to require this type of training due to the large number of staff members who have various roles and responsibilities. Additionally, staff may have access to training (both internal and external) provided by their teams or services. As a result, the training reported may not accurately reflect all staff members who have accessed modern slavery training.

Targeted training ensures that staff responsible for key aspects of service delivery are equipped with the necessary knowledge and skills to address modern slavery within their specific roles.

Number of training delivered to staff and attendance

Procurement

Number of sessions: 2

Number of attendees:

Session 1: 50

Session 2: 44

Review active high-risk projects to understand how modern slavery considerations were embedded

Due to capacity limitations, it is not feasible to review all current projects that are high-risk of modern slavery practices and engagement with suppliers.

To leverage insights from active procurements and current contracts to inform our handling of future high-risk projects and our overall approach to managing risks in procurement and contract management activity.

Project sampling

During the 2025/2026 financial year, 7 active projects with a total contract value of £158m

Reporting concerns of modern slavery

For further information on modern slavery and how to spot the signs that someone may be a victim, please see: Unseen

Reports of suspected or actual cases of modern slavery can be made via the following channels.

Non-emergency concerns: call the Modern Slavery Helpline – 08000 121 700 or local police on 101 (ask for their Modern Slavery Team)
For concerns about your working conditions and your rights, and abuse or exploitation at work: contact the Fair Work Agency.
Emergency, immediate danger, or threat to life situation: call 999
Surrey County Council Whistleblowing: Our counter fraud initiatives and strategies
Concerns for an adult with care needs – Adult Safeguarding: 0300 470 9100
Concerns for a child with care needs – Children’s Single Point of Access: 0300 470 9100

Approval of statement

This statement has been approved by the Corporate Leadership Team on 4 August 2026. It will be reviewed and updated on an annual basis.

Signed by

Terence Herbert, Chief Executive
Date: 14 September 2026

Tim Oliver OBE, Leader of the Council
Date: 15/09/2026

Annex – Organisational Policies

Policy	Relevance to tackling modern slavery
Council Constitution	Surrey County Council’s Constitution sets out how the council conducts its business, how decisions are made and the procedures to be followed to make sure that these are efficient, transparent, and accountable to local people. The “Procurement and Contract Standing Orders” in the Constitution sets out how the Council authorises and manages spending and contracts with other organisations. The procurement approach is relevant to tackling modern slavery as it covers issues such as: social sustainability measures to ensure that supply chain partners operate fair and ethical working practices; the requirement of procurement teams to work closely with human resources to manage direct and indirect employment arrangements (such as temporary workers, agencies, and consultants); and ensuring that relevant policies and codes of conduct are communicated to suppliers. It also includes a specific section on modern slavery which requires Council officers to have regard to the risk of unethical labour practices in the supply chains of goods, services and works that being procured.
Whistleblowing Policy	Our whistleblowing policy enables individuals to feel confident in raising serious concerns and reassures that they will be protected from possible reprisal or victimisation. The policy covers: all Council employees; members of the Council; those carrying out work for the Council on its premises, such as agency workers, contractors, and consultants; providers of works services and supplies, including external contractors; and those providing services under a contract with the Council in their own premises, for example, care homes. The policy provides information on how individuals may raise concerns confidentially and how they will be dealt with. This policy is important for individuals wanting to raise concerns about modern slavery and/or related issues.
Social Value Policy	The aim of this policy, and the accompanying guidance, is to set out how Surrey County Council will deliver maximum social, economic and environmental value, not only through its commissioning, procurement, and contract management activities but also through enabling wider collaboration and resource sharing between people and organisations across the county. The policy and accompanying guidance are relevant to tackling modern slavery as they encourage commissioners to identify social issues that might be connected to a project or service. This is relevant for projects or services where the risk of poor working practices and modern slavery are high.
Officers’ Code of Conduct	The purpose of this Code is to help employees support the Council’s aim to provide high quality services fairly and efficiently in line with its values. The Code of Conduct, which applies to all Council employees, agency workers, contractors and their staff, outlines the expectations of the organisation in terms of the behaviour of individuals whilst working for, or on behalf of, the Council. This is relevant to the anti-slavery agenda as the Code expects employees to behave ethically and maintain high standards of personal conduct and be aware of and act in accordance with the Council’s values and behaviours.
Health and Safety	The Council has various policies which aim to promote high standards and good practices in relation to health, safety, and welfare. This includes the Health, Safety and Wellbeing Policy which sets out the general approach to the management of health and safety and the way in which managers and employees should control risks. These procedures are important to tackle modern slavery as victims are at increased risk of work-related injuries and ill health due to inadequate protective equipment and health and safety measures, including appropriate training.
Working Time Regulations Policy	The Council recognises that excessive overtime beyond permitted national legal limits can contribute to forced labour practices when coupled with forms of threat. The Working Time Regulations Policy sets out the Council’s position regarding working time in line with the Working Time Regulations 1998. This policy applies to all permanent, part-time, temporary and bank workers employed by Surrey County Council, whether on Surrey Pay or national terms and conditions. Managers using agency workers are expected to ensure that the limits to working time and rest break requirements are applied to these workers when they are working for the Council.
Recruitment	The Council has several recruitment policies to ensure that we have the right people with the right skills in the right place at the right time. The policies below are relevant to the anti-slavery agenda as they cover aspects of work where vulnerable people could be taken advantage of and exploited. The Council recognises that victims of modern slavery can be exploited in legitimate jobs with legal terms of employment but exploited by others unrelated to the Council. Therefore, the policies below are important to ensure that potential victims and vulnerabilities are identified during the resourcing and recruitment process. Key policies include: Resourcing policy: This covers various aspects of the resourcing process such as human resource planning, internal progression, recruitment, selection, and induction. It ensures that relevant eligibility and safeguarding checks are in place in the hiring process. This includes ensuring eligibility of successful candidates to work in the UK and confirming qualifications and experience. Safe employment and disclosure and barring service policy: This enables the Council to fulfil its statutory obligations to perform appropriate background checks on employees and volunteers who carry out certain roles that involve working with children, young people, and vulnerable adults. This policy applies to individuals who are, or wish to be, directly engaged by the Council to carry out work duties and voluntary activities on its behalf. The policy does not cover contractors or agency workers. Short term resourcing needs policy: The policy covers the management of temporary or short-term resourcing needs, including the use of agency workers or consultants. Managers are responsible for ensuring there is a clear business case based on the urgency of service needs, potential scarcity of skills and the impact insufficient staffing would place on the service prior to engaging a temporary worker. The Council have a managed service provider who supplies all agency workers. The Council have set out the responsibilities for the agency as a hiring manager throughout their assignment. The policy recognises the rights of agency workers including the rights under the Agency Workers Regulations 2010 which gives agency workers the entitlement to the same or no less favourable treatment as comparable employees with respect to basic employment and working conditions, if and when they complete a qualifying period of 12 weeks in a particular job.
Equality Policy	EDI in Employment Statement: EDI in Employment Statement: In line with the Council’s ambition to ensure “no one left behind,” this statement outlines our commitment to EDI and the steps we will take to ensure a respectful and supportive environment for all employees. This includes having inclusive staff networks to improve staff experiences within our organisation, making reasonable adjustments to ensure disabled people are not put at a substantial disadvantage compared to non-disabled people, and monitoring and evaluating our workforce diversity. The Council recognises that certain vulnerable, marginalised, and underrepresented groups are at a higher risk of poor labour and employment practices and therefore our policies and associated guidance, such as our Ending Bullying and Harassment Policy, ensure that every member, manager, and employee have a duty to be aware of equality issues in their daily activities.
Grievance Policy and Procedure	The Grievance Policy and Procedure aim to create a working environment in which all employees can freely raise concerns and seek a resolution promptly, fairly, and informally wherever possible. Grievance mechanisms are important to tackle modern slavery as it involves an additional route by which employees can raise complaints or concerns.
Domestic Abuse	This policy gives guidance on how to recognise domestic abuse, including honour-based abuse, how to support employees who are suffering domestic abuse and how to deal with employees who are perpetrating domestic abuse. This policy applies to all employees on Surrey Pay terms and conditions of employment and those employment groups who choose to adopt Surrey Pay policies. It will also apply to teachers in schools where the Council is the employer of staff, and in other maintained schools who choose to adopt the policy. The policy educates managers on signs that may indicate an underlying domestic violence issue such as a drop in performance, increased absenteeism, deliberate isolation at work and showing obvious signs of stress and nervousness. While this policy focuses specifically on domestic abuse, it is important for tackling modern slavery as cases may share similar indicators of abuse.
Trade Unions	At Surrey County Council unions meet very regularly with the Council’s management to discuss a wide variety of issues and to feedback staff concerns and issues. The Council provides information to staff on the benefits of trade union membership and information on how to join a union. The Council also has a Trade Union Recognition and Facilities Time Agreement in place with Surrey County Council Trade Unions. The agreement explains trade union recognition and representation within the Council, sets out the arrangements for the management of relations between Surrey County Council and the trade unions it recognises for the purposes of collective bargaining, documents a framework for negotiation, consultation and information-sharing and sets out the facilities time that Surrey County Council will provide to the unions recognised for collective bargaining purposes to enable them to represent the interests of their members who are employees of the council. The Council recognises that trade union representation in the workplace can help reduce the risk of modern slavery by representing the interest of workers, ensuring fair working practices, supporting workers in negotiating their terms and conditions, and the resolving of grievances.

Surrey Safeguarding Adults Policy and Procedures	Our safeguarding adults work is an important part of our work in Adult Social Care. The aim of this policy is to set the direction for our safeguarding adults work. It outlines the Council’s commitment to adult safeguarding including: preventing harm and reduce the risk of abuse or neglect to adults with care and support needs; stop abuse or neglect wherever possible; safeguard adults in a way that supports them in making choices and having control about how they want to live; promote an approach that concentrates on improving life for the adults concerned; raise public awareness so that communities, alongside professionals, play their part in preventing, identifying and responding to abuse and neglect; provide information and support in accessible ways to help people understand the different types of abuse, how to stay safe and what to do to raise a concern about the safety or well-being of an adult ; and address what has caused the abuse or neglect.
Surrey Safeguarding Children Partnership Procedures Manual	These procedures contain the Surrey Safeguarding Children Procedures which cover the areas served by the Surrey Safeguarding Children Partnership. The manual reflects current legislation, government statutory guidance and expectations, and accepted best practice. It advocates a child-centred approach to ensure that the welfare of children is safeguarded and promoted. This includes protecting: Protecting children from maltreatment; preventing impairment of children’s health and development; ensuring that children grow up in circumstances consistent with the provision of safe and effective care; and taking action to enable all children to have the best outcomes.
Supplier Code of Conduct	The Council believes that its supply chain plays a vital role in making a positive contribution to its communities and society. Procuring in an ethical, fair, responsible and sustainable way which allows us to work with successful bidders to align with our policy objectives is a priority. The Council's Supplier Code of Conduct embeds these policy objectives and provides a detailed expectation of our supply chain. We expect our suppliers and their supply chains to follow three key principles which focus on people, planet and public service. These principles are underpinned by an overarching expectation for suppliers to conduct their business responsibly, maintaining high standards of integrity and professionalism in their business dealings.