Modern slavery statement 2025 / 2026
In accordance with Section 54 of the Modern Slavery Act 2015, the Police and Crime Commissioner for Gwent and the Chief Constable recognise their responsibility as an employer to be aware of the potential for instances of modern slavery, and to report such instances or concerns to the relevant bodies.
This statement sets out the work undertaken during the financial year ended 31 March 2025 to identify, prevent and address modern slavery across the force and its supply chains.
What is modern slavery?
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, sexual exploitation, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
The Police and Crime Commissioner for Gwent and the Chief Constable are committed to ensuring that there is no modern slavery or human trafficking in the Force supply chains or in any part of the business. The Force’s policies, procedures and our work to tackle modern slavery, demonstrates our commitment to act ethically, with integrity and to identify risks that we can work to mitigate.
In 2017, the police and crime commissioners and chief constables from the four Welsh police forces signed up to the Welsh Government Ethical Employment in Supply Chains Code of Practice.
Our approach to identifying and tackling modern slavery is broken down into four key areas:
Enforcement - we will play an active role in enforcement and will use our roles in employment and purchasing goods and services to improve intelligence gathering whilst ensuring full compliance with the Code of Practice as well as acting promptly on information received.
The Force’s Modern Slavery policy, set by the Chief Officer team, is in place to reduce the risk of serious harm to victims and improve safety, health and wellbeing.
The policy outlines how modern slavery offences will be dealt with and offenders held to justice. Working with the Crown Prosecution Service or other bodies, we endeavour to successfully prosecute offenders, with the aim to enhance the trust and confidence of victims.
Robust training is provided to all officers, highlighting signs, process, victim care and support services.
Ethical procurement – promoting the development of ethical supply chains in the delivery of contracts for the police service in Wales and specifically in Gwent.
Employment – following best practice and demonstrating full commitment to constant improvement within the systems and structures of Gwent Police, as well as working with the other forces in Wales and with partners to identify and eradicate any form of exploitation.
Environment – we will create an environment where the public in Wales have confidence and understanding of how to report any signs of exploitation in all its forms. We will ensure that all our staff, particularly Community Support Officers and staff in our Force Control Room, are fully aware of what to look out for and what to do when concerns are reported.
We recognise that modern slavery extends far beyond our national borders and that risks are increased with complex supply chains.
A review of our supply chains has highlighted the potential risk of modern slavery in the following categories:
- information communication and technology
- construction
- cleaning and waste disposal services
- uniform manufacture
We appreciate that modern slavery can and does occur in many other supply chain categories and we are mapping our supply chains using a risk tool to identify the areas we should prioritise as part of our practical response to modern slavery risks.
Fully investigating supply chains is a demanding task but in the previous 12 months we issued supplier assessment questionnaires to a further 36 suppliers, bringing the total issued to 125, with 100 suppliers given a rating. Bluelight Commercial (BLC) supported us in this work by approaching a number of suppliers to complete a social value assessment. The ratings act as a baseline to measure progress by the supplier in tackling modern slavery, monitored through contract management activity. The suppliers selected are identified as higher risk due to their industry type, nature of the workforce, supplier location, commodity type or the level of our expenditure or are suppliers to whom we have recently awarded a contract and issued the assessment as part of our contract management activity. Where suppliers achieve a basic rating, we encourage them to improve their rating, providing guidance to assist smaller suppliers and signposting them to sources of advice to understand how to make improvements. Social Value is a standard item for regular meetings with suppliers as we recognise that this is an ongoing initiative throughout the life of the contract. Demonstrating social, economic and environmental good practice benefits suppliers who wish to be successful in winning future public sector opportunities.
We are committed to sharing information to make the best use of our resources. By working with other forces, we can better investigate supply chains based on the greatest risk of human exploitation.
We will continue to work to raise awareness of modern slavery issues across our supply chain. In December 2024, we reached our target to assess the top 100 suppliers across South Wales Police and Gwent Police by 2025 and will continue to progress this activity. The annual turnover of these 100 suppliers exceeds £55 billion which illustrates the impact of Welsh Policing on ethical procurement.
Due diligence and risk assessment
Gwent Police has continued to advance this work to deliver during the period 2024-2025.
Policy
As set out in the Joint Collaborative Commercial and Procurement Strategy, 2025-2030, the four Welsh forces have adopted the Bluelight Commercial Responsible Procurement Policy which focusses on the three main themes of People, Planet and Purse, recognising the key role procurement can play in tackling some of the greatest challenges facing our communities. The policy includes demonstrating our assurance of ethical procurement and supply practice.
- We reconfirmed our commitment to implement the Welsh Government Ethical Employment in Supply Chains Code of Practice, and ethical purchasing principles.
- The Gwent Police, Crime and Justice Plan 2025-2029 sets out our policing priorities which include keeping people safe and preventing crime, making our communities safer, protecting the vulnerable and putting victims first. Improving trust and confidence cuts across all of our priorities.
- We are supportive of the principles in the Bluelight Commercial Responsible Procurement & Commissioning Strategy.
- Our recruitment policy reflects our commitment to the Welsh Government Ethical Employment in Supply Chains Code of Practice and is operated and assessed in line with the equality, diversity and inclusion force direction. The recruitment team are responsible for ensuring ethical principles of employment are adhered to when utilising job sites and recruitment agencies.
- Our Business Interest Policy reflects the Welsh Government Ethical Employment in Supply Chains Code of Practice. Officers and staff must be aware of the Code when submitting a business interest approval request.
- The Welsh Government Code of Practice is a standard agenda item on the agenda of our trade unions.
- The Force’s Modern Slavery Policy for frontline officers is reviewed annually by the Force Intelligence & Organised Crime Unit.
- Other relevant policies include the College of Policing Code of Ethics and the All Wales Whistleblowing policy to empower staff to raise suspicions of any unlawful and unethical employment practice.
Procurement procedures
We are working in line with the National Procurement Policy Statement which states that contracting authorities should ensure their suppliers are committed to providing high quality jobs, safe and healthy working conditions, fair pay, opportunity and progression for workers.
- Where appropriate and proportionate, we are using the Bluelight Commercial Social Value Toolkit to ask bidders how they are tackling modern slavery within their organisations and supply chains. We score social value in our tenders to demonstrate how we expect our suppliers to reflect our response and in turn, assist the force in delivering a range of social value initiatives.
- We have continued to increase the awareness of ethical employment in supply chains in order to deliver a culture of wider responsibility within the Force for those involved in the procurement of goods and services, considering not only ethical supply chains but decarbonisation and sustainability, ethical business practice and support for local business and our communities.
- Our standard contract terms and conditions include the right to investigate and establish accountability and a commitment by the winning bidder to complete an assessment questionnaire to establish a baseline where appropriate.
- We continue to share best practice and our work to assess suppliers with the Welsh forces and other Welsh public sector organisations. For example, Dyfed-Powys Police utliise 62 of the 100 suppliers we have assessed for South Wales Police and Gwent Police.
Payment Performance Statistics
- Invoice payment performance statistics are published annually on the Police and Crime Commissioner’s website in line with the statutory requirement. We will comply with any new requirements under the Procurement Act legislation that is still evolving.
Assessing existing suppliers and supply chains
We utilise the Bluelight Commercial Social Value Planning Tool to assess:
- modern slavery
- ethical business practice
- climate emergency
- equality, diversity and inclusion
- social and community contribution
Through contract management, we are evidencing examples of our suppliers reflecting our modern slavery code of ethical procurement within their organisations and offering tangible social value.
Training and raising awareness
- Completion of annual CIPS (Chartered Institute of Purchasing and Supply) refresher training by strategic procurement staff.
- We continue to encourage officers and staff with responsibility for contracts across to attend the Fundamentals of Contract management training provided by Bluelight Commercial. The training includes an awareness of ethical supply chains.
- Ethical dilemma scenarios are shared across the Welsh forces to improve awareness of ethical matters across the forces.
- Recruitment, promotion, interview and related internal processes encourage equality, diversity and inclusion good practice.
- A communications plan is in place to ensure staff are aware of and trained in the internal referral routes for highlighting modern slavery concerns where they emerge.
- The success of this work is reported into the Welsh Forces’ Finance Joint Assurance Group and at the All Wales Collaboration Board Group, by the Chief Financial Officer.
Reporting
This Statement has been approved by The Police and Crime Commissioner for Gwent and the Chief Constable. It will be reviewed and updated annually.
Reporting Concerns
The public and staff equally have a responsibility to be aware of potential instances of modern slavery or of a business using forced labour. If you have any such concerns, please contact any of the following bodies:
Gwent Police: Telephone 101 (or 999 in an Emergency). Report a crime online
Modern Slavery Helpline: Telephone 0800 0121700
Crimestoppers: Telephone 0800 555 111
Confidential Concerns Line, Safecall 0800 9151571 (Gwent Police employees only)
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Modern Slavery Statement 2025 - 2026