Modern slavery and human trafficking statement

1.1 The Council acknowledges the provisions set out in the Modern Slavery Act (2015) and this statement is made pursuant to section 54(1) and the
recommendations arising from an independent review published in May 2019.

1.2 Portsmouth City Council is committed to preventing slavery and human trafficking in its corporate activities and to ensuring that the services it commissions (and where applicable, the associated supply chains) are free from slavery and human trafficking.

1.3 This Modern Slavery and Human Trafficking Statement sets out the Council’s current position and improvement plans. The council will identify, understand, and mitigate all potential modern slavery risks related to its business and will put in place steps to ensure there is no slavery or human trafficking in its own business operations and/or in its supply chains. For the avoidance of doubt, this statement also applies to Portsmouth International Port.

1.4 This statement will be issued annually, setting out relevant information in respect of the previous financial year and published on the council’s website.

1.5 This statement relates to activities undertaken during the financial year April 2025 to March 2026

2.1 The council’s role in relation to modern slavery is broader than commercial organisations that are required to publish a transparency statement, and can be set out in four areas:

• identification and referral of victims – to report concerns please see paragraph 2.5 below
• supporting victims – this can be through safeguarding children and adults with care and support needs and through housing/homelessness services
• community safety services, enforcement, and disruption activities both independently and with partners
• making sure procurement processes and supply chains are free from modern slavery

2.2 The Council acknowledges its role in working across the city and with the Police and Crime Commissioner’s office to raise awareness of the signs of modern slavery, identifying those vulnerable to it and responding with partners to reports and incidents. This work involves a variety of council services and partners including the International Port, UK Border Force, Police, Civil Contingencies, Environmental Health and Trading Standards, Housing, Neighbourhoods and Building Services, Licensing, Children’s Social Care and Adults Social Care.

2.3 Security meetings are held regularly between Port colleagues, MOD, Police, Border Force and other partners to share intelligence.

2.4 The Modern Slavery Steering Group meets regularly to monitor the program of continuous improvement set out in item 10.

2.5 Work to protect children and vulnerable adults who are trafficked and/or exploited is overseen by our local safeguarding boards including referral processes to the national Independent Child Trafficking Advocacy Service and multi-agency specialist groups (Missing Exploited and Trafficked Group – MET).

2.5.1 Find more information at Portsmouth Safeguarding Children Partnership

2.5.2 Report concerns about an adult or child at Portsmouth Safeguarding Adults Board

3.1 The Government’s approach to tackling modern slavery has been shaped by a number of international laws, conventions and protocols which the UK has opted in to, ratified, or is already bound by, including the: 1950 European Immigration Act 2016 and the Modern Slavery Act 2015.

4.1 Portsmouth City Council (PCC) is a unitary authority situated in Portsmouth within the county of Hampshire. PCC provides a wide range of statutory and discretionary services, delivered both directly by the Council and through external contractors.

4.2 The Council’s senior management structure

4.3 The Council’s constitution

5.1 PCC’s Supplier Questionnaire (SQ) includes a requirement to comply with the Modern Slavery Act 2015 as per the central government issued SQ template document which has been updated to strengthen the commitment of the questionnaire from optional to mandatory asking for copies of statements from all new suppliers identified as commercial organisation under the Modern Slavery Act 2015. In addition PCC will consider retrospective application to existing high risk areas identified by the Labour Exploitation – Industry profiles – sectors at risk – GLAA.

5.2 Further, we would expect and request assurance that the practices of companies and organisations operating within the EU adhere to Article 4 of the European Convention on Human Rights concerning the prohibition of slavery and forced labour.[1]

5.3 Risk assessment and mitigation for modern day slavery to be built into the new procurement processes arising from the Procurement Act 2023, which came into effect in October 2024.

5.4 On a case-by-case basis individual procurements will be assessed for modern slavery risk. High risk contracts will include project specific quality questions relating to modern slavery for tenderers to provide assurances on supply chain management and contract delivery in relation to mitigating against instances of modern slavery.

5.5 The majority of contracts let and managed by the council are low risk for labour exploitation. The programme of continuous improvement includes a plan to develop a new procurement strategy that will identify the highest risk existing contracts and map the associated supply chains. Procurement governance arrangements will be revised to monitor new contract activity that will trigger the application of additional due diligence in respect of high value, high risk contracts in industries identified by the Labour Exploitation – Industry profiles – sectors at risk – GLAA.

5.6 Strategic contracts will be audited on a rolling basis for compliance. These are determined by each directorate based on risk.

5.7 Survivors of Modern Slavery are included as beneficiaries of the local social value procurement policy approved by the Council in March 2021 (available on request).

[1] The government remains committed to the European Convention on Human Rights – https://www.gov.uk/government/consultations/human-rights-act-reform-a-modern-bill-of-rights/human-rights-act-reform-a-modern-bill-of-rights-consultation

6.1. PCC is an active member of the Hampshire and Isle of Wight Modern Slavery Partnership. The Partnership has developed a Modern Slavery Partnership Strategy 2023-2026.

 

7.1 PCC has the following policies that are relevant to the identification of modern slavery risks and the steps it takes to prevent slavery and human trafficking in its operations. All policies are readily available to staff and are also available by contacting the Council direct (please email  Caroline.Hopper@portsmouthcc.gov.uk )

7.1.1 Whistle blowing policy – the council encourages all its employees, councillors, contractors, their agents and/or subcontractors, consultants, suppliers and service providers to report concerns about any aspect of service provision, conduct of officers and others acting on behalf of the Council, or the supply chain. The policy is designed to make it easy to make disclosures without fear of discrimination and/or victimisation. The Policy was reviewed by the Governance & Audit Standards Committee in January 2024 and March 2025.

7.1.2 Employee Code of Conduct – the council’s employee code of conduct (Council Constitution, Part 4C) makes clear to employees the actions and behaviour expected of them when representing the council. The council strives to maintain the highest standards of employee conduct and ethical behaviour when managing the supply chain. View the council’s constitution.

7.1.3 Behaviours and Values – Following its launch in 2023, the behaviours framework sets the approach and expectation across all aspects of PCC business. The framework sets out universal behaviours associated with core values of respect, integrity, collaboration, inclusion and being people-focused.

It shows how all staff contribute to the success of the council and creates a guide to encourage and model positive behaviours that are both central to enabling everyone to be at their best in the workplace, and integral to good safeguarding.

7.1.4 Recruitment policy – the council adheres to robust continuing employment checks/standards, this includes ensuring identities and qualifications, UK address, right to work in the UK, (i.e. people bought into the country illegally will not have a National Insurance number), suitable references and payroll information. The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. Recruitment policies were last updated in March 2024.

7.1.5 Fraud and Anti-corruption policy – this requires staff to perform business activities with due diligence in a transparent and ethical manner and to encourage the reporting of suspected wrongdoing. This is also included in the staff induction “Welcome to PCC”.

8.1     The children and adults safeguarding partnerships provide city wide governance in relation to identification, referral and support of vulnerable children and adults who may be at risk of abuse or exploitation. Portsmouth Multi-agency Safeguarding Hubs for children and adults will assess the need for referral to the National Referral Mechanism. Please refer to the links previously provided for details.

In 2025 Portsmouth became part of a Hampshire wide NRM pilot, including a Children’s Services panel. Learning from the pilot will inform the strategic assessment and support wider transitional safeguarding work across children’s and adults’ services.

In January 2026 the Local Government Association published Common Ground: Building Cohesive Communities, which highlights the importance of community cohesion in reducing vulnerabilities among migrants and other marginalised groups who may be at greater risk of exploitation, thereby supporting efforts to address modern day slavery.

In Portsmouth, increasing division and hate crime were identified as local issues during 2025, with concerns from communities that risk undermining this work. In response, the Community Safety Sub-Group of the Health and Wellbeing Board established a workstream to address these issues and strengthen cohesion across the city.

9.1 Modern slavery and human trafficking is included within the council’s safeguarding training for staff working in children and adult services. This training is mandatory for the social care workforce and is consistent with that of other local authorities across the county. In the past 12 months (1 April 2025 – 31 March 2026) 649 staff completed safeguarding training bringing the total number of members of staff have registered or completed on-line training to 2382.

9.2 Of the 649 staff who had completed training, 373 were not social care employees which is also a significant increase from the 204 of the previous year. Whilst these figures include other areas of the council, the largest growth over the past 2 years has been in Housing, Neighbourhood and Building Services with 318 staff trained over this time period.

9.3 Although not currently a mandatory requirement, the introduction of a new Learning Management System has made it easier for staff to access training and the Modern Slavery training module has been completed by 383 staff in the 2026/25 financial year. For 261 staff this has been in addition to them completing safeguarding training.

9.4 A Modern Slavery update is included in regular community safety briefings to directorate management teams and a short animation highlighting hidden vulnerabilities has been commissioned and included in the council’s induction program for all new staff. The animation has been shown as part of the Welcome to PCC (W2PCC) induction session since June 23. During 2025/26, 248 staff watched the animation during the W2PCC sessions, bringing the total number of staff that have seen the animation since 2023 to 569.

9.5 Elected Councillors have their own directory of training and are able to access the new Modern Slavery e-learning as well as safeguarding workshops. For 2026 Modern Slavery will also be included in the Community Safety and Cohesion new members induction training module. In addition to this the Local Government Association have a Councillor guide to tackling modern slavery that is available on their website Councillor guide to tackling modern slavery (local.gov.uk).

10.1 Compliance audit findings are reflected in the Modern Slavery Improvement Plan which is monitored and overseen by the Modern Slavery Working Group, Chaired by the Director of Corporate Services. Each team, department and directorate have the responsibility to identify high risk areas within their systems and processes and contracts for review and audit.

10.2 Strategic Leadership – An annual report is submitted to the Governance and Audit Committee as part of corporate health monitoring process. Regular Modern Slavery working group meetings chaired by the Director of Corporate Services monitors the improvement plan.

10.3 Working with partners – continue to work in active partnership with the Police and Crime Commissioner for Hampshire and Isle of Wight and local safeguarding boards. Support the Hampshire and Isle of Wight Modern Slavery Partnership by continuing to ensure Portsmouth is represented at an appropriate level at the Modern Slavery Partnership Board and sub-groups. Work with Police colleagues to improve local data analysis, emergency planning procedures and enforcement operations.

10.4 Raising awareness – continue to raise awareness of modern slavery by supporting local and Hampshire-wide campaigns to complement annual national Anti-Slavery activity in October and expanding training across the organisation.

10.5 Develop and expand training – Continue to increase the number of non-social care staff and elected councillors accessing e-learning and/or face to face training on modern slavery.

10.6 Procurement and supply chains – Each directorate will continue to determine their priority high-risk contracts for review and audit against compliance. Continue work undertaken to develop a procurement strategy linked with longer term work on social value.

10.7 Policies and processes – continue to ensure that policies and procedures remain relevant and reflect the statutory duty and Council’s commitment to the agenda.

10.8 Enforcement and disruption – continue to support police led community safety responses and disruption activities, improve local data gathering, working alongside partner agencies such as the police, fire service and health services to target enforcement activity.

10.9 Additional Guidance was published at the end of 2025 which supports the development of the Modern Slavery Statement. We are committed to ensuring the requirements of this guidance are incorporated into our action plan, along with best practice over the coming year.

This statement was approved by Portsmouth City Council on 14 July 2026

Documents

Modern Slavery Integrated Impact Assessment