Risk assessment and due diligence

As part of the council’s due diligence processes, it requires its suppliers to demonstrate their commitment and approach to supporting slavery. Therefore, the council screens its suppliers as part of the procurement process. It is intended this activity will be extended to include contract management activity in the future. 

The due diligence measures to detect and eliminate slavery will be developed over time to be guided by risk assessment. The nature of business carried out by the council means that the risk of slavery is considered low, it is necessary to remain vigilant to any potential risk. 

Staffordshire County Council is committed to ensuring modern slavery and human trafficking is not taking place anywhere in any of its supply chains. It is developing prevention, detection, and reporting measures both at the procurement and the contract management stage. The council already scrutinises low priced tenders, applies the mandatory or discretionary exclusion criteria from Crown Commercial Service 4 stipulations, scores and clarifies appropriately focused slavery criteria and it reviews its contract terms and conditions for appropriate clauses for inclusion to ensure compliance with the Modern Slavery Act. The council is currently reviewing these terms and conditions to also be applicable to sub-contractors in the supply chain. 

Where appropriate, the council will investigate supplier and supply-chain working conditions with support from expert independent, third parties to support y in-house operations.