Modern Slavery & Human Trafficking Statement 2024 - 2025

1. Background

In 2023 we further strengthened our partnership between Isle of Wight NHS Trust (IWT) and Portsmouth Hospitals University NHS Trust (PHU) by forming an NHS Group. The Group is not a merger of our Trusts but will enable greater collaboration between our two organisations. By working together, we hope to be able to provide and improve services across our sites allowing our patients to benefit from the knowledge and expertise held in both Trusts. We have put in place a leadership structure to enable a focus on joint working to plan for the changes required for clinical and financial sustainability as well as leading day-to-day delivery in each of our Trusts.

The two Trusts remain two separate statutory organisations with an overarching Executive team, supported by dedicated Trust Leadership Teams for both PHU and IWT, each headed by a Chief Officer. They align the strategic direction and transformation work across our two organisations and together with the Trust Leadership Teams, oversee the delivery of each Trust’s operating plan and strategy.

Our Board committees, all chaired by a Non-Executive Director and reporting to the Board, provide strengthened oversight and management of planning, performance and risk. More details about our Board and committees can be found elsewhere in this Annual Report. The Trust Leadership Team, which includes both Executive Directors and Divisional Directors, ensures good governance across the organisation.

The Boards and committees meet in common. The Boards-in-Common have agreed to produce a combined statement for the NHS Group on behalf of PHU and IWT.

2. Introduction

Modern Slavery can take many forms including slavery, servitude and forced or compulsory labour and human trafficking. The Modern Slavery Act 2015 is an Act of the Parliament of the United Kingdom designed to combat modern slavery in the UK.

Section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015 requires all commercial operations in the UK with a turnover in excess of £36million to publish an annual statement setting out the steps they take to prevent modern slavery in their business and their supply chains.

Both PHU and IWT have a zero-tolerance approach to any form of modern slavery, and this statement sets out the steps both organisations have taken during the financial year 2023 / 2024 and are continuing to take to ensure that modern slavery and human trafficking is not taking place within our business or supply chain.

All members of staff within both organisations have a personal responsibility for the successful prevention of modern slavery and human trafficking, with the Procurement Department taking a lead responsibility for compliance in the supply chain.

Both PHU and IWT are committed to acting ethically, with integrity and transparency in all business dealings, and putting effective systems in place to safeguard against modern slavery taking place within the business or our supply chain.

3. Organisation structure, business and supply chains 

Isle of Wight NHS Trust (IWT)

The Isle of Wight NHS Trust is an integrated Acute and Ambulance healthcare provider in England. The Trust provides care to a local population of 142,000 as well as the tourist population which rises significantly in the Summer.

In July 2024, Community, Mental Health and Learning Disability services on the Isle of Wight transitioned to be run by Southern Health NHS Foundation Trust. In October 2024, the newly formed Hampshire and Isle of Wight Healthcare NHS Foundation Trust was launched bringing services provided by Southern Health NHS Foundation Trust, Solent NHS Trust and others together. These services continue to be provided locally across the Island.

The Island’s population is less diverse than England and has fewer young working-age people (aged 20 to 44 years) than the national average and significantly higher numbers of older people (aged 70 years and over).

The population is expected to increase by 3% over the next five years, and with a growing number of older residents. People are living with more long-term conditions such as heart and respiratory disease, diabetes, hypertension, and dementia. These and other long-term conditions are also becoming more common with treatment being needed from an earlier age.

The Trust works with both public health and commissioners to provide high-quality services and provide treatment for people at the earliest stage. We also recognise the important role we play in addressing health inequalities and raising awareness of environmental factors that may impact a person’s health.

In 2024/25 the Trust provided Acute and Ambulance services from St Mary’s Hospital in Newport including an Emergency Department, urgent care service, Community Diagnostic Centre (CDC), emergency and planned surgery, intensive care, paediatric services, a special care baby unit (SCBU), and maternity care services. The Trust also provides diagnostic and screening, pathology, pharmaceutical and outpatient services.

The Isle of Wight Ambulance Service is also based in Newport and delivers all emergency and non-emergency ambulance transport, NHS111 and patient transport services.

Portsmouth Hospitals NHS Trust (PHU)

Portsmouth Hospitals University NHS Trust provides hospital and community care, as well as specialist services to a local population of 700,000 people across Portsmouth and Southeast Hampshire. In addition, we offer certain tertiary services to a wider catchment area in excess of 2.5 million people including:

  • A designated cancer centre serving a population of 800,000 within the south of Hampshire. We are also part of the Central and South Coast Cancer Network.
  • We are home to the Wessex Kidney Centre which is the third largest renal unit in England providing renal services to 2.4 million adults across Hampshire and the south of England.

We have over 8,700 staff, 1,200 beds and more than 200 military personnel working alongside us from Joint Hospital Group South.

The health needs of our communities are changing and thanks to advancements in healthcare, people are living longer than ever before. This does mean that there has been a rise in the number of older people living with complex and multiple long-term health conditions such as cardiovascular and respiratory diseases and cancer who require more regular intervention and support from our services.

The Trust serves communities across the city, Gosport and Fareham, and Southeast Hampshire, which include some of the most deprived 20% of the national population. Around a fifth of our admissions into the hospital come from people living in the most deprived areas, while individuals over the age of 70 now represent 30% of our admissions.

The number of disabled residents in Portsmouth city is higher than England and Southeast region averages, and demand for urgent and emergency care is unusually high.

The Trust continues to work closely with public health and commissioners to provide high-quality services and provide treatment for people at the earliest stage. We also recognise the important role we play in addressing health inequalities and raising awareness of environmental factors that may impact a person’s health.

Most of the Trust’s services are provided at the Queen Alexandra Hospital (QA) in Cosham, with a range of outpatient and diagnostic facilities located within our local communities. These include:

  • St Mary’s Hospital in Portsmouth, which provides midwifery, dermatology and enablement services.
  • Gosport War Memorial Hospital, where a range of services, including the Blake Maternity Unit, Urgent Treatment Centre and diagnostics, are provided.
  • Petersfield Community Hospital, where the Grange Maternity Unit is based.
  • Fareham Community Hospital, where a chemotherapy unit and dialysis unit are both based.
  • Dialysis Centres located across Hampshire and the Isle of Wight including Totton, Isle of Wight, Havant, Milford and Basingstoke.

4. Policies in relation to slavery and human trafficking

Both organisations have several internal policies to ensure that we are conducting our business in an ethical and transparent manner. These include:

  • Recruitment and Selection Policy: We operate robust recruitment practices, including eligibility to work in the UK checks for all directly employed staff. Audits are undertaken by the approved framework for all agency workers engaged via approved frameworks to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will. We also require external agencies supplying temporary staff to demonstrate compliance with the legislation.
  • Equal Opportunities: We have a range of controls to protect staff from poor treatment and/or exploitation, which complies with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment and access to training and development opportunities.
  • Safeguarding policies: We adhere to the principles inherent both within our safeguarding child and adult policies. These provide clear guidance to ensure our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain.
  • Freedom to Speak Up (Whistle Blowing) Policy: Both trusts have updated their Freedom to Speak up Policies to reflect and align to the National Freedom to Speak Up Policy for the NHS. The policies ensure all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals, and how to raise these concerns.
  • Standards of business conduct: this NHS code explains the way we behave as organisations and how we expect our employees and suppliers to act.

We undertake appropriate pre-employment checks and require our agencies on approved frameworks to do the same. We protect staff from poor treatment and/or exploitation and comply with all respective laws and regulations including fair pay rates and terms of conditions of employment. We consult and negotiate with Trade Unions on proposed changes to employment, work organisation, and contractual relations.

5. Due diligence processes in relation to slavery and human trafficking

The Trust’s Procurement and Supply Chain Team are guided by current legislation and government guidance. These include:

  • Comply with the Procurement Act 2023 (PA23) and The Health Care Services (Provider Selection Regime) Regulations 2023, including application of the mandatory and discretionary exclusion grounds relating to modern slavery under Schedules 6 and 7 PA23.
  • Use the Cabinet Office Procurement Specific Questionnaire which asks suppliers to confirm their compliance with s.54 of the Modern Slavery Act 2015
  • Include PPN06/20 Social Value Model requirements within our tenders (one of the policy outcomes is on identifying and managing the risks of modern slavery)
  • Use the standard NHS Terms and Conditions when procuring goods and services, which include several requirements and obligations on suppliers in relation to modern slavery.

IWT and PHU has commissioned ‘The Guardian Service’ to support people to raise concerns in a confidential, supportive and anonymised manner, with appropriate signposting. The Guardian Service will help promote an open and honest culture of listening and learning, so that concerns raised are acted upon in a fair manner, and the speak up function is being actively promoted across the Trust. Any themes or trends are highlighted through internal reporting mechanisms but should something be of concern such as trafficking or modern slavery these would be raised immediately either by exception reporting or direct to an executive director as appropriate.

The NHS People Promise commits to ensuring that “we each have a voice that counts, that we all feel safe and confident to speak up and take the time to really listen to understand the hopes and fears that lie behind the words”. As we continue collaborative working across PHU and IWT we seek to further enhance access to ‘speaking up’ services aiming to ensure our people have easy access to raising concerns regardless of their shift pattern or working hours. Furthermore, key actions include regular communication of the methods to raise concerns; engagement with our people to understand the experience of raising concerns; and analysis of themes to develop a culture for improvement defined as where everyone feels empowered and supported to make improvements, raise concerns, and challenge the status quo; working together to enhance care, safety and services for the benefit of all.

The Trust have a specialist Safeguarding Team which supports both organisations to ensure that we have robust safeguarding arrangements across all areas. This includes responding to allegations of abuse of patients, staff and the wider public and sharing concerns where appropriate with partner organisations.

PHU has an allegations management policy to respond to allegations relating to any member of staff which indicate they may be unsuitable to work with adults or children and works closely with statutory bodies and professional bodies. Management of Allegations is included in the Persons in Positions of Trust (PiPOT) Policy in IWT, which provides a clear framework for managing cases where allegations have been made against a Person in Position of Trust (PiPoT), focusing on the management of risk and provides guidance to ensure appropriate actions are taken in relation to recognising, reporting, recording and responding to incidents.

6. Risk assessment and management

We have robust policies detailing how the Trusts effectively manage risks. Our aim is to promote a risk awareness culture in which all risks are identified, assessed, understood and proactively managed. This will promote a way of working that ensures risk management is embedded in the Trusts’ culture and becomes an integral part of each Trust’s objectives, plans, practices and management systems including in relation to assessment and management of modern slavery and human trafficking risks.

7. Key performance indicators to measure effectiveness of steps being taken

  • KPI 1 - Requirement for Procurement staff to complete annual training on modern slavery.
  • KPI 2 - Reporting any suspected modern slavery violations to an Executive Director immediately upon detection and investigating the reports within 72 hours.
  • KPI 3 - Modern Slavery Assessment Tool will be completed for all new requirements over £2m which are assessed as medium to high risk of Modern Slavery.
  • KPI 4 - Documented evidence of Modern Slavery as a standing Agenda item with Supplier Relationship meeting on a quarterly basis.
  • KPI 5 - The recruitment process for substantive staff is audited on a regular basis (average every two years), by the Trust’s auditors. This includes pre-employment checks and the rights to work in the UK.
  • KPI 6 - Monitoring of incidents and Freedom to Speak Up themes to identify any concerns relating to modern slavery.

8. Training on modern slavery and trafficking

IWT training is provided as part of the mandatory training package. Equality, Diversity and Human Rights training, Safeguarding Adults training, Safeguarding Children training, and Prevention of Radicalisation training all include role relevant modern slavery awareness, and staff are required to complete the courses every three years (except for Equality, Diversity and Human Rights training, which is completed once during the onboarding process).

PHU training is provided as part of Safeguarding training.

Further support and resources on modern slavery and human trafficking is available in both organisations on the staff intranet.

Staff in both organisations are able to access training provided by our Multi-agency Children’s

Partnerships and Safeguarding Adults Boards.

We have specialist safeguarding adult and children teams, whom staff can contact for support with reporting of concerns and who will train staff on how to recognise issues of concern and the actions they need to take when they identify any concerns.

9. Review of effectiveness

In 2024 - 2025 , no concerns were identified by either Trust or brought to either Trust’s attention indicating non-compliance with the Modern Slavery Act 2015.

Both Trusts intend to continue to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in our supply chains. In 2025 - 2026, our anti- slavery programme will include:

  • Continuing to effectively monitor our contracts and supply chain to ensure that new and existing suppliers are compliant with the Modern Slavery Act 2015.
  • Continuing to have robust recruitment systems and processes in place including for overseas recruitment and temporary workers.
  • Strengthening our Freedom to Speak Up processes to ensure all staff feel confident and safe to raise concerns.
  • Work with partners such the local councils and the police, as required, to ensure robust procedures are in place.
  • Continuing to deliver safeguarding training and specialist support for all our staff; and implementing any new guidance or best practice.
  • Continue on our maturity journey as an NHS Group through further alignment in both Trusts’ policies and approaches.
  • Review and alignment of training covering modern slavery in both Trusts to learn from each other and ensure we have the best approach in bout our Trusts.

10. Trust Board of Directors Approval

The statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes both PHU and IWT slavery and human trafficking statement. The Boards-in-Common have considered and approved this statement at the June 2025 Board and will continue to support the requirements of the legislation.

11. Reporting and Signposting

If you suspect someone could be a victim of modern slavery, contact Isle of Wight Police on 999, 101 or through the Hampshire Constabulary website: Home | Hampshire Constabulary

Alternative contacts, available 24 hours a day, 365 days a year: