This statement relates to actions and activities during the financial year 1 April 2018 to 31 March 2019.
Public Sector Audit Appointments (PSAA) recognises that it has a responsibility to take a robust approach to slavery and human trafficking, and is committed to ensuring that such practices have no place in its own business, its supply chain or other activities. The organisation supports the requirements of the Modern Slavery Act 2015 and opposes modern slavery and human trafficking.
Organisational structure and supply chains
This statement covers all activities of Public Sector Audit Appointments, which operates only within England.
PSAA is responsible for discharging the functions of an appointing person specified by the Secretary of State for Housing Communities and Local Government under the Local Audit (Appointing Person) Regulations 2015, including (but not limited to):
(i) issuing an invitation to all relevant principal authorities to become an opted-in authority;
(ii) appointing the external auditor to all opted-in principal authorities;
(iii) specifying scales of fees for the audit of accounts of opted-in authorities; and
(iv) managing compliance by local auditors with the requirements of the PSAA audit services contracts.
PSAA is a small company with a Board of five non-executive directors and six staff. The key elements of its supply chains are contracts for audit services with audit firms, and service level agreements with the Local Government Association for business services.
For more information on our activities, please see the about us page of our website.
Definition of modern slavery
The term ‘modern slavery’ captures a whole range of types of exploitation, many of which occur together. These include but are not limited to:
- Sexual exploitation: this includes sexual abuse, forced prostitution and the abuse of children for the production of child abuse images/videos.
- Domestic servitude: this involves victims being forced to work in usually private households, performing domestic chores and childcare duties.
- Forced labour: this can happen in various industries, including construction, manufacturing, laying driveways, hospitality, food packaging, agriculture, maritime and beauty (nail bars).
- Criminal exploitation: this can be understood as the exploitation of a person to commit a crime, such as pick-pocketing, shop-lifting, cannabis cultivation, drug trafficking and other similar activities that are subject to penalties and imply financial gain for the trafficker.
- Human trafficking: this requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult.
- Other forms of exploitation: organ removal; forced begging; forced benefit fraud; forced marriage and illegal adoption.
Risk assessment and due diligence
We are committed to ensuring that modern slavery does not occur in our business. Our procedures include:
- Robust recruitment procedures for substantive staff and agency workers. This process is compliant with UK employment legislation and includes pre-employment checks, for example ’right to work‘ document checks, obtaining references and understanding any employment gaps. DBS checks would be undertaken for relevant posts.
- Reporting knowledge or suspicion of criminal activity (including slavery or human trafficking) through our whistleblowing procedures, which ensure that employees can raise their concerns confidentially.
- A mandatory e-learning module for all staff on how to tackle and spot modern slavery.
We have procedures and guidance in place that contribute to ensuring that our suppliers understand our values and ethics in relation to modern slavery. These requirements are incorporated in PSAA’s contract terms and specify a supplier’s contractual obligation concerning modern slavery.
The organisation operates the following policies that support its approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in its operations:
Whistleblowing policy: PSAA encourages all its employees and those employed on a contract for service or through an agency to report any concerns related to the direct activities, or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures without fear of retaliation. Employees or workers who have concerns can raise their concern confidentially in writing, or schedule a meeting with the Chief Executive accompanied by a trade union representative.
Recruitment/agency workers guidance documents: PSAA 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.
Awareness-raising: PSAA has raised awareness of modern slavery issues by requiring staff to complete an e-learning module on modern slavery. This module covers the basic principles of the Modern Slavery Act 2015; how employers can identify and prevent slavery and human trafficking; what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and what external help is available, for example through the Modern Slavery Helpline.
Implementation and effectiveness
We have taken the following actions to implement our statement on modern slavery:
- we have reviewed and updated all relevant corporate and human resources policies in relation to modern slavery requirements;
- we have reviewed and updated our procurement procedures and related documentation; and
- all staff have completed e-learning training on modern slavery.
We will continue to review our business operations to identify any parts that may be at risk of modern slavery and human trafficking and we will update this statement periodically in light of this.
We are undertaking further work on measuring the effectiveness of our policy and procedures, to be included in the annual update of this statement.
This statement was approved on 26/02/2019 by PSAA’s Board, and will be reviewed and updated annually.
Tony Crawley Steve Freer
Chief Executive Chairman
Date signed: 26/02/2019