Modern Slavery Statement



Devon County Council is committed to eliminating modern slavery, human trafficking and other forms of exploitation in the county.

Our roles include:

  1. Developing a strategy with partners to address modern slavery.
  2. Raising awareness of slavery, uncovering its existence and identifying perpetrators.
  3. Supporting victims and safeguarding individuals who are at risk.
  4. Ensuring, to the best of our ability, that our services and supply chains are free from exploitation arising from modern slavery and human trafficking.
  5. Raising awareness of modern slavery and human trafficking across our workforce through training.
  6. Promoting equality and tackling discrimination in all its forms.

These roles span several partnerships and cover all the services that we commission and provide. This statement provides a brief summary of our work, with links to sources of further information.

What is modern slavery?

Modern slavery is a crime in which traffickers and slave masters coerce, deceive or force victims to work for little or no pay. It can involve physical, sexual, emotional and financial abuse and other inhumane treatment. Modern slavery can also involve human trafficking, where victims are transported between locations in order to be exploited. Until quite recently it was a largely hidden crime, but is now a priority for Police and public sector partners.

There is no typical victim of Modern Slavery. They can be any age, gender, nationality and ethnicity. However, some people are at greater risk of exploitation including younger people, homeless people and people with mental health problems or learning disabilities. Some may not recognise themselves as victims or understand that they could be entitled to help and support. There may be a language barrier, so victims are not able to communicate. They may have had personal possessions, money, their identity or travel documents taken away from them. They may be threatened with violence to themselves or their families if they do not cooperate.

Modern slavery takes many different forms and operates across several sectors of society and the economy. Research has identified seventeen types of offence, in four categories:

  • Labour exploitation
  • Domestic servitude
  • Sexual exploitation
  • Criminal exploitation.

Our roles in tackling modern slavery

Devon County Council is an upper-tier Council with responsibility for the two-tier area of Devon, which covers eight District Council areas: East Devon, Exeter, Mid Devon, North Devon, South Hams, Teignbridge, Torridge and West Devon. We represent a population of around 800,000 and administer an area of 6,564 km2, geographically the third largest in England.

Our organisation is structured into ten service groupings, with major areas of responsibility including Adult Care and Health, Children’s Services, Communities, Public Health, Environment and Prosperity, Highways, Infrastructure, Development and Waste.

Key partnerships relating to the organisations’ work to tackle anti-slavery include:

  • The Safer Devon Partnership, which provides strategic leadership for community safety matters across the county.
  • The Devon and Torbay Anti-Slavery Partnership, which operates jointly between the Safer Devon Partnership and Safer Communities Torbay.
  • The Devon Children and Families Partnership which has a 2018-2021 joint exploitation strategy with the Safer Devon Partnership to address exploitation of children.
  • Torbay and Devon Safeguarding Adults Partnership, which has a role in protecting adults and ensuring even the most vulnerable are kept safe and well.
  • Devon Procurement Partnership which is a partnership of 19 permanent member organisations. Many of our contracts are created through this partnership, dependent on the circumstances and requirements.

Our roles in tackling modern slavery include:

1) Developing a strategy with partners to address modern slavery

The Safer Devon Partnership has identified exploitation as a strategic priority for Devon, based on a strategic assessment of high-level crime and disorder threats in the County.

2) Raising awareness of slavery, uncovering its existence and identifying perpetrators

We also work across County and Council boundaries as part of Devon and Torbay Anti-Slavery Partnership, which is responsible for coordinating and overseeing preventative work and responses to modern slavery and human trafficking within the county. The Partnership’s roles include:

  • Preventative and awareness-raising work with frontline staff across all sectors and the public. This includes training and communication to increase understanding of modern slavery and human trafficking, and knowledge of how to identify and report concerns and safeguard vulnerable people.
  • Providing strategic support for responses to modern slavery incidents and to the safeguarding of victims.
  • Improving local intelligence in order to increase the likelihood of prosecutions and safeguard those vulnerable to, or being exploited through, modern slavery and human trafficking.
  • Encouraging collaborative working and information sharing between agencies.

Buy with Confidence is a register of Trading Standards Approved businesses. Every business listed has undergone a series of detailed checks before being approved as a member of the scheme.

Devon County Council works with Fairtrade Devon and Devon Development Education to promote the benefits of Fairtrade and encourage individuals, communities, organisations and companies to act in support of Fairtrade.

3) Supporting victims and safeguarding individuals at risk

Our frontline staff have a vital role in spotting signs of modern slavery and human trafficking and safeguarding and supporting victims. These include Adult and Children’s Social Care staff, Trading Standards officers, health visitors, commissioned housing services and many others. Elected Councillors may also come across modern slavery or trafficking.

Safeguarding Slavery Leads, based in Adults and Children’s services, act as points of advice and information for staff and as liaison between safeguarding professionals and the Police.

Under Section 52 of the Modern Slavery Act 2015, local authorities are under a duty to notify the Home Office when they identify a potential victim of modern slavery. The National Referral Mechanism is a framework for identifying and referring potential victims of modern slavery and ensuring they receive the appropriate support.

Those who are recognised as potential victims of modern slavery through the National Referral Mechanism have access to specialist support for a period of at least 45 days while their case is considered. This support may include access to legal advice, accommodation, protection and emotional and practical help.

This support is in addition to our statutory safeguarding role. Where victims of slavery have care and support needs, we may carry out an assessment under the Care Act 2014 or safeguarding under the Children’s Act 1989. A safeguarding plan may be put in place to cover the victim’s needs, for example for an adult placement in a supported living environment, help with daily living skills and psychological support.

4) Ensuring to the best of our ability that our services and supply chains are free from exploitation arising from modern slavery and human trafficking

We require our contractors and suppliers to demonstrate their commitment to supporting human rights within their supply chain relating to, for example, child labour, forced labour, health and safety and working hours.

Our main actions relating to procurement include:

  • Identifying and managing risks in new procurements through general procurement guidance, challenging abnormally low tenders or quotations to ensure to the best of our ability that no breaches of labour laws are taking place, rejecting suppliers that do not meet the minimum standards required by law, and designing new procurements to take account of modern slavery risks. We hold a central register of contracts and exercise due diligence when considering taking on new suppliers.
  • Assessing existing contracts by understanding supply chains, strengthening contract management to manage risks and working with suppliers to progressively improve.
  • Acting when modern slavery is identified or suspected by working with suppliers to resolve issues and change working practices, and by terminating a contract as a last resort.
  • Training; to raise awareness of modern slavery and what suppliers must do to comply with the Modern Slavery Act.

5) Raising awareness of modern slavery and human trafficking across our workforce through training

We have run awareness training workshops for staff, including material produced by the organisation UNCHOSEN and information covering the local context regarding modern slavery and human trafficking in Devon.

An Exploitation Toolkit has been produced for anyone who, through their paid or voluntary work, may come across people who are vulnerable to exploitation. It helps people to understand, identify and report signs of exploitation, and access guidance and support.

6) Promoting equality and tackling discrimination in all its forms

Our Equality Officer maintains a modern slavery web page which raises awareness of modern slavery and human trafficking and links to further sources of information.

Under the Equality Act, we must have due regard to the need to:

  • Eliminate unlawful discrimination
  • Advance equality of opportunity between people who share a protected characteristic and those who don’t
  • Foster good relations between people who share a protected characteristic and those who don’t.

Our achievements, priorities and plans

Achievements 2019/20

Community Safety

  • Development and roll out of Exploitation Toolkit (see above).
  • Roll out of bitesize training sessions on exploitation delivered by Devon’s Community Safety Partnerships.
  • Targeted training rolled out to raise awareness amongst frontline volunteers and staff working with homeless/rough sleepers.
  • Trading Standards held a training day in February 2019 and have now launched a training video to educate traders about modern slavery. They are currently developing a training module and resources for auditors, and plan to expand the Buy With Confidence Scheme into the carwash industry.


  • Child Exploitation Strategy covering all forms of exploitation being actively progressed and cascaded operationally.
  • New Exploitation Coordinator in place in the Multi-Agency Safeguarding Hub.


  • All large-scale procurements require relevant commercial organisations to comply with the Modern Slavery Act 2015 annual reporting requirements.

Workforce Development

  • An e-learning module is being developed.

Plans and priorities 2020/21

Community safety

  • Continue to raise multi-agency awareness of Modern Slavery and Human Trafficking via e-learning and a Modern Slavery and Human Trafficking Conference.
  • Develop and deliver a local agreement/protocol for the provision of humanitarian assistance, reception centres and accommodation for multiple potential victims of modern slavery and human trafficking.
  • Encourage increased multi-agency intelligence reporting to police to enhance threat assessments and knowledge regarding modern slavery and human trafficking.


  • Work across DCC and the Southwest Procurement Board to raise profile and bring attention to Modern Slavery.
  • Undertake supply market assessments and focus reviews to uncover and eliminate slavery from our supply chain.
  • Modern Slavery is included within the newly developed Devon County Council’s Procurement Strategy.

Workforce development

  • Roll-out of e-learning module.

Measuring our effectiveness

Our key performance indicators include the number of:

  • Referrals to National Referral Mechanism
  • Children and young people subject to “Safer Me” plans
  • Adults and children identified at risk
  • Partnership intelligence forms submitted
  • Disruptions for persons and locations of concern.

Our policies and procedures

The following policies are relevant to addressing modern slavery and they are reviewed regularly to ensure that they remain up to date and fit for purpose:

  • Adult Safeguarding polices (as part of Devon Safeguarding Adults Partnership) and Child Safeguarding policies (as part of Devon Children and Families Partnership). These policies set out organisational responsibilities for protecting adults or children at risk of abuse and describe how multi-agency safeguarding arrangements work.
  • Safeguarding of Children Arrangements.
  • Joint Exploitation of Children Strategy.
  • Whistleblowing policy. This policy ensures that workers can report wrongdoing or failures, including concerns relating to the council’s activities and supply chains. It protects their employment rights if they ‘blow the whistle’ about such issues.
  • Human Resources policies. These policies cover recruitment and working at Devon County Council, including procedures for vetting new employees and eligibility to work in the UK. They cover employer and employee responsibilities in relation to employees, consultants, contractors, volunteers and agency workers.
  • Procurement guidance including Achieving Equality through Commissioning and Procurement.
  • Equality Policy which describes our commitment to eliminating discrimination, providing equality of opportunity and challenging prejudice in order to advance the achievement of equality and foster good relations between diverse groups in Devon.

About this Statement

We will renew this Statement annually and publish an update within 6 months of the end of each financial year. A public report on our progress will be issued by October of each year.


Cllr John Hart, Leader of Devon County Council

Dr Phil Norrey, Chief Executive

September 2020