Modern Slavery and Human Trafficking Act 2015: The Clatterbridge Cancer Centre Commitment

1. Introduction

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

Modern slavery remains a hidden crime. We all have a responsibility to be alert to the risks of modern slavery, however small, in our organisation and in the wider supply chain. Trust colleagues are expected to report concerns and our management teams are expected to act on concerns in line with Trust policies, the law, and NHS guidelines.

At The Clatterbridge Cancer Centre NHS Foundation Trust (the "Trust"), we are committed to ensuring that no modern slavery or human trafficking takes place in any part of our business or our supply chain, upholding the provisions of the Modern Slavery and Human Trafficking Act 2015.

This statement sets out actions taken by The Clatterbridge Cancer Centre to understand all potential modern slavery and human trafficking risks and to implement effective systems, controls, and best practice. We aim to take all reasonable steps to prevent slavery and human trafficking. We expect our staff, partners, and suppliers to comply with the legislation and report any concerns immediately.

The Clatterbridge Cancer Centre wishes its service users, staff, and all stakeholders to be confident in the knowledge that we operate a zero-tolerance approach to modern slavery and human trafficking.

2. Our commitment

We are fully aware of the responsibilities we bear towards our service users, staff, and local communities. We aim to follow good practice and to take all reasonable steps to prevent slavery and human trafficking.

We are committed to promoting a proactive and inclusive approach to equality in both employment and service provision. This supports an inclusive culture which values diversity. This includes a commitment to building a workforce which is valued and whose diversity reflects the communities it serves, enabling the Trust to deliver the best possible healthcare services.

The Clatterbridge Cancer Centre is guided by a strict set of ethical values in all of its business dealings and expects its suppliers to adhere to these same principles. The Trust is committed to ensuring there is no modern slavery in any part of the business and requires suppliers to hold the same ethos.

Crucially, we recognise our duties under the Health and Care Act 2022, which places a responsibility on NHS bodies to take steps to eradicate the use of goods and services tainted by slavery and human trafficking.

The Trust is also committed to ensuring that all staff are aware of the Modern Slavery Act 2015 and their safeguarding duty to protect and prevent any further harm and abuse when it is identified or suspected that an individual may be or is at risk of modern slavery and human trafficking.

3. About The Clatterbridge Cancer Centre NHS Foundation Trust

The Clatterbridge Cancer Centre NHS Foundation Trust provides highly specialist cancer care for a population of 2.4 million people across Cheshire and Merseyside, North Wales, the Isle of Man, and parts of Lancashire.

In June 2020, we opened Clatterbridge Cancer Centre - Liverpool, our spectacular new cancer hospital in the heart of Liverpool’s Knowledge Quarter, providing state-of-the-art facilities as part of a £162m investment. Alongside our flagship hospital in Liverpool, we also have two other main cancer centres:

  • Clatterbridge Cancer Centre - Wirral: Providing outpatient cancer treatment and supportive care on the Clatterbridge Health Campus in Bebington, Wirral.
  • Clatterbridge Cancer Centre - Aintree: Our radiotherapy treatment centre on the Aintree University Hospital site.

Together, working across three sites and operating specialist chemotherapy clinics in four of Merseyside's district hospitals, we deliver a comprehensive range of inpatient care, advanced radiotherapy, chemotherapy, and other systemic anti-cancer therapies including gene therapies and immunotherapies.

Our supply chains enable the procurement of a wide range of goods and services on behalf of our clients and service users. These supply chains are extensive and include medical equipment, pharmaceuticals, estates and facilities management, and ICT hardware / software.

4. Our policy on slavery and human trafficking

We are fully aware of the responsibilities we bear towards our service users, employees, and local communities. We are guided by a strict set of ethical values in all our business dealings and expect our suppliers (i.e., all companies we do business with) to adhere to these same principles.

We have zero tolerance for slavery and human trafficking. Staff are expected to report concerns about slavery and human trafficking, and management are expected to act upon them in accordance with our policies and procedures.

Our approach is supported by the following internal policies:

  • Whistleblowing (Freedom to Speak Up) Policy: Encouraging staff to report concerns without fear of reprisal.
  • Safeguarding Adults and Children Policies: Providing mechanisms to identify and protect vulnerable individuals.
  • Equality, Diversity and Human Rights Policy: Ensuring fair treatment for all staff.
  • Procurement Policy: Embedding ethical standards in our buying processes.

5. Due diligence, risk assessment and management

To identify and mitigate the risks of modern slavery and human trafficking in our own business and our supply chain, we undertake the following:

Employment standards

  • Pre-employment checks: Undertake appropriate pre‐employment checks on directly employed staff and agencies on approved frameworks. Agency compliance is audited to provide assurance that pre‐employment clearance has been obtained for agency staff.
  • NHS standards: Adhere to national NHS employment checks / standards. This includes the right to work in the UK, verification of employees’ UK addresses, and factual references.
  • Fair pay and conditions: Implement a range of controls to protect staff from poor treatment and/or exploitation, complying with all respective laws and regulations. These include provision of fair pay rates (Agenda for Change), fair terms and conditions of employment, and equitable access to training and development opportunities.
  • Culture: We are working towards embedding an overarching learning culture throughout the organisation which will underpin our ongoing provision of fair employment terms and conditions.
  • Union engagement: Consult and negotiate with trade unions on proposed changes to contractual terms and conditions and proposals relating to organisational change.

Supply chain and procurement

  • NHS Supply Chain: Purchase a significant number of products through NHS Supply Chain, whose ‘Supplier Code of Conduct’ includes strict provisions around forced labour. We rely on their upstream due diligence for these frameworks.
  • Contractual compliance: Our purchase orders and tender specifications comply with the NHS Standard Terms and Conditions. We ensure that all NHS contracts for the supply of goods and provision of non-clinical services have contractual clauses requiring compliance with the Modern Slavery Act (2015).
  • Social value (PPN 06/20): Include social value criteria evaluation in our tender documents (minimum 10% weighting where appropriate), ensuring appropriate weight is given to modern slavery, human trafficking, and ethical supply chain elements.
  • Government guidance (PPN 02/23): Ensure adherence to the Cabinet Office Procurement Policy Note 02/23 (Tackling Modern Slavery in Government Supply Chains) by identifying and managing risks in new and existing procurement activities using the risk assessment tools provided by the government.
  • Procurement Act 2023: In preparation for and compliance with the new procurement regime, we verify that suppliers are not subject to mandatory debarment grounds, which include convictions for modern slavery offences.
  • Ethical code: Uphold professional codes of conduct and practice relating to procurement and supply, including adherence to sustainable and ethical values as advocated by the Chartered Institute of Procurement and Supply (CIPS).
  • Contract management: Ensure ongoing due diligence through effective contract management and building strong working relationships with suppliers.

Measuring effectiveness

To ensure our steps are effective, we monitor the following key performance indicators (KPIs):

  • Monitoring of actions put in place to review and provide assurance on their effectiveness.
  • Review of any whistleblower referrals regarding modern slavery.
  • Audits of recruitment agency compliance.

6. Training and awareness

Advice and training about modern slavery and human trafficking is available to staff through our safeguarding children and adults training, our safeguarding policies and procedures, and our safeguarding leads.

  • Safeguarding training: As part of our mandatory training, all clinical and front-line staff receive safeguarding training that includes identifying signs of modern slavery and human trafficking (Level 1 to Level 3 depending on role).
  • Recruitment competency: As part of our recruitment process, we consider the extent to which applicants have knowledge of and skills to comply with their obligations to safeguard service users, which includes modern slavery and human trafficking.
  • Procurement training: The Procurement team undertakes specific ethical procurement training (such as the CIPS Ethics Test) to ensure they can identify supply chain risks.

It is extremely important to The Clatterbridge Cancer Centre that all employed staff are supported to recognise signs and indicators of abuse, which includes concerns relating to modern slavery and human trafficking. We have a responsibility as an organisation delivering care and treatment to vulnerable children and adults, and we take this duty very seriously.

The organisation monitors any modern slavery issues through our Safeguarding service and together with partner agencies (such as the Merseyside Safeguarding Adults Board).

7. Board of Directors’ Approval

This statement has been approved by the Trust’s Board of Directors in February 2026 who will continue to support the requirements of this legislation. The Board will review and update the statement on an annual basis.

The statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and describes the steps taken by The Clatterbridge Cancer Centre NHS Foundation Trust (“the Trust”) to ensure that modern slavery and human trafficking are not taking place in our organisation or in our supply chains.

This constitutes The Clatterbridge Cancer Centre NHS Foundation Trust’s slavery and human trafficking statement for the financial year ended 31st March 2026.

Joan Spencer, Chief Executive
4th February 2026