Modern Slavery Statement

HR Strategy

The HR strategy is reviewed annually to ensure it remains relevant. The strategy has the following themes:

  • Continuous improvement (organisation)
  • Continuous personal improvement
  • Effective employee relations and engagement
  • Learning and development
  • Attracting the right people
  • Health and Wellbeing

The following processes and procedures support the Council in meeting the requirements of the Modern Slavery Act.

Employment Policies

The Councils have an ongoing programme to update employment related policies regularly, the policies are introduced in conjunction with the recognised Trade Unions.


South Hams Council recruitment policies are reviewed and updated in conjunction with our recognised Trade Unions. These policies include robust procedures for vetting new employees. It ensures original documents are seen to verify identity and qualifications. It also ensures they are paid directly into an appropriate, personal bank account.

Confidential Reporting Policy

The Council encourages all its staff, customers and other business partners 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. Our organisation's confidential reporting policy is published on our website and designed to make it easy for workers (Council and third parties) to make disclosures. Disclosures can be made without fear of victimisation, subsequent discrimination or disadvantage.

Staff Code of Conduct

South Hams Staff Code of Conduct makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain. The Staff Code of Conduct was last updated in 2019.

Supplier/Procurement Strategy

The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker's working conditions. However, serious violations of the organisation's procurement strategy will lead to the termination of the business relationship.

Agency workers

South Hams Council 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. We use a managed service, provided by Comensura Ltd, who contract out to agencies.

Councillors Code of Conduct

The Council expects all Councillors to demonstrate the highest standards of conduct and behaviour. All Councillors are required to abide by a formal Code of Conduct. Breaches are investigated by the Monitoring Officer or a representative of his/her choice.

Declaration of Interests

We expect all Councillors and employees to record and declare personal and prejudicial interests.

Councillors Induction and Training

Councillors complete induction training which include safeguarding training following election. Further training is offered to all staff and councillors on an ongoing basis through the safeguarding specialist and the Community Safety Partnership.


The Council reviewed and updated the safeguarding policy in November 2020. An internal audit was also completed in 2020 with a "good" outcome. A number of training sessions have taken place for staff. South Hams Council has a safeguarding specialist and three safeguarding champions. The safeguarding specialist regularly meets with other district council colleagues to share best practice of implementation and monitoring of relevant policies and procedures. They also stay up to date with current legislation and to safeguard and promote the welfare of children and vulnerable adults and protect them from harm.

Partnership Working

The Council works in partnership with a wide range of agencies including Devon and Cornwall Police and Devon County Council Social Care teams to prevent neglect and abuse, to detect and report occurrences and to support victims.

Staff Training

Posters will be displayed on staff notice boards across the organisation, detailing where staff can go for help if they become aware of anyone who may be experiencing slavery. There is also further information on the website for staff who regularly work from home. Awareness and information courses are offered regularly to staff, at no cost, through the South Devon and Dartmoor Community Safety Partnership.