Modern Slavery Statement
“Thank you so much for providing the interpreter today. It was a very difficult case of trafficking with a traumatised young person. The interpreter was so sensitive and skilled. She made a real difference.”
[Local Authority Social Worker praising an interpreter provided by HITS]
HITS is implacably opposed to Modern Slavery in all its many forms.
We stand against Human Trafficking, Slavery, Forced Labour and Domestic Servitude and all other types of exploitation.
Our recruitment, employment, purchasing and procurement policies and procedures are designed and implemented to minimise the risk of Modern Slavery.
We are committed to the identification, addressing and reporting of Modern Slavery and all forms of exploitation wherever it is encountered.
WHAT IS MODERN SLAVERY?
Modern Slavery is a collective term which incorporates many types of exploitation, including human trafficking, forced labour, domestic servitude, and slavery. It is an international crime affecting over 40 million people around the world. It has also been estimated that there may be more than 100,000 victims of modern slavery in the UK. This figure includes victims trafficked from overseas and vulnerable people in the UK who are forced illegally to work against their will across many different sectors such as agriculture, hospitality, construction, retail and manufacturing. An estimated 27% of Modern Slavery victims in this country are UK nationals.
The Modern Slavery Act 2015 is designed to tackle slavery in the UK and consolidates previous offences relating to trafficking and slavery.
A person commits and offence of Slavery, servitude and forced or compulsory labour, if:
(a) the person holds another person in slavery or servitude and the circumstances are such that the person knows or ought to know that the other person is held in slavery or servitude, or
(b) the person requires another person to perform forced or compulsory labour and the circumstances are such that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.
Within this Act, an offence of trafficking occurs “if [a] person arranges or facilitates the travel of another person with a view to [that person] being exploited.”
For a detailed examination of Modern Slavery, please refer to the document “A Typology of Modern Slavery Offences in the UK” at www.antislaverycommissioner.co.uk.
The Modern Slavery Act 2015 requires commercial organisations supplying goods or services with a turnover of more than £36 million to prepare and publish an annual ‘Slavery and Human Trafficking Statement’. The Statement must set out the steps the organisation has taken, if any, during its financial year to ensure that slavery or trafficking is not taking place in its supply chain.
Although the requirement to publish an annual Modern Slavery statement does not apply to SMEs, the Home Office advises that such organisations consider creating a Statement.
With the duty to publish a Statement having been extended to public sector bodies, any SME wishing to provide services to the public sector should now expect to be asked to provide formal evidence of practical steps taken to combat Modern Slavery.
Additionally, from January 2021, all Government contracts will include a scoring criterion that measures how bidders deliver social value. Therefore, if a business can demonstrate they meet best practice modern slavery mitigation, they will be highlighting their social value priorities and increase their chances of winning public contracts.
Herts Interpreting & Translation Service (HITS) operates within the registered charity Dacorum Council for Voluntary Services (operating name: Community Action Dacorum). HITS is registered at Companies House as DCVS Trading Ltd (the trading arm of the overall charity).
Dacorum Council for Voluntary Service was formed in 1947 and registered as a charity in 1983. HITS was founded in 2001 and was registered as a trading entity in 2017.
Herts Interpreting & Translation Service (HITS) is one of the largest and most successful independent, non-commercial services in the UK. HITS provides language support services (face-to-face, video and telephone interpreting, written translation, audio recordings, language assessments) for Health Trusts, Local Authorities, Criminal Justice Agencies, non-statutory sector organisations, commercial and private clients throughout the Home Counties, the East of England, Thames Valley, Greater London and beyond.
In addition to our core staff based at our main offices in Hemel Hempstead, we have approximately 800 interpreters, translators and assessors based in the UK.
Our business activities occur almost exclusively within the UK and are subject to all relevant national legislation.
OUR QUALITY STANDARDS AND ACCREDITATIONS
HITS holds the ISO 9001:2015 Quality Standard. This accreditation assures all customers that all work-processes, from initial contact to completion, are governed by rigorously maintained and monitored procedures and accord with all applicable standards. In summary: a guarantee of a wholly professional approach. (Expiry Date: November 2021).
HITS holds the ISO 27001:2017 Quality Standard. This accreditation assures all customers that their invaluable data and information is held securely in a controlled environment and is handled with strict adherence to the principles of Information Security, Data Protection and general confidentiality. (Expiry Date; November 2022).
HITS has been a registered training and examination centre on behalf of the Chartered Institute of Linguists since 2001. Since 2002, HITS has received 10 national awards from the Chartered Institute for the success of its students (including UK Examination Centre of the Year twice and leading UK student in the Health or Local Government examination options on eight occasions).
In addition to the quality standards and accreditations possessed directly by HITS, our managing charity, Dacorum Council for Voluntary Service, holds the Queen’s Award for Voluntary Service, Investors in People accreditation and Cyber Essentials.
Each of the above informs our overall commitment to high-quality and ethically driven provision.
GENERAL RISK ASSESSMENT
As a provider of interpreting and translation services, we do not directly employ or engage with individuals (interpreters and translators) considered to be at the highest risk of exploitation. However, our customers (for example, Local Authorities) may themselves be directly involved with the victims of Modern Slavery and we may be required to assist in interviews or investigations.
In 2019, the Salvation Army issued a warning that human traffickers may be recruiting interpreters for the purpose of re-trafficking victims during face-to-face appointments. This confirmed a risk that HITS had previously identified in consultation with its customers.
To mitigate this identified risk, HITS ensures that all interpreters employed or engaged by our Service are appropriately vetted and that service providers (professionals using interpreting services) are made aware of professional protocols around interpreting and how to report any concerns or suspicions. In addition, we also require external agencies supplying interpreters to HITS to comply with our requirements around the prevention of exploitation.
MITIGATING RISK BY VETTING OF INTERPRETERS
To undertake work on behalf of HITS, an interpreter must:
- Provide proof of their Right to Work (in accordance with the Home Office Right to Work Checklist)
- Provide proof of permanent residence in the UK.
- Provide proof of any relevant qualifications (other than those directly achieved through HITS’ own training and examination department)
- Provide a clear and current DBS check at an enhanced level
- Elect to join the HITS payroll or provide documented proof of a current HMRC registration (including a Unique Tax Reference number)
HITS uses its own in-house payroll to monitor payments to staff, interpreters and translators and external suppliers.
The HITS Payroll Team ensures that payments for interpreters are made only to nominated personal accounts and not to third-party accounts.
HITS will not issue payment to an interpreter or translator via cheque or cash.
RECOGNISING THE SIGNS OF POSSIBLE EXPLOITATION
In addition to the controls applied above, HITS seeks to mitigate the risk of external exploitation of its own workers (staff and interpreters) by a constant awareness of the signs of potential exploitation. These signs include (but are not limited to):
Physical Appearance: In the course of their work, an interpreter may look unkempt, malnourished, or dirty. They could also have signs of physical abuse such as scars, bruises, scratches, or even untreated injuries. They may appear at assignments shabbily or inappropriately attired.
Financial Issues: An interpreter may appear to have little or no money and food or little and unsuitable clothing. They may contact HITS repeatedly for an advance upon their wages or may be regularly unable to attend assignments for want of a bus or rail fare. On one reported occasion, an interpreter (not engaged by HITS) asked a service provider for money to be able to get home after the assignment.
Professional Performance: An interpreter may regularly fail to attend an assignment but be able to offer no valid explanation. They may regularly withdraw from assignments at the very last moment citing personal reasons or even no reasons at all. They may appear unusually distracted or unengaged during an assignment or behave in an inappropriately aggressive or agitated manner.
Isolation and Control: An interpreter may appear to be rarely left alone and could seem to be under the control of someone else who is always speaking on their behalf. This person may regularly answer their mobile phone or contact HITS continually on their behalf. They may be driven to and from assignments by this person.
The above signs may not necessarily be an indication of an incidence of Modern Slavery but could be reasons for general concern. HITS prides itself on its close relationship with its interpreters and exercises an ongoing Duty of Care in addition to measures designed to identify possible cases of Modern Slavery.
HITS encourages feedback from its customers with regard to the above and will act promptly and appropriately upon any such feedback.
These observations are extended to the training courses delivered by HITS, where it may be possible to observe a trainee over a significant period.
MITIGATING RISK WITHIN OUR SUPPLY CHAIN
Cost pressures may compel some suppliers to look overseas for telephone and video interpreters and the translation of written materials. This will result in lower costs but also lower quality control and a lack of transparency and accountability. Such unethical processes will also serve to denude the UK-based stock of skilled interpreters and translators.
For these reasons, as a point of principle, HITS does not engage interpreters or translators based outside the UK.
HITS also does not formally sub-contract language support services from external agencies or other suppliers. However, on occasion, we may be required to approach a specialist agency for a service not available within our own resources (in particular, with regard to very rare or uncommon languages).
In such circumstances, we will require the agency to complete an External Agency Interpreter Confirmation Form. In addition to information pertaining to the booking, the agency will be asked to confirm the following:
- The Qualification level of the Interpreter
- That the interpreter’s Right to Work has been established
- That a clear and recent DBS check is held by Interpreter at the legally mandated level (Enhanced)
- That the agency has taken all reasonable steps to ensure that the interpreter will pay all due taxes on their interpreting work
It should be understood by potential customers that on occasion HITS may have to decline to provide a service when the above required assurances cannot be provided.
On occasion, HITS may also engage an individual external linguist for a ‘one-off’ project. In such circumstances, HITS will source an external linguist only from recognised professional registers or associations (for example, the National Register of Public Service Interpreters or the Chartered Institute of Linguists).
PURCHASING & PROCUREMENT
In addition to the conditions detailed above, pertaining to the engagement of interpreters or translators or the use of external agencies, the following general purchasing principles are also applied:
HITS will only purchase goods and services from legitimate traders and companies.
HITS will not knowingly purchase goods that are counterfeit (for example, computer software) or of uncertain provenance.
All goods and services purchased by HITS will be itemised and traceable through official receipts or invoices.
In matters of significant expenditure, a rigorous procurement process will be followed, and formal quotes will be invited from at least three suppliers.
MEASURING THE EFFECTIVENESS OF MITIGATION
The following Key Performance Indicators have been established by HITS to measure the effectiveness of the steps being taken to combat Modern Slavery:
- 100% adherence to published vetting requirements for HITS interpreters.
- 100% adherence to published vetting requirements for external agencies.
- Continual monitoring of above and immediate action to be taken in cases of non-compliance.
- At least one training event per year dedicated to Modern Slavery and related issues.
- All reported incidents to be logged via established processes detailed in the HITS Quality Manual.
- To provide professional support to customers in their own direct interaction with Modern Slavery scenarios
- To embed understanding of Modern Slavery issues at every level of HITS (including the booking, finance, and management teams, as well as interpreters)
- Modern Slavery Statement to be updated on annual basis.
All issues concerning Modern Slavery should be referred to the HITS Head of Service, Ian McKenzie. In his absence, please contact Fatima Ikram, HITS Head of Booking and HR.
This statement was prepared by Ian McKenzie, HITS Head of Service. [Updated July 2021]
HITS is Cabinet Office Modern Slavery assessed (with full compliance in Governance, Policies and Procedures, Risk Assessment & Management, Due Diligence, Training and KPIs).