Modern Slavery Statement
This Modern Slavery and Human Trafficking Statement (this ‘Statement’) will be reviewed and updated on an annual basis by the Executive Director – Resources. In the case of any minor changes, this Statement will be presented for approval to the Executive Leadership Team. However, as a minimum, this Statement will be presented for re-approval to the Liverpool City Region Combined Authority every five years or earlier, if there is a significant change in relevant legislation and its associated obligations.
Voluntary Slavery and Human Trafficking Statement
This Statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the ‘Act’) and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015. This Statement is published by Liverpool City Region Combined Authority, Merseytravel and on behalf of its subsidiary companies (‘we’, ‘us’, ‘our’, ‘Organisation’). This is our statement for the financial year ending 31 March 2026 and sets out the steps we have taken and will take to identify modern slavery, to ensure it is not occurring in the Organisation and to reduce to the absolute minimum the risk of modern slavery occurring elsewhere in its supply chains.
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.
We oppose slavery and human trafficking in all its forms. This Statement sets out the steps we have taken to date and sets out the ongoing work we are carrying out in 2025-2026 to understand more about the potential modern slavery risks within our Organisation’s structure and supply chains, as well as the steps taken to eradicate these risks. Last year’s steps included establishing an internal Working Task and Finish Group to be responsible for progressing the actions set out in the previous Statement and reporting on progress in our next statement. The Working Task and Finish Group was created and the same Group are involved in the creation of this year’s Statement.
About Us
Liverpool City Region has a population of approximately 1.6 million, which has seen growth of 3% since 2011 (Census 2021 data). The City Region has experienced a period of significant regeneration and economic growth since 2000, which whilst very welcome, also contributes to the conditions where modern slavery can enter supply chains.
At the time of writing, Liverpool City Region Combined Authority is led by Metro Mayor Steve Rotheram with the elected Mayor of Liverpool and the leaders of Halton, Knowsley, St Helens, Sefton and Wirral councils. It is a public body created as the result of a ‘Devolution Deal’ with central government, with the intention of bringing powers and funding back to the City Region to improve the quality and responsiveness of decision making and local accountability. Merseytravel is the strategic transport advisor to the Liverpool City Region Combined Authority and is also responsible, on its behalf, for transport delivery.
The Organisation delivers impact in the communities of the City Region by making investments in transport infrastructure, skills, culture, digital and housing, as well as delivering services and programmes for public transport, homelessness, adult education and employment. Currently, 1,129 staff are directly employed by the Liverpool City Region Combined Authority.
At the time of writing, public bodies are not required to make a modern slavery statement under section 54 of the Modern Slavery Act 2015. However, we will continue to make this voluntary statement to show our commitment to ethical trading principles and to set out the steps we are taking to identify risks and tackle modern slavery and human trafficking in our business and in our supply chains.
Our Mission
Fairness and Social Justice are at the core of our mission, hence the commitment to tackling the injustice of modern slavery. We also acknowledge it is our duty to ensure that taxpayers’ money is not inadvertently funding criminal activity and the misery it creates, and to protect vulnerable workers both in the UK and elsewhere. We recognise that modern slavery is a regional issue and our action plan for this year will continue to look at what we can do to help eliminate slavery and human trafficking within our regions.
We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our relationships. We have implemented and will continue to enforce effective systems and controls to identify and reduce the risk of modern slavery occurring in our own business or in any of our supply chains.
We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our tender and procurement processes, we have introduced and trained our Legal, Procurement and Commercial teams on specific prohibitions in our standard supplier contracts against the use of forced, compulsory or trafficked labour or anyone held in slavery or servitude, whether adults or children, and we expect our suppliers to hold their own suppliers to the same high standards.
Last year, we worked with Procurement and Social Value Teams on a new Monitoring Questionnaire that we sent to winning bidders in our tenders. We asked before we entered into a contract with a supplier for its approach on modern slavery, asking if its organisation publishes an annual Modern Slavery Statement, voluntary or otherwise. We stated that we encouraged Suppliers to outline their approach to preventing modern slavery within their business and supply chains. We also asked if an organisation or anyone in an organisation has been convicted of any offence involving slavery and human trafficking or been (or are) the subject of any investigation, inquiry or enforcement proceedings regarding any offence or alleged offence of or in connection with slavery and human trafficking within the last five years. Affirmative answers warranted further enquiry and a conviction or ongoing investigation specific to modern slavery or human trafficking means that bidder will not be able to supply to Liverpool City Region Combined Authority. However, this version of the questionnaire is now out of date and the Organisation is working on creating and embedding a new template based on the new Procurement Act 2023 which replaces supplier selection and exclusion requirements with new rules on conditions of participation and exclusion. Work this year will involve continually looking at contracts due for renewals, other procurement, with specific work already ongoing with departments such as Transport and our Operators.
Our Fair Employment Charter (the ‘Charter’) was launched in 2021, striving to make our region the fairest, most equitable place in the country to work or run a business. Internally and across the City Region we are trying to make sure we all do the right thing: pay the Real Living Wage, clamp down on the insecure work or zero hours contracts, offer a real seat at the table to trade unions and give staff opportunities to progress and thrive. The Charter was developed in partnership with over 300 local employers of all sizes, trade unions and workers and is designed to promote businesses who offer secure, properly paid jobs and treat staff well. The ultimate aim of the Charter is to identify and support organisations to implement fair and safe employment practices across the region and celebrate them accordingly, and to build the broader movement of employers to encourage and embed fair employment practices within the City Region.
Policies
Our annually updated Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships, to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains. We also have the following internal policies in place relevant to modern slavery, which we continuously review and update:
Due diligence and risk assessment
To help identify and monitor the risk of slavery and human trafficking in our supply chain we reviewed our procurement practices in line with Government guidance on tackling modern slavery in government supply chains (reference PPN 02/23). The guidance is aimed at procurement and commercial practitioners at all levels who are operating in government, but the contents can be applied by any organisation in the public sector.
As above, part of our review included updating our tender, procurement and grant agreements with anti-slavery and human trafficking provisions with suppliers and grant recipients. We raise awareness and support potential suppliers or applicants from the outset by enquiring about their anti-slavery and human trafficking practices before we enter into a contractual relationship with them. As part of this on-going work, we are continuing to map high risk goods and services agreements with our existing suppliers and grant recipients by raising awareness and supporting any modern slavery concerns. Last year, Senior Leadership Team were trained in raising awareness of our Modern Slavery Policy and internal teams have come forward requesting support for issues relevant to each of their working and operational areas. We continue to work with internal colleagues and share the work with our external partners. Externally, we have built excellent relationships with a wide range of agencies, including Changing Lives and Merseyside Police, who have delivered joint training to our Homelessness, Households into Work and Transport Teams. We continue to work with the Merseyside Police & Crime Commissioner through the Liverpool City Region Combined Authority’s membership of the Merseyside Police & Crime Commissioner Modern Slavery Network. Two members of staff attend the Network meetings which have proved an invaluable opportunity to develop valuable partnerships across the Region. Staff have volunteered at the Police & Crime Commissioner’s Anti-Modern Slavery Events such as the Freedom Bus which toured the Liverpool City Region and likewise, Merseyside’ Police & Crime Commissioner staff have kindly volunteered their time and helped with the Liverpool City Region Adult Safeguarding week in October 2024.
Our Safeguarding and Legal Team continue to work closely with our Housing First and Homelessness Commissioning Team to work with existing Police contacts in relation to reducing modern slavery within our existing projects, in particular, in relation to the rising issue of cuckooing in our City Region and how to recognise the signs. We have supported the Police with materials designed for vulnerable people and the public to educate around cuckooing. We will continue to review new legislation in relation to modern slavery, in particular The Crime and Policing Bill; proposed landmark legislation to bring forward the ban of cuckooing, a highly exploitative practice where criminals seize control of a vulnerable person’s home without consent to conduct illegal activities like drug dealing. There are different types of cuckooing:
The most common form of cuckooing is when a person’s home is taken over to distribute drugs, the person’s property is taken as a place to live and the property is taken over to financially abuse the tenant.
Cuckooing often begins when the vulnerable adult is befriended by those that want to take over the property. The vulnerable adult may be offered something, this could be a relationship, friendship, drugs and/ or alcohol, money or clothing.
Previous incidents of cuckooing have been identified by our Housing First Service. Our Housing First Team have had specific training in relation to recognising signs, reporting and wellbeing support for our staff working in these areas. Ongoing risks have been identified as service users tend to be more vulnerable and have multiple support needs than others in the community and are therefore targeted when they are given a new tenancy. We currently work with adult social care, Police and housing associations to support the service user and stop the cuckooing as soon as the Housing First Team have any concerns.
Effectiveness in combatting slavery and human trafficking
We are and still intend to use the following key performance indicators (KPIs) to measure how effective we have been at ensuring that slavery and human trafficking is not taking place in our Organisation, our services or supply chains:
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our Organisation, we have and will continue to provide training to all staff. We are in the process of creating a bespoke training module with our Learning and Development Team specifically to cover modern slavery and human trafficking; linking into our internal Modern Slavery Policy, as additional practical, guidance to our employees on where to report concerns and seek help. Since our last Modern Slavery Statement, all employees are required to complete mandatory Level 1 safeguarding training which includes identifying signs of modern slavery prevention. There are also plans for refresher training and we will seek to implement any additional enhanced Government recommended training for employees involved in procurement decisions and procedures.
Further steps
Following a review of the steps we took in 2024/2025 to identify and eliminate slavery or human trafficking in our supply chains, we intend to take the following further steps in 2025/2026 to combat slavery and human trafficking:
Over the course of the next year, we intend to:
Reporting Concerns
If anyone suspects modern slavery or human trafficking
If an employee or anyone suspects workers are being subjected to modern slavery or receives an anonymous ‘tip-off’, they should involve law enforcement agencies:
In cases of suspected child labour exploitation in the UK, Local Authority Children’s Services and the Police should be notified immediately by dialling 999.
For internal employees, please refer to the internal reporting advice in our Modern Slavery Policy.
This voluntary modern slavery and human trafficking statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes the Liverpool City Region Combined Authority’s and Merseytravel’s modern slavery and human trafficking statement for the financial year ending 31 March 2026. This statement was previously approved by the Liverpool City Region Combined Authority on 15 March 2024.
We are committed to reviewing and refreshing this Statement on an annual basis.
