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Equality, Inclusion and Human Rights

The Public Sector Equality Duty (PSED) of the Equality Act 2010 requires the ICB to have due regard to the need to eliminate discrimination, harassment and victimisation, advance equality of opportunity and foster good relations. These are often referred to as the three general aims of the PSED. Having due regard requires the ICB to consider removing or minimising disadvantages, taking steps to meet people’s needs, tackling prejudice, and promoting understanding. In addition, we must publish equality information annually; demonstrating how we have met the general aims of the public sector equality duty and prepare and publish one or more equality objectives at least every four years.

The ICB recognises and values the diverse needs of the population we serve, and we are committed to reducing health inequalities and improving the equality of health outcomes for local people. We are committed to embedding equality and diversity considerations into all aspects of our work, including policy development, commissioning processes and employment practices. We recognise that equality is about ensuring that access to opportunities is available to all and that no one should have poorer life chances because of the way they were born, where they come from, what they believe, or whether they have a disability. We believe that diversity is about recognising and valuing differences by being inclusive, regardless of age, disability, gender re- assignment, marriage or civil partnership status, pregnancy and maternity, race, religion or belief, sex, or sexual orientation.

We are committed to:

  • Improving equality of access to health services and health outcomes for the diverse population we serve.
  • Building and maintaining a diverse, culturally competent ICB workforce, supported by an inclusive leadership team.
  • Creating and maintaining an environment where dignity, understanding and mutual respect, free from prejudice and discrimination, is experienced by all and where patients and staff feel able to challenge discrimination and unacceptable behaviour.

You can read more about how we deliver against these commitments in our Annual Equality Assurance Report which will be published at the end of the financial year.

Gender Pay Gap

It is now mandatory for organisations with 250 or more employees to report annually on their gender pay gap. NHS organisations are covered by the Equality Act 2010 (Specific Duties and Public Authorities) Regulations 2017.

The report demonstrates the difference between the average earnings of men and women who are directly employed, engaged by, either via agency or contracts for service by the ICB. Some self-employed individuals may also be included in the report if the ICB requires them as individuals to carry out the required work.

Reporting is on the basis of information captured on a snapshot date each year. For NHS organisations this is 31 March, with organisations required to publish their gender pay gap information by 30 March of the following year.

The Gender Pay Gap Report for the ICB will be published on 30 March 2024.

Modern Slavery and Human Trafficking Statement

This statement comprises the slavery and human trafficking statement of Nottingham and Nottinghamshire ICB (the organisation) for the financial year ending 31st March 2023 in accordance with Section 54, Part 6 of the Modern Slavery Act 2015. The organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking and is absolutely committed to preventing slavery and human trafficking in its corporate activities.

Click here to read our statement

Definition of Offences

Modern day slavery, servitude, forced or compulsory labour

A person commits an offence if 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
  • requires another person to perform forced or compulsory labour and the circumstances are such that that the person knows or ought to know that the other person is being required to perform forced or compulsory labour.

Human trafficking

A person commits an offence if:

  • the person arranges or facilitates the travel of another person (victim) with a view to being exploited
  • it is irrelevant whether the victim consents to travel and whether the victim is an adult or a child.


A person is exploited if one or more of the following issues are identified in relation to the victim:

  • slavery, servitude, forced or compulsory labour
  • sexual exploitation
  • removal of organs
  • securing services by force, threats, and deception
  • securing services from children, young people, and vulnerable persons.

Organisational Structure

As an authorised statutory body, the ICB is the lead commissioner for health care services (including acute, community, mental health, and primary care) in Nottingham and Nottinghamshire. We are committed to ensuring that there is no modern slavery or human trafficking in any part of our business activity and in so far as is possible to holding our suppliers to account to do likewise.

Our approach

Our overall approach is governed by compliance with legislative and regulatory requirements and the maintenance and development of best practice in the fields of contracting and employment. The ICB recognises safeguarding as a high priority for the organisation. To achieve this, we ensure that we have arrangements in place to provide strong leadership, vision, and direction for safeguarding. We make sure we have clear accessible policies and procedures in line with relevant legislation, statutory guidance, and best practice

The organisational structure, business, and supply chain

We have a clear line of accountability for safeguarding within the ICB. The ICB’s Chief Executive has ultimate accountability for ensuring that the health contribution to safeguarding and promoting the welfare of children and adults is discharged effectively across the whole health economy through commissioning arrangements. The Director of Nursing is the ICB’s executive lead for safeguarding and has responsibility for providing leadership and gaining assurance in relation to safeguarding issues within the ICB. The ICB employs the expertise of Designated professionals for both children and adults. These roles are an integral part of the ICB’s activity and support the delivery of the safeguarding adult and children’s agenda.


The ICB ensures that organisations commissioned to provide services have appropriate systems that safeguard children in line with section 11 of the Children Act (2004) and Working Together to Safeguard Children (2018), and adults in line with The Mental Capacity Act 2005, The Care Act 2014, and The Modern Slavery Act 2015. 

Business and supply chains

The ICB is committed to ensuring that there is no Modern Slavery or Human Trafficking in our supply chains or in any part of our business. Safe recruitment principles are adhered to which includes strict requirements in respect of identity checks, work permits and criminal records. The pay structure is derived from national collective agreements and is based on equal pay principles with rates of pay that are nationally determined. Systems are in place to encourage the reporting of concerns and through the Freedom to Speak Up Guardian.

With regards to providers and supply chains, we expect these entities to have suitable anti-slavery and human trafficking policies and processes in place. We will use our routine contract management meetings with major providers to hold them explicitly to account for compliance with the Act and we will implement any relevant clauses contained within the Standard NHS Contract.

Contracting with providers is a core function of the ICB

The ICB is committed to social and environmental responsibility and has zero tolerance for Modern Slavery and Human Trafficking. Any identified concerns regarding Modern Slavery and Human Trafficking would be escalated as part of the organisational safeguarding process and in conjunction with partner agencies, such as the Local Authority and Police.

All our contracting and commissioning staff are suitably qualified and experienced in managing healthcare contracts and will receive appropriate briefings on the requirements of the Modern Slavery Act 2015 (the Act). We undertake due diligence when considering taking on new suppliers, and regularly review our existing suppliers.

Ensuring that Slavery and Human Trafficking is not taking place in its business or supply chains

The ICB aims to be as effective as possible in ensuring that modern slavery and Human Trafficking is not taking place in any part of our business or supply chains by:

  • Effective interagency working with local authorities, the police and third sector organisations which includes appropriate arrangements for preventing and responding to modern slavery and Human Trafficking.
  • Signing up to the multi-agency policy and procedures for the protection of adults with care and support needs.
  • Undertaking robust NHS employment checks and payroll systems.
  • Ensuring good communication through contract management meetings, with our commissioned providers in the supply chain and their understanding of, and compliance with, our expectations in relation to the NHS terms and conditions. These conditions relate to issues including bribery, slavery, and other ethical considerations.

Staff training about Slavery and Human Trafficking

Slavery and Human Trafficking is part of the organisation’s Mandatory Safeguarding Children and Adults training programme.

This statement is made pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our organisation’s modern slavery and human trafficking statement for the current financial year.

Freedom to speak up Guardian

Jon Towler
Jon Towler – Freedom to Speak Up Guardian

The Freedom to Speak Up Guardian is in place to provide an independent and impartial source of advice to staff at any stage of raising a concern.

This role supports the  organisation in becoming a more open and transparent place to work, where all staff are actively encouraged and enabled to speak up safely.

For more information regarding the role of the Freedom to Speak Guardian please see the ICB’s Standards of Business Conduct Policy

Officers may also wish to report concerns using the ICB’s Raising Concerns (Whistleblowing) Policy.

The above policies can be found in the “Our Policies” section of the website here