On 1 April 2023, new PPN 02/23 (replacing PPN 05/19) will apply to all in-scope organisations, including all Central Government departments and NHS bodies, prescribing certain actions for dealing with the risks of modern slavery in existing contracts and in all new procurements.
PPN 02/23 identifies 4 key areas of activity:
- Identifying and managing risks in new procurements;
- Assessing existing contracts;
- Taking action when victims of modern slavery are identified; and
- Training, to raise awareness of modern slavery.
The guidance prescribes a risk based and proportional approach which is consistent with previous requirements. There is however a new focus on market engagement to identify risk and allow authorities to design properly targeted and appropriate selection and award criteria, that are sufficiently robust but which do not represent unnecessary barriers for SMEs. There are also some enhanced obligations for those procurements deemed “high” risk in respect of modern slavery, including obtaining self-declarations for all supply chain members at selection stage and specimen clauses for inclusion into affected contracts.
The changes are clearly of interest to authorities responsible for implementing them but also for bidders, providing useful information on additional scrutiny required in relation to supply chains.
PPN 02/23 can be found here.
For further information, please contact:
Lucy Probert, Hill Dickinson
lucy.probert@hilldickinson.com
