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Public alignment statement

PPN 009 Tackling Modern Slavery

Episodic ICCE recognises PPN 009 - Tackling Modern Slavery in Government Supply Chains as a significant procurement and contract-management source for identifying and managing modern-slavery risk in public supply chains. The source sets expectations for risk-based assessment, supply-chain visibility, proportionate market engagement, supplier information, due diligence, contractual controls, monitoring, audit, remediation, training, safeguarding and worker-sensitive response.

Those expectations are especially relevant to temporary labour because construction, agency work, complex labour chains and low-visibility worker arrangements are recognised risk characteristics. For temporary-labour activity, this creates a clear need for reliable evidence showing who was engaged, through which route, under what employment and payroll treatment, with what hours, pay, deduction, payment, grievance, exception, correction, remediation and audit history. That evidence can support authorised risk assessment and contract monitoring, but it cannot prove that exploitation is absent and must never delay emergency, safeguarding, law-enforcement or victim-support action.

ICCE aligns with PPN 009 as a Collaborative Procurement-Support Provider for ICCE-routed temporary-labour activity. It supports authorised contracting authorities, suppliers, contractors, procurement teams, framework providers, contract managers, responsible-procurement functions, modern-slavery risk owners and auditors by preserving controlled labour-chain evidence relevant to worker route, counterparty attribution, supply-chain coverage, pay, payment, challenge, exception, remediation and audit lineage. ICCE does not identify victims, investigate offences, conduct human-rights due diligence, perform the Anti-slavery Risk Tiering Tool or Modern Slavery Assessment Tool, determine exclusion, make safeguarding or referral decisions, certify compliance or certify a modern-slavery-free supply chain.

Episodic maintains a continued alignment commitment by reviewing this statement where PPN 009, associated guidance, Anti-slavery Risk Tiering Tool material, Modern Slavery Assessment Tool context, legacy PPN 02/23 position, Procurement Act exclusion context, safeguarding practice, UMS-505 procurement-support outputs or ICCE-routed evidence controls are amended, replaced, superseded or materially clarified.

Alignment table

Expectation Relevant sources ICCE enforced alignment ICCE evidence / output
Scope, applicability and policy-context control Domain 1 - scope, applicability, timing and legacy arrangements ICCE preserves externally supplied PPN applicability, procurement context, contract reference, risk owner and reporting-period evidence while keeping legal and policy applicability external Procurement-context record, contract identifier, PPN reference, reporting-period record, legacy-position limitation
Risk tiering and risk-relevant labour evidence Domains 2 and 3 - risk-based approach, ARTT and risk characteristics ICCE preserves worker-route, temporary-labour, agency, hours, pay, deduction, dispute, grievance, exception and chain evidence capable of supporting external risk assessment Worker-route evidence, counterparty attribution, hours and pay evidence, exception record, external risk-tier reference
Proportionality and market-engagement support Domains 4 and 5 - proportionality, SME/VCSE participation and preliminary market engagement ICCE supports proportionate evidence release by distinguishing source population, coverage, missing evidence and limitation, while buyer-led engagement and proportionality decisions remain external Evidence coverage statement, recipient-specific release record, unsupported-evidence statement, capability and limitation profile
Specification, social-value and tender support Domains 6 and 11 - specification, Social Value Model treatment, tender assessment and award ICCE provides worker-route, pay, grievance, due-diligence, remediation and contract-selected metric evidence relevant to buyer-defined PPN 009 or PPN 002 modern-slavery requirements Worker outcome evidence, supply-chain evidence, contract KPI pack, supplier-commitment reference, tender-evaluation boundary
High-risk supply-chain information and mapping Domains 7 and 14 - high-risk supply-chain information, self-declarations and supply-chain mapping ICCE preserves recognised engager, agency, counterparty, worker, activity and contract-context evidence for ICCE-routed labour while identifying known gaps and external tiers Responsible-supply-chain visibility pack, counterparty register, chain-coverage record, external identifier, missing-tier limitation
Exclusions, due diligence and participation conditions Domains 8, 9 and 10 - exclusion grounds, enhanced due diligence, self-cleaning, conditions of participation and modern-slavery statements ICCE preserves external exclusion, debarment, statement, source and remediation references alongside ICCE-side labour evidence, without determining statutory exclusion or supplier technical ability External status reference, restriction record, due-diligence evidence pack, remediation chronology, no-exclusion-decision statement
Contract terms, action plans and existing-contract management Domains 12 and 13 - contract terms, information rights, action plans, subcontractor controls and existing contracts ICCE preserves contract-context, clause-reference, counterparty, worker, payroll, exception, action-plan, corrective-action and release evidence supporting externally governed contract management Contract reference, action-plan record, corrective-action milestone, worker correction evidence, periodic monitoring output
KPIs, reassessment and external assurance tools Domains 15 and 16 - KPIs, management information, reassessment, MSAT and external assurance tools ICCE preserves recurring labour metrics, external target references, chain changes, exception trends and external tool references while keeping risk reassessment and MSAT or ARTT outputs external KPI pack, management-information output, external MSAT or ARTT reference, reassessment evidence, limitation statement
Audits, site visits and worker-sensitive verification Domain 17 - audits, site visits and worker-sensitive verification ICCE provides auditable worker, route, hours, pay, deduction, payment, grievance and correction evidence to support properly governed external audits, without replacing worker interviews or site verification Audit evidence pack, population and sampling support, external audit reference, corrective-action record, restricted evidence controls
Suspected victims, safeguarding and immediate response Domain 18 - suspected or identified victims, safeguarding, referral and immediate response ICCE preserves tightly restricted incident, escalation, referral-reference and ICCE-side action evidence while keeping victim identification, safeguarding, law enforcement and referral authority external Restricted incident record, escalation timestamp, authorised referral reference, worker-protection status, disclosure limitation
Remediation and corrective action Domain 19 - remediation, corrective action, collaboration and termination as last resort ICCE preserves action plans, responsible parties, milestones, worker-related corrections, counterparty restrictions, follow-up evidence and closure status without deciding human remedy or termination Remediation chronology, payroll or access correction, counterparty action record, follow-up evidence, external closure reference
Training, awareness and capability boundary Domain 20 - training, awareness and organisational capability ICCE may preserve externally verified training evidence and provides system-specific guidance, while substantive modern-slavery, human-rights and safeguarding competence remains external External training reference, role-specific access record, system guidance acknowledgement, capability limitation
No absence, compliance or certification claim PPN 009 naming and claim controls; safeguarding and evidence-boundary rules ICCE preserves that UPS-AS-006 is an alignment and evidence-support statement, not a compliance certificate, investigation, victim-identification decision or zero-risk assurance No-absence statement, no-certification statement, no-investigation statement, risk-evidence boundary, public wording control

Sources covered

Principal source set

Lifecycle and evidence domains covered

Publisher
Augscape Research & Development Limited, trading through the Episodic ICCE documentation surface.

Company number
12996074

Website
episodic.co.uk

Document status
Public alignment statement · 2.1

Publication date
10 July 2026

Use boundary
General information only. Not legal, tax, financial, insurance, employment or investment advice.