Agreed We will continue to work openly with the Home Office to manage this issue.

Lampard Report Recommendations We welcome the work undertaken by Kate Lampard, and her team, and their diligence and professionalism. We would like to thank them for the way they have dealt with the staff, residents and other key stakeholders. We take our responsibilities for the running of Yarl s Wood extremely seriously and have reviewed the report in detail. Our response to the recommendations is set out below. Many of the recommendations made have already been implemented and those that remain to be actioned will be done so as soon as possible. Recommendation R1 Serco should monitor the numbers of Time Served Foreign National Offenders (TSFNO) detained at Yarl s Wood, and the impact their presence has on the good order of the centre and the safety and security of others. Serco should consult regularly with the Home Office to ensure that only those who do not threaten good order, safety and security are detained at Yarl s Wood. (Within three R2 Serco should continue to press the Home Office to improve the quality and timeliness of information-sharing about TSFNO transferred to Yarl s Wood. (Within three R3 Serco should consider with the Home Office the development of suitability criteria for the detention of TSFNO at Yarl s Wood. (Within three R4 Serco should consider with the Home Office whether the escort service can take responsibility for ensuring that residents are presented to Home Office Serco Response / Action to be taken Agreed - We monitor all TSFNOs on a daily basis and this figure is reported to the Home Office. The Home Office is informed when a TSFNO demonstrates negative and challenging behaviour that threatens the good order of the Centre. There are several recent examples when TSFNOs have been transferred to either another Immigration Removal Centre or prison as a result of poor behaviour. Ultimately the decision on who should or should not be sent to Yarl s Wood belongs to the Home Office. Agreed We will continue to work openly with the Home Office to manage this issue. Agreed - We will discuss with the Home Office, but the policy around who is or is not suitable for detention lies with them. Not Agreed - Our strong view is that greater risks would be faced by introducing a third party into the process of removal within the Centre. Our staff have built rapport with the 1

Immigration Enforcement for removal. This would include escorting residents from their room in Yarl s Wood. (Within three R5 Managers at Yarl s Wood should put in place a programme of organisational development work involving all staff, to develop a clearer and better shared understanding of the centre s mission, role and purpose, and the cultures and arrangements, including staffing arrangements, that will ensure the appropriate care of Yarl s Wood s residents. Such a programme should allow staff to share their insights and engage them in devising plans for how the centre will be managed in the best interests of residents and staff. (Within three R6 Managers should review the Centre s policies, its recruitment, training and appraisal arrangements and the regime at the Centre to ensure they are consistent with its mission, role and purpose. (Within three residents and it is our opinion that the introduction of a third party would raise the anxiety of the residents and make an already stressful experience even more so. Agreed. The management team shares with staff the vision and major issues that do impact or are likely to impact on the lives of residents and staff within the centre, and we encourage their input. For example, in the last year staff had a valuable input into the following: Opening freedom of movement around the centre for residents Introduction of the post room Development of the Care Suite Developing and introducing a new shift pattern that improves the operation of the Centre, including interaction with residents and time set aside for professional development We will be re-energising the employee partnership forum and we have also started setting up a team to deal with the recent staff engagement survey, which a number of staff have volunteered to be on. Agreed We are reviewing recruitment in terms of how we select suitable candidates to work in the Centre. Training has and continues to be reviewed and specialist modules covering - safeguarding, human trafficking, professional standards, mental health, Female Genital Mutilation and understanding the needs of asylum seekers - have been introduced. This is for the initial officer training course currently running and will also be rolled out to existing staff. Although there is some commonalities between the training given to our prison officers and that of detention officers at Yarls Wood we will ensure that centre specific training is also given. 2

R7 Managers should review the appraisal process and ensure that those who undertake appraisals have the time, training and support they need to appraise staff in a robust and meaningful way. (Within three R8 Managers should undertake a review of present local policies and arrangements for whistle blowing and reporting matters of concern. They should devise policies and arrangements that are easily understood by staff, command the confidence of staff and encourage and support them to report colleagues whose behaviours are inappropriate or below standard. (Within six R9 Managers undertaking the current staffing review should address the question of how staff can best be given time to engage with residents and meet their emotional as well as practical needs. (Urgent) R10 Managers undertaking the current review of staffing should rectify the problems with management capacity. (Urgent) R11 Managers should undertake an audit and assessment of the roles that only female staff should Agreed - The appraisal process implemented is the Serco standard process. Managers will be retrained in conducting appraisals and time set aside to ensure they are carried out effectively. Completed - As per HMCIP recommendation, we have removed the local whistleblowing policy and adhere to the Serco wide Speak Up policy. The policy is publicised on the Intranet and on posters around the Centre. Senior management are continually reminding staff of the standards and behaviours we expect from all personnel. Staff are also encouraged to report inappropriate behaviour and are given reassurance that they can do so without fear of any reprisals. Professional Standards training is delivered to all new officers and the Centre Manager will be meeting with all candidates on future courses to have a discussion around professional standards and whistleblowing. We will also ensure that we produce a simplified version of the guidance that can be made available to the staff on site. Agreed All staff are encouraged to engage effectively with residents and understand that this a core part of their role. We supplement staff engagement via the use of other parties such as local charities who can come in and act as listening services. There are also faith representatives at the Centre who fulfil some of these needs. We will ensure that the importance of the engagement of staff with residents is reinforced and will keep it under review. Completed - A new Assistant Director post has been agreed and the recruitment process has been completed. The new Assistant Director will start in February 2016. Agreed - The number of female staff has increased as a proportion of overall staffing (55%). It may not be practical or achievable to have some tasks only undertaken by a 3

undertake and how many female staff are required at Yarl s Wood to answer the needs of residents. Managers should develop a staffing plan, based on that audit and assessment. (Within three R12 Managers undertaking the current staffing review should in particular consider and address weaknesses in the night time staffing arrangements. (Urgent) R13 Managers should review policy and procedure in relation to entering residents rooms and interviews with and checks on residents, particularly at night, to ensure that interviews and checks are undertaken as thoroughly as necessary and in a consistent manner by all staff. (Within three R14 Managers should review staff handover arrangements as a matter of urgency. (Urgent) R15 Managers should closely monitor standards of cleaning throughout the Centre. (Within three female member of staff but we will review what the staffing profile would look like if some tasks were designated female only. We continue to recruit predominantly female staff (8 of the 11 students on the current training course are female). Completed The night time staffing profile has also been reviewed as part of the Workforce Management Project and the night time staffing level has subsequently increased. The new staffing profiles are being implemented to begin in January 2016. Management also run a staff forum which gives staff members the opportunity to raise and discuss any issues they have with any matter pertaining to the centre. Agreed - This will be done as part of the policy review. Routine searching of rooms has ceased and only female staff carry out intelligence led searching which is rare. Management continues to reinforce the procedures for entering a resident s room. We are currently working on a programme that allows roll counts to be managed via a biometric system rather than having a member of staff physically checking that a resident is in a room. Agreed Handover sessions were embedded as part of the new shift pattern agreed with staff and should now be taking place on a consistent basis. Handovers will be continuously monitored to ensure their effectiveness. Handover books are in place. New shift patterns which allow greater time for handover have been introduced in January 2016 as part of the overall staffing review. Agreed - Standards are monitored but we will look again and ensure that they are maintained. We meet with the Home Office and IMB regularly. Moreover, the Home Office Estates Manager audits the Centre monthly and routinely comments about the high standards of cleanliness. HMCIP stated most rooms were clean 4

R16 Managers should continue to look for opportunities to improve the physical environment at Yarl s Wood and make it less prison-like. In particular they should discuss with the Home Office whether they can give residents access to more extensive open space and whether they can undertake works to provide more natural light to the corridors and common parts of the centre. (Within six R17 Serco should routinely redecorate those parts of the centre showing wear and tear. (Within six Agreed - The remaining security wire has now been removed. Physical works to provide more natural light would be cost prohibitive but some of the bigger green spaces may be able to be opened up. We will also look at re-introducing some outdoor activities such as horticulture. We have recently improved the outdoor sports area for residents. Residents currently have unrestricted access to the gardens from 9am to 9pm. Agreed We already have a planned maintenance regime in place at Yarl s Wood which includes redecoration where required. R18 Managers should ensure that menus: offer adequate appetising fresh fruit and vegetables and encourage the consumption of five portions of fruit and vegetables a day; and offer a better-balanced choice of foods at lunchtimes. (Within three Completed Yarl s Wood introduced new menus on 1 December 2015 as part of a wider review of catering in our all custodial facilities. These menus have been created in conjunction with our catering supplier to ensure they are nutritious, healthy and balanced and will address the concerns raised around the quality and variety of the food. We will look at the opportunity to stock fresh items in the shop. R19 Leftovers that would otherwise go to waste should be offered to residents. (Within three Under consideration - This will be considered although there will be no equitable way to distribute them which may cause unrest with some residents, so we will have to consider this in relation to the overall impact. We will focus on how waste can be minimised. There are also potential issues with a heightened risk of food poisoning if residents try to take cooked canteen meals to their rooms as there are currently no cold storage facilities available in the accommodation areas. This could affect the health of residents. We will investigate how best we can deal with this. 5

R20 Serco should consider how residents might be given greater opportunities to cater for themselves, including by expanding the cultural kitchen facilities, the choice of foods in the shop and providing facilities for residents to store and cook food and make snacks for themselves. (Within six R21 Serco should work with the Home Office to ensure that the current DSO on food and fluid refusal is appropriately amended to allow residents who prefer to cater for themselves to do so without automatically being subject to ACDT. (Within three R22 Serco should review the activities, education and training programmes available to residents to ensure they allow them adequately to occupy their time and provide meaningful activity, education and training, even for the most able residents. (Within three R23 Managers at Yarl s Wood, in consultation with the local safeguarding adults board, should devise appropriate adult safeguarding policy and practice, including staff training. (Within three Agreed - Discussions have been held with the HiS church charity who run the market in the centre and they would be very keen to sell food products in addition to what is already sold in the shop. As with the shop, any profits would go into a resident support fund. We currently have microwave ovens on the residential units for snacks and we will look at how we could expand the facilities. Agreed - This is a Home Office policy and is currently under review. Serco will work with the Home Office as part of the review. Not Agreed - The HMCIP inspection found no issue with the provision of such activities (with the exception of a couple of recommendations which have been actioned). They were complimentary about the range of activities available. Residents have access to a cultural kitchen where they can prepare their own meals, arts and crafts, a hairdressing salon and an education suite, plus other leisure activities. These activities are available to all residents. However we do recognise that for some of the more able residents the current education curriculum may not provide suitable challenge and we will consider how best to make available a curriculum appropriate to their needs. Agreed - The Centre Manager has met with Director of Children s and Adults Services and discussed how safeguarding policy and practice can be improved in the Centre. The Centre Manager will also attend the Bedford Borough Council Safeguarding Board throughout the year. Bedford Borough Council Safeguarding training is currently being introduced to the centre. 6

R24 Managers at Yarl s Wood should actively engage with the local authority safeguarding team and the safeguarding adults board and ensure there is appropriate and ongoing information sharing to secure the safeguarding of residents. (Within three Agreed There is regular ongoing dialogue with the local authority safeguarding team, as set out above, and all allegations and incidents will be shared with them. R25 In consultation with the Local Safeguarding Children s Board, managers should review and redraft Yarl s Wood s child protection and safeguarding policies to ensure that they clearly and consistently identify the extent of staff responsibilities for safeguarding and promoting the wellbeing of children, including children in the community, and conform to the requirements of the LSCB. (Within three R26 In consultation with the Local Safeguarding Children s Board, managers should review the training of staff in relation to safeguarding and child protection to ensure that they are given regular training to help them understand and meet their responsibilities for safeguarding and promoting the wellbeing of children. (Within three Completed - This activity is already taking place in consultation with: 1. The Poppy Project (effects of human trafficking) 2. Local Safeguarding Children s Board (safeguarding children) 3. Local Safeguarding Adults Board (safeguarding adults) 4. UNHCR (understanding the needs of asylum seekers). Age dispute cases within the Centre will continue to be managed and cared for as per current policy. Agreed - Contact has been made with a number of organisations who have agreed to provide specialist training for staff: 1. The Poppy Project (effects of human trafficking) 2. Local Safeguarding Children s Board (safeguarding children) 3. Local Safeguarding Adults Board (safeguarding adults) 4. UNHCR (understanding the needs of asylum seekers). These include the following that have been provided as a course package by Bedford Borough Council; 7

Female Genital Mutilation (FGM), Forced Marriage, Spirit Possession and Honour Based Violence, Trafficking, Exploitation and Modern Slavery Dignity in Care Introduction to Safeguarding Children Safeguarding Adults All staff will undergo this training. R27 Managers should agree with the Local Safeguarding Children s Board on arrangements for reporting concerns and on the pattern and frequency of future contact between the Local Safeguarding Children s Board and Yarl s Wood. (Within three R28 The Centre Manager and senior Serco managers should continue to engage at all levels with NHS commissioners and G4S to ensure that concerns about the healthcare provision at Yarl s Wood are addressed. (Within three R29 Serco should open discussions with G4S, NHS England and local mental health care providers to consider how best to meet the needs of detainees with severe mental health issues, and ensure that they are Completed - We have agreed with the Local Safeguarding Children s Board to report concerns as and when they arise. Regular contact will be maintained between both Yarl s Wood and Local Safeguarding Children s Board, and the Centre Manager and Safeguarding Lead will attend Safeguarding Board (twice per year) at Bedford Borough Council. Agreed - Whilst Serco does engage daily with the local Healthcare provider and at a national level with the parent company, the commissioning of the Healthcare service is outside of Serco s control. The recent HMCIP inspection highlighted the shortcomings of the service and action does appear to be taking place to rectify them. We will continue to work with NHS England and G4S Health. The Centre Manager attends Healthcare Partnership Board every two months along with the Home Office, NHS England (including Commissioner), IMB and G4S Health. The Senior Management Team also meets weekly and monthly with G4S Health to discuss operational, governance and assurance issues. Agreed - Medical care of the detainees does not fall into Serco s remit beyond referring them to the Healthcare provider. Whilst we can ask the provider to consider the appropriate interventions, this is not in our contractual remit and we need to be careful about overstepping our bounds. We have no influence on who arrives at the Centre 8

assessed and receive care and treatment in a timely and appropriate fashion. (Urgent) R30 Pregnant residents should be allowed to eat their meals away from the main dining rooms without having to obtain permission from healthcare staff. (Within three with a mental health condition and indeed how soon they are transferred to an appropriate establishment for specialist mental health care. G4S Health have started rolling out a Mental Health Training programme for Serco staff at Yarl s Wood. Agreed - To be discussed with G4S Health and a process agreed to facilitate this. R31 Serco managers should undertake a thorough review of the initial training course and the refresher training programme to ensure that they enable staff to fulfil their roles and responsibilities. The review and any consequent redesign of staff training should ensure that staff are adequately trained in mental health matters affecting residents at Yarl s Wood; the backgrounds and vulnerabilities of residents; interpersonal skills including de-escalation techniques; and adult and child safeguarding. (Within six R32 Serco managers should consider with the Home Office the possibility of providing training to give DCOs a better understanding of the rudiments of the immigration process. (Within six R33 The Serco director of media relations should form and maintain a regular stakeholder group. (Within three Completed - As previously described, and we will continue to constantly review. Agreed - The Home Office has delivered training to staff in the past on general immigration, and we will discuss having this refreshed. Agreed Stakeholder group to be agreed and Serco s media relations to facilitate regular meetings. 9

R34 Serco should seek to agree with the Home Office a new strategic communications plan for Yarl s Wood based on the principles of transparency and openness. (Within three R35 Serco should seek Home Office approval for a programme of visits to the centre. Visitors could include officers and politicians from the local council, interested MPs and groups providing services. The purpose of the programme would be to show them the work and facilities and brief them. (Within six Agreed - To be discussed with the Home Office. Agreed - All visits have to be approved by the Home Office and Yarls Wood is already subject to a number of visits from outside agencies. This will be part of the communications strategy as per Recommendations 33 and 34. 10