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Modern Slavery Policy

1. Purpose

The purpose of this policy is to ensure that our domiciliary care service takes a zero-tolerance approach to modern slavery and human trafficking in line with the Modern Slavery Act 2015 and Care Inspectorate Wales (CIW) regulations. Our organisation is committed to preventing, identifying, and responding to modern slavery risks, ensuring that all service users, employees, and supply chain workers are protected from exploitation, forced labour, and human trafficking.

We recognise that modern slavery can occur in various forms, including:

• Forced labour – where individuals are compelled to work against their will.
• Human trafficking – where individuals are moved and exploited.
• Debt bondage – where individuals are forced to work to repay debt.
• Domestic servitude – where individuals are forced to work under poor conditions with little or no pay.

This policy outlines the preventative measures, reporting mechanisms, and safeguarding procedures we have in place to combat modern slavery effectively.

2. Scope

This policy applies to:

• All staff, including care workers, supervisors, and managers, within our organisation.
• Service users and their families, ensuring they are not subjected to exploitation.
• Third-party providers and suppliers, ensuring ethical practices in recruitment and procurement.
• External agencies, including local authorities, law enforcement, and safeguarding teams.

It covers:

• Identifying modern slavery and human trafficking.
• Screening and due diligence in recruitment and supply chains.
• Preventative measures and safeguarding responsibilities.
• Reporting mechanisms and responding to modern slavery concerns.
• Staff training and ongoing compliance.

3. Identifying Modern Slavery and Human Trafficking

Modern slavery is often hidden, and victims may be unable or afraid to seek help. Staff must be trained to identify warning signs, including:

3.1 Signs of Modern Slavery in Service Users

• Unexplained injuries or signs of physical abuse.
• Fearful behaviour, appearing withdrawn, anxious, or frightened.
• Lack of personal identification or documents being controlled by someone else.
• Being accompanied or monitored by someone who speaks on their behalf.
• Poor living conditions or reports of being forced to work.

3.2 Signs of Modern Slavery in Staff or Workers

• Unusual dependency on an employer or agency (e.g., working excessive hours without choice).
• Withholding of wages or deductions that are unexplained.
• Confiscation of personal documents (passport, bank details).
• Living in overcrowded or unsuitable conditions.
• Fear of authorities or reluctance to discuss personal matters.

If any red flags are identified, staff must report concerns immediately to the Safeguarding Lead ({{org_field_safeguarding_lead_name}}).

4. Preventing Modern Slavery in Our Organisation

4.1 Ethical Recruitment and Employment Practices

We ensure that all employees are recruited fairly and transparently, with:

• Right-to-work checks on all employees and agency workers.
• No recruitment fees charged to staff.
• No withholding of wages, personal documents, or contracts.
• Freedom for employees to leave their job or refuse work without penalty.
• Access to clear employment terms and conditions.

All external recruitment agencies must comply with ethical hiring practices, and we will only partner with agencies that meet CIW and UK labour standards.

4.2 Safe and Ethical Supply Chains

We take reasonable and proportionate steps to identify and manage the risk of modern slavery and human trafficking within our supply chains and procurement arrangements.

Our arrangements include:

• considering modern slavery and labour exploitation risks when selecting and reviewing suppliers, contractors and recruitment agencies;
• requiring suppliers and contractors to comply with applicable UK employment, labour, safeguarding and modern slavery legislation;
• where a supplier or contractor is legally required to publish a slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015, taking reasonable steps to confirm that an appropriate current statement has been published;
• considering modern slavery risks particularly where workers may be vulnerable to exploitation, including recruitment, temporary staffing, agency work and labour supply arrangements; and
• taking proportionate action where concerns about modern slavery or exploitation are identified.

Where suspected modern slavery is identified within a supply chain, recruitment arrangement or contractual relationship, we will prioritise the safety and welfare of any potential victim and will make appropriate safeguarding or law-enforcement referrals. We will consider the nature and seriousness of the concern, the risks to potential victims, the supplier’s response and any advice received from relevant statutory agencies before determining appropriate contractual action.

Nothing in this section requires a supplier that is not subject to section 54 of the Modern Slavery Act 2015 to produce a statutory slavery and human trafficking statement.

5. Reporting and Responding to Modern Slavery Concerns

5.1 Internal Reporting Mechanisms

Any member of staff who knows or suspects that a service user, member of staff or other person may be experiencing modern slavery, human trafficking, forced labour, domestic servitude or another form of exploitation must act without delay.

Staff must:

• take any immediate and reasonable action necessary to protect the person from immediate harm, without placing themselves or others at unnecessary risk;
• report the concern immediately to the Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) or the Safeguarding Lead ({{org_field_safeguarding_lead_name}});
• record accurately and factually what has been seen, heard, disclosed or otherwise identified, including the date, time, circumstances and any immediate action taken;
• preserve relevant information or evidence and must not investigate the allegation themselves or question the potential victim unnecessarily;
• avoid confronting a suspected perpetrator where doing so could increase the risk to the potential victim, staff or others; and
• maintain confidentiality while sharing information with those who need it for safeguarding, law-enforcement or regulatory purposes.

Where the concern or allegation involves the Registered Manager, Safeguarding Lead or another person to whom the concern would normally be reported, staff must not report the concern solely to that person. The concern must instead be escalated through the organisation’s safeguarding and whistleblowing arrangements to an appropriate senior person, the Responsible Individual and, where required, directly to the local authority safeguarding service, Care Inspectorate Wales or the police.

No member of staff must delay reporting a safeguarding concern because they believe somebody else will report it.

Any allegation concerning a practitioner or person in a position of trust will also be managed in accordance with the current Wales Safeguarding Procedures, including the procedures for allegations against practitioners and those in positions of trust.

A failure by a member of staff to report abuse or suspected abuse may result in disciplinary action in accordance with the organisation’s disciplinary procedure and applicable regulatory requirements.

5.2 External Reporting and Multi-Agency Collaboration

Where modern slavery, human trafficking or exploitation is suspected, the organisation will follow the current Wales Safeguarding Procedures and make all safeguarding, regulatory and law-enforcement referrals and notifications required by the circumstances.

Safeguarding referral

Where a service user is an adult at risk, or there is reasonable cause to suspect that an adult with care and support needs is experiencing or is at risk of abuse or neglect and is unable to protect themselves, the concern must be referred without delay to the relevant Local Authority Safeguarding Team ({{org_field_local_authority_authority_name}}) in accordance with the Social Services and Well-being (Wales) Act 2014 and the Wales Safeguarding Procedures.

Where the potential victim is a child, concerns must be referred immediately to the relevant local authority children’s social services in accordance with the Wales Safeguarding Procedures. Child trafficking and modern slavery are safeguarding concerns and must be treated as potential child abuse.

Staff must not delay a safeguarding referral while attempting to establish whether modern slavery has definitely occurred. Reasonable concern is sufficient to activate the safeguarding process.

Immediate danger and police involvement

Where there is an immediate risk to life, a serious or immediate threat of harm, or a crime is in progress, the police must be contacted by calling 999.

Where there is no immediate emergency but police involvement is required, the appropriate non-emergency police reporting route should be used.

The Modern Slavery and Exploitation Helpline may also be contacted on 08000 121 700 for information, advice or reporting. Contacting the helpline does not replace any safeguarding referral, police report, National Referral Mechanism referral or CIW notification that is otherwise required.

National Referral Mechanism

The National Referral Mechanism is the United Kingdom framework for identifying and referring potential victims of modern slavery and ensuring access to appropriate specialist support.

Only designated First Responder organisations can make a formal referral into the National Referral Mechanism. Where this organisation is not itself a designated First Responder organisation, it will work promptly with an appropriate designated First Responder, such as the local authority, police or another authorised organisation, so that a referral can be considered and made where appropriate.

For an adult potential victim:

• the adult’s informed consent is required before they can be referred into the National Referral Mechanism;
• the adult must be given sufficient information to understand what the National Referral Mechanism is, the support potentially available and the implications of referral; and
• where the adult does not consent to an NRM referral, the organisation will continue to address any immediate safeguarding risks and will liaise with an appropriate designated First Responder regarding any applicable Duty to Notify requirements.

For a child or young person under 18 who is a potential victim of modern slavery:

• safeguarding action must be taken immediately;
• consent is not required for referral into the National Referral Mechanism; and
• the organisation will work with children’s social services, the police or another designated First Responder to ensure the appropriate referral is made.

Notification to Care Inspectorate Wales

The service provider will make notifications to Care Inspectorate Wales in accordance with Regulation 60 and Schedule 3 of the Regulated Services (Service Providers and Responsible Individuals) (Wales) Regulations 2017, as amended.

In particular, a CIW notification must be made where the circumstances meet a notifiable category, including:

• any abuse or allegation of abuse in relation to an individual that involves the service provider, a member of staff or a volunteer;
• any allegation of misconduct by a member of staff;
• any incident reported to the police; or
• any other event specified as notifiable under the Regulations.

Notifications will be made through CIW Online without delay and in accordance with the timescales required by the Regulations and current CIW guidance.

A safeguarding referral to the local authority does not remove the obligation to make a separate CIW notification where the circumstances are notifiable.

Recording and co-operation

The organisation will keep a clear and contemporaneous record of:

• the concern, allegation or evidence received;
• any immediate protective action taken;
• the wishes and views of the potential victim, where appropriate;
• any safeguarding referral made;
• any contact with the police or other statutory body;
• any referral or liaison concerning the National Referral Mechanism;
• any CIW notification made;
• advice received and decisions made;
• the outcome of referrals where this information is available; and
• any action required to reduce the risk of recurrence.

The organisation will co-operate with the local authority, police, CIW, designated First Responders and other relevant agencies and will provide information lawfully where this is necessary for safeguarding, regulatory or law-enforcement purposes.

6. Supporting Potential Victims and Victims of Modern Slavery

6.1 Immediate Safety and Protection

Where a service user or member of staff is believed to be a potential victim of modern slavery, human trafficking or exploitation, the organisation will place their immediate safety and welfare at the centre of its response.

We will:

• take reasonable immediate steps to reduce the risk of further harm;
• contact emergency services where there is an immediate danger to the person or others;
• make the appropriate safeguarding referral;
• support the person to access safe accommodation through the local authority, police, a designated First Responder or an appropriate specialist organisation where safe accommodation is required;
• support access to urgent healthcare or other professional services where required;
• consider communication, language, disability and accessibility needs;
• avoid actions that could alert a suspected perpetrator or increase the risk to the potential victim;
• respect the person’s wishes and choices where this is consistent with safeguarding and legal requirements; and
• work with appropriate statutory and specialist agencies to ensure that the person’s immediate protection and support needs are addressed.

The organisation will not undertake investigative interviews or attempt to determine conclusively whether modern slavery has occurred. Investigation and formal victim-identification processes will be undertaken by the relevant statutory authorities and designated bodies.

6.2 Ongoing Support

Where ongoing support is required, the organisation will work within the limits of its registered service, Statement of Purpose and staff competence and will co-operate with relevant professionals and agencies.

Where appropriate, we will support the individual to access:

• local authority safeguarding and social services;
• the National Referral Mechanism through an appropriate designated First Responder;
• advocacy services;
• healthcare and mental health services;
• specialist modern slavery and trafficking support;
• housing and safe accommodation services;
• welfare rights and benefits advice;
• immigration or independent legal advice from appropriately authorised providers; and
• employment or other rehabilitation support.

Any care and support that continues to be provided by this organisation will be reviewed to ensure that it remains safe, appropriate and consistent with the individual’s assessed needs and personal plan.

Information will be shared only where there is a lawful basis to do so and in accordance with safeguarding requirements, data protection legislation and the organisation’s confidentiality and information-sharing procedures.

7. Staff Training and Compliance

7.1 Mandatory Training and Staff Competence

All staff will receive safeguarding training appropriate to their role as part of their induction and thereafter at appropriate intervals in accordance with the organisation’s training programme, current CIW requirements and the applicable Social Care Wales safeguarding training, learning and development standards.

Training relevant to modern slavery and human trafficking will ensure that staff understand:

• what modern slavery, human trafficking, forced labour, domestic servitude and exploitation may involve;
• indicators that a service user, colleague or other person may be experiencing exploitation;
• the relationship between modern slavery and safeguarding adults and children in Wales;
• their personal responsibility to act on and report safeguarding concerns without delay;
• the organisation’s internal reporting and whistleblowing arrangements;
• how and when concerns must be referred to the local authority safeguarding service or police;
• that staff must not investigate suspected modern slavery themselves or unnecessarily question a potential victim;
• the purpose of the National Referral Mechanism and the role of designated First Responder organisations;
• the different consent requirements applying to adult and child potential victims;
• the requirement for the service provider to make relevant notifications to Care Inspectorate Wales where a notifiable event has occurred; and
• the importance of accurate, timely, confidential and factual record keeping.

The organisation will maintain records of safeguarding and modern slavery training completed by staff and will address identified gaps in knowledge or competence through supervision, additional training or other appropriate management action.

Safeguarding responsibilities, including modern slavery and exploitation, will be revisited through staff supervision and whenever changes in legislation, statutory guidance or the Wales Safeguarding Procedures affect staff practice.

7.2 Ensuring Ongoing Compliance

To maintain compliance, our organisation will:

• Conduct annual reviews of modern slavery risks.
• Ensure regular audits of recruitment and supply chain policies.
• Keep updated on CIW and UK government guidelines on modern slavery.

Failure to adhere to this policy may result in disciplinary action, including termination of employment or contracts.

8. Related Policies

This policy should be read alongside:

• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13).
• Whistleblowing (Speaking Up) Policy (DCW29).
• Recruitment, Selection, and Retention Policy (DCW26).
• Staff Conduct and Code of Ethics Policy (DCW28).
• Confidentiality and Data Protection Policy (DCW34).

9. Policy Review

This policy will be reviewed annually or sooner if there are changes in legislation, best practices, or CIW guidance. The Registered Manager is responsible for ensuring compliance.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
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