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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Modern Slavery Policy

1. Purpose

This policy outlines {{org_field_name}}’s commitment to preventing modern slavery and human trafficking in our operations and supply chains. Modern slavery is a crime that violates fundamental human rights, encompassing slavery, servitude, forced or compulsory labour, and human trafficking. This policy sets out how we ensure our business and supply chains are free from modern slavery and what actions we take when concerns arise.

At {{org_field_name}}, we recognise that the care sector can be vulnerable to exploitation. Therefore, we are committed to creating a safe and transparent working environment where all individuals are treated with dignity, respect, and fairness. We take a zero-tolerance approach to modern slavery and expect the same high standards from our employees, suppliers, and stakeholders.

2. Scope

This policy applies to all employees, contractors, suppliers, and any other stakeholders working with or on behalf of {{org_field_name}}. It is relevant to all aspects of our service provision, including staff recruitment, procurement, and relationships with external providers.

It covers all individuals working at all levels within the organisation, including but not limited to, senior management, employees, agency workers, volunteers, interns, apprentices, suppliers, and service providers. We are committed to ensuring that our operations and those of our supply chain do not contribute to any form of modern slavery.

3. Related Policies

To support the implementation of this policy, the following policies provide additional guidance and should be referred to when necessary:

• Safeguarding Adults and Children Policy – Ensures the protection of vulnerable individuals against harm and exploitation.
• Whistleblowing Policy – Provides guidance for employees to report concerns safely and confidentially.
• Recruitment and Selection Policy – Outlines ethical recruitment practices to prevent forced labour.
• Equality, Diversity, and Inclusion Policy – Supports a culture of respect and fairness.
• Health and Safety Policy – Ensures safe working conditions that mitigate the risk of exploitation.

• Adult Support and Protection Policy – Sets out how the service identifies, reports and responds to adults at risk of harm, including exploitation, coercion, neglect, financial harm and human trafficking.
• Child Protection Policy – Applies where the service has contact with children or young people, including family members in a supported person’s home, and sets out how child protection concerns are reported.
• Safer Recruitment Policy – Sets out the checks required before employment starts, including identity checks, right to work checks, references, Disclosure Scotland and PVG Scheme membership where the role is regulated.
• Staffing, Supervision and Training Policy – Sets out how the service ensures safe staffing, regular supervision, learning and development, and staff competence.
• Data Protection and Confidentiality Policy – Sets out how information about suspected modern slavery, trafficking or exploitation is recorded, shared and stored lawfully.
• Duty of Candour Policy – Applies where an incident may have resulted in unintended or unexpected harm and the statutory duty of candour is triggered.
• Complaints Policy – Provides information for supported people, relatives, carers, staff and others on how to raise concerns about poor practice, exploitation or unsafe care.

4. Legislative and Regulatory Framework

This policy is informed by, and should be read alongside, the current legal and regulatory framework for care at home services in Scotland, including:

• Human Trafficking and Exploitation (Scotland) Act 2015, which creates offences of human trafficking, slavery, servitude and forced or compulsory labour, and provides for victim support and Scotland’s trafficking and exploitation strategy.
• Modern Slavery Act 2015, including section 54 where the organisation meets the statutory threshold for publishing an annual slavery and human trafficking statement.
• Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015, which set the turnover threshold for section 54 reporting.
• Public Services Reform (Scotland) Act 2010, under which care services are registered and regulated by the Care Inspectorate.
• Social Care and Social Work Improvement Scotland (Requirements for Care Services) Regulations 2011, including the requirements to promote quality and safety, protect the health, welfare and safety of service users, respect privacy and dignity, maintain personal plans and ensure suitably qualified and competent staff.
• Health and Care (Staffing) (Scotland) Act 2019, which places duties on care service providers to ensure appropriate staffing for safe, high-quality care.
• Adult Support and Protection (Scotland) Act 2007, where a supported person or other adult may be at risk of harm, including exploitation, coercion, financial harm or neglect.
• Protection of Vulnerable Groups (Scotland) Act 2007, as amended, and the Disclosure (Scotland) Act 2020, including requirements for PVG Scheme membership for regulated roles.
• Equality Act 2010, including duties to prevent discrimination, harassment and victimisation.
• UK GDPR and Data Protection Act 2018, where information about concerns, investigations, workers, supported people or third parties is recorded or shared.
• Health and Social Care Standards: My support, my life, which set out what people should experience when using health, social care or social work services in Scotland.
• SSSC Codes of Practice for Social Service Workers and Employers 2024, which set out the standards of conduct and practice expected of workers and employers in Scottish social services.
• Care Inspectorate guidance on records, notifications, quality frameworks and self-evaluation, including the requirement to keep accurate records and notify relevant matters in line with current guidance.

5. Our Commitments

5.1 Recruitment Practices

{{org_field_name}} ensures that all recruitment processes are ethical and transparent by:

• Conducting thorough pre-employment checks, including right-to-work verification and appropriate Disclosure Scotland checks and PVG Scheme membership checks for regulated roles before the worker starts work, and at renewal or update points required by law or organisational procedure.
• Ensuring all job offers include a detailed written contract, clearly outlining roles, responsibilities, and rights.
• Prohibiting unlawful recruitment fees, ensuring that no worker has to pay for employment opportunities.
• Engaging only with reputable recruitment agencies that adhere to fair labour practices.
• Verifying that agency workers receive fair treatment and are not subjected to coercion or threats.

• Ensuring that workers are not charged recruitment fees, placement fees, sponsorship fees, training fees, uniform fees or other deductions that could create debt bondage or financial control.
• Ensuring that workers are given clear information, before they accept employment, about pay, working hours, expected duties, travel time, deductions, accommodation arrangements where relevant, grievance routes and how to leave employment.
• Ensuring that workers retain control of their own passport, biometric residence permit, identity documents, bank card and personal documents. The service may only view, copy and securely store documents where this is lawful and necessary.
• Ensuring that salary is paid directly into an account in the worker’s own name, unless there is a lawful and documented reason for an alternative arrangement.
• Checking any recruitment agency, overseas recruitment partner or labour provider before use, including their approach to ethical recruitment, worker fees, contracts, accommodation, complaint routes and modern slavery risk.
• Recording modern slavery and labour exploitation risks as part of recruitment governance, especially where workers are recruited from overseas, are dependent on employer sponsorship, have limited English, rely on tied accommodation, or appear dependent on another person to speak or act for them.

5.2 Worker Welfare and Support

• Fair Pay: Ensuring all employees are paid at least the National Minimum Wage or Living Wage and are provided with clear payslips.
• Safe Working Conditions: Implementing regular audits to maintain a safe, supportive, and ethical working environment.
• Confidential Support System: Establishing secure and anonymous reporting channels for workers to raise concerns.
• No Forced Labour: Prohibiting withholding of wages, excessive working hours, or control over personal identification documents.

• Workers must be free to leave employment by giving the required contractual notice. Managers must not threaten workers with dismissal, deportation, loss of accommodation, loss of sponsorship or reports to authorities as a means of control or punishment.
• Workers must not be subjected to coercion, intimidation, threats, harassment, bullying, discriminatory treatment or abuse of power.
• Any concerns about excessive working hours, unsafe travel schedules, unpaid work, unlawful deductions, dependency on a third party, isolation, fearfulness, unexplained injuries, poor living conditions, control of documents or control of wages must be treated as potential indicators of exploitation.
• Where staff accommodation is provided, arranged or recommended by the organisation, this must be safe, voluntary, clearly documented and not used as a means of control.
• Workers must have access to confidential reporting routes, including line management, senior management, whistleblowing arrangements, the Modern Slavery Helpline, Police Scotland and relevant local authority safeguarding routes.

5.3 Indicators of Modern Slavery and Exploitation

Managers and staff must remain alert to signs that a worker, supported person, family member or other adult or child may be experiencing modern slavery, human trafficking or exploitation. Indicators may include, but are not limited to:

• appearing frightened, withdrawn, anxious, controlled or unable to speak freely;
• another person speaking on their behalf or refusing to leave them alone;
• not having possession of their own passport, identity documents, bank card or phone;
• being transported to and from work by someone who appears to control them;
• working excessive hours or being unable to take rest breaks or leave;
• receiving little or no pay, or wages being paid to another person;
• owing money to an employer, recruiter, sponsor, landlord or third party;
• living in overcrowded, unsafe or controlled accommodation;
• having unexplained injuries, untreated health needs or signs of neglect;
• being threatened with dismissal, eviction, deportation, violence, withdrawal of care or harm to family members;
• being prevented from accessing healthcare, advocacy, interpreters, legal advice or support services;
• showing signs of sexual, criminal, labour, domestic, financial or care-related exploitation.

In a care at home setting, staff must also be alert to exploitation affecting people receiving care, unpaid carers, relatives, domestic workers, visitors or others in the household. Any concern must be reported immediately in line with this policy, safeguarding procedures and local Adult Support and Protection or Child Protection procedures.

5.4 Training and Awareness

• Mandatory Modern Slavery Training: Educating all staff on how to recognise, prevent, and report modern slavery.
• Management and HR Training: Providing additional training for leadership teams on ethical employment practices.
• Staff Induction and Continuous Development: Ensuring all new employees are made aware of their rights and responsibilities from day one.

• Training must be provided at induction and refreshed at intervals set by the organisation’s training matrix, or sooner where legislation, guidance, local procedures or identified risks change.
• Training must include:
  • the meaning of modern slavery, human trafficking, forced labour, servitude and exploitation;
  • indicators of exploitation in care at home, recruitment, overseas recruitment, agency work and supply chains;
  • how to respond safely where a person may be controlled by another person;
  • Adult Support and Protection and Child Protection reporting routes;
  • the role of Police Scotland, local authority safeguarding teams, the Modern Slavery Helpline and designated First Responder Organisations;
  • consent and confidentiality when making referrals or sharing information;
  • the National Referral Mechanism and how staff can support a referral through an appropriate First Responder Organisation;
  • accurate recording, escalation and Care Inspectorate notification requirements;
  • the SSSC Codes of Practice, including the duty to report harm, exploitation, abuse, dangerous practice and concerns about fitness to practise.
• Managers, HR staff and those involved in recruitment must receive enhanced training on ethical recruitment, sponsorship risks, labour exploitation, unlawful deductions, document retention, worker dependency and supply chain due diligence.

5.5 Supply Chain Management

• Supplier Due Diligence: Conducting regular risk assessments to evaluate supplier compliance with ethical labour standards.
• Contractual Obligations: Including anti-slavery clauses in all contracts to enforce compliance.

• Supplier contracts must require suppliers, agencies and subcontractors to:
  • comply with all applicable modern slavery, employment, immigration, health and safety, equality and data protection law;
  • prohibit worker-paid recruitment fees;
  • ensure workers receive written terms and clear payslips;
  • ensure workers retain control of their own identity documents;
  • provide safe and voluntary accommodation where accommodation is arranged;
  • notify {{org_field_name}} immediately of any suspected modern slavery, trafficking, forced labour or labour exploitation connected to services supplied to the organisation;
  • co-operate with audits, investigations and remedial action plans.
• Supplier due diligence must be proportionate to risk and must be recorded. Higher-risk suppliers include recruitment agencies, overseas recruitment partners, agency staffing providers, uniform suppliers, cleaning contractors, transport providers and any supplier using low-paid, temporary, migrant or agency labour.
• Where concerns are identified, {{org_field_name}} will prioritise the safety and rights of affected workers or potential victims and will not take action that may increase the risk of harm, destitution, intimidation or retaliation.

• Audits and Compliance Reviews: Conducting supplier visits and monitoring working conditions.
• Zero-Tolerance Approach: Taking immediate action against suppliers found to be in breach of modern slavery laws.

Where {{org_field_name}} meets the statutory threshold under section 54 of the Modern Slavery Act 2015, the organisation will prepare, approve, sign and publish an annual slavery and human trafficking statement in line with current UK Government guidance. Where the organisation is below the statutory threshold, it will consider publishing a voluntary statement or summary of actions as good practice.

5.6 Identifying and Reporting Concerns

• All staff, volunteers, agency workers, contractors, suppliers and external stakeholders must report any suspected modern slavery, human trafficking, forced labour, servitude or exploitation immediately. Concerns may relate to workers, people receiving care, unpaid carers, relatives, children, visitors, suppliers or others connected with the service.
• Staff must not investigate suspected modern slavery themselves, confront an alleged perpetrator, alert a person who may be controlling the potential victim, or take action that may increase risk. The immediate priority is safety, preservation of evidence, accurate recording and prompt escalation.
• Concerns must be reported to the Registered Manager or the most senior person on duty. If the concern involves the Registered Manager, the concern must be reported to the Provider, Responsible Individual, senior management, whistleblowing route, Police Scotland or the relevant local authority safeguarding team.
• Where there is immediate danger, staff must call 999. Where a crime may have been committed but there is no immediate danger, staff must contact Police Scotland on 101. Staff may also contact the Modern Slavery Helpline on 08000 121 700 for advice.
• Where the concern relates to an adult who may be unable to safeguard their own wellbeing, property, rights or other interests, the service must follow local Adult Support and Protection procedures and contact the relevant local authority social work or adult protection team.
• Where the concern relates to a child or young person, the service must follow local Child Protection procedures and contact the relevant local authority children’s services or Police Scotland.
• Where the concern may meet Care Inspectorate notification criteria, the Registered Manager must submit a notification to the Care Inspectorate in line with current notification guidance and within the required timescale.
• Potential victims of modern slavery may be referred into the National Referral Mechanism only by a designated First Responder Organisation. For adults, referral normally requires the adult’s informed consent. Where the service is not a First Responder Organisation, the Registered Manager must contact an appropriate First Responder Organisation, such as Police Scotland or the local authority, for advice and referral support.
• All concerns, decisions, referrals, advice received, notifications and actions taken must be recorded clearly, factually and securely.

5.7 Responding to Modern Slavery Cases

If modern slavery, human trafficking, forced labour, servitude or exploitation is suspected or identified, {{org_field_name}} will take prompt, safe and proportionate action. The response will be led by the Registered Manager or senior manager unless they are implicated in the concern.

The service will:

• take immediate steps to protect the potential victim and any other person at risk;
• call 999 where there is immediate danger or urgent medical need;
• contact Police Scotland, the local authority Adult Support and Protection team, children’s services, or another relevant safeguarding route as required;
• seek advice from the Modern Slavery Helpline where appropriate;
• support referral to the National Referral Mechanism through a designated First Responder Organisation, where appropriate and with adult consent where required;
• consider advocacy, interpreting, healthcare, housing, legal advice and other specialist support needs;
• preserve relevant records, rotas, recruitment records, contracts, payslips, communications, incident records, supplier records and audit trails;
• submit any required Care Inspectorate notification;
• inform commissioners or relevant placing authorities where required and safe to do so;
• consider whether the matter triggers Adult Support and Protection, Child Protection, whistleblowing, disciplinary, grievance, complaints, duty of candour, data protection or health and safety procedures;
• avoid taking action against a potential victim for behaviour that may be directly linked to their exploitation;
• review risks, staffing, recruitment, supplier arrangements, training and governance to prevent recurrence.

Any internal investigation must not interfere with a police, local authority, Care Inspectorate, SSSC or other statutory investigation. Where a worker’s fitness to practise may be impaired, the service will consider referral to the SSSC or other relevant professional body in line with applicable guidance.

6. Monitoring and Compliance

To ensure the policy remains effective, {{org_field_name}} will:

• Conduct annual internal audits to assess compliance.
• Perform supplier reviews to maintain ethical standards.
• Keep detailed records of reports and investigations.
• Embed modern slavery risk assessments into governance and risk management strategies.

• Monitor recruitment and workforce data for indicators of exploitation, including unusual turnover, repeated use of the same address or bank account, concerns about debt, excessive hours, unexplained absences, dependency on one individual, or workers appearing unable to speak freely.
• Audit a sample of recruitment files at least annually to confirm that identity checks, right to work checks, references, Disclosure Scotland and PVG checks, contracts, pay information and induction records are complete.
• Audit agency and supplier files at least annually, or more often where risk is higher.
• Review all modern slavery concerns, safeguarding referrals, whistleblowing concerns, complaints, staff grievances, Care Inspectorate notifications and supplier issues to identify patterns and learning.
• Report modern slavery risks and actions to senior management as part of governance and quality assurance.
• Where applicable, prepare and publish an annual modern slavery statement and review year-on-year progress.

7. Policy Review

This policy will be reviewed at least annually, or sooner where there are changes in legislation, Care Inspectorate guidance, SSSC guidance, Home Office modern slavery guidance, local Adult Support and Protection or Child Protection procedures, organisational structure, recruitment practice, supplier arrangements, or identified risks. The review will take account of incidents, concerns, notifications, audit findings, staff feedback, supported person feedback, complaints, whistleblowing concerns and learning from external reviews or regulatory findings.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
Reviewed on: {{last_update_date}}
Next Review Date: {{next_review_date}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.