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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Modern Slavery Policy

1. Purpose

The purpose of this policy is to affirm {{org_field_name}}’s zero-tolerance approach to all forms of modern slavery, including human trafficking, forced labour, debt bondage, and exploitation. We are committed to preventing, identifying, and responding to any instances of modern slavery within our organisation, workforce, and wider supply chains. This policy ensures compliance with the Modern Slavery Act 2015 and aligns with CQC Regulation 13 (Safeguarding service users from abuse and improper treatment), which requires providers to protect people from abuse, including inhuman or degrading treatment and exploitation.

2. Scope

This policy applies to all individuals working at or on behalf of {{org_field_name}}, including permanent and temporary employees, bank and agency workers, volunteers, contractors, suppliers, and service providers. It covers both the people we support and our employees. The policy supports our obligation to act ethically, transparently, and in accordance with the law. It is relevant to our recruitment practices, staff supervision, procurement procedures, safeguarding responsibilities, and partnerships with other organisations.

3. Related Policies

• CH02 – Fit and Proper Persons: Employed Staff Policy
• CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CH18 – Risk Management and Assessment Policy
• CH26 – Recruitment, Selection, and Retention Policy
• CH27 – Staff Supervision, Training, and Development Policy
• CH30 – Equality, Diversity, and Inclusion Policy
• CH35 – Duty of Candour Policy

4. Understanding Modern Slavery

Modern slavery is the severe exploitation of other people for personal or commercial gain and can take many forms including forced labour, domestic servitude, sexual exploitation, and human trafficking. Victims may be subjected to threats, violence, deception, or coercion. In a care setting, this could involve individuals being forced to work against their will, being underpaid or unpaid, being controlled through fear or debt, or being isolated and prevented from accessing support. Staff must understand that modern slavery can affect both colleagues and the people we support and may be hidden behind signs of dependency, restriction, or distress.

5. Preventing Modern Slavery in Employment Practices

{{org_field_name}} is committed to ethical and lawful recruitment. We ensure:

• All recruitment is managed internally or through verified agencies
• Right to work checks are carried out in line with UK law
• References and background checks are completed for every new staff member
• No recruitment fees are charged to workers by agencies we use
• Employees have freely signed contracts and access to their own documents
• Employees are paid at least the National Minimum Wage and receive payslips
  The Registered Manager {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} is responsible for auditing recruitment processes and ensuring that no worker is subjected to unfair, exploitative, or unlawful conditions.

6. Protecting People We Support from Exploitation

We assess the people we support for any risk of exploitation or abuse, especially those who rely on others for care or financial support. Signs of modern slavery may include:

• Unexplained injuries, malnourishment, or poor hygiene
• Fearful or withdrawn behaviour
• Lack of control over finances or documentation
• Sudden changes in social networks or living arrangements
• Working in unsafe conditions or being overworked
  Staff must be vigilant, report concerns immediately to the Safeguarding Lead {{org_field_safeguarding_lead_name}}, and ensure that the individual is supported in a safe, respectful, and confidential manner. Safeguarding referrals will be made to {{org_field_local_authority_authority_name}} where appropriate.

7. Raising Concerns and Whistleblowing

All staff are encouraged to speak up if they suspect someone is being exploited or coerced. Reports can be made to:

• Line Managers
• Safeguarding Lead {{org_field_safeguarding_lead_name}}
• Registered Manager {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
• Through the CH29 – Whistleblowing (Speaking Up) Policy
  Concerns can also be raised anonymously. We assure all staff that they will be supported and protected when reporting suspected modern slavery or unethical practices. Where a crime is suspected, the police and the Modern Slavery Helpline (0800 0121 700) may also be contacted.

8. Supplier and Contractor Due Diligence

{{org_field_name}} takes steps to ensure our suppliers and contractors share our zero-tolerance stance on modern slavery. We only work with organisations that comply with the Modern Slavery Act 2015. This includes:

• Reviewing supplier policies and statements on modern slavery
• Requiring confirmation of ethical employment practices
• Terminating contracts if concerns of exploitation arise
  The Company Director {{org_field_company_director_first_name}} {{org_field_company_director_last_name}} oversees procurement and ensures due diligence is part of all supplier agreements.

9. Staff Training and Awareness

All staff receive mandatory training on modern slavery, trafficking, and exploitation during induction and refresher sessions every two years. Training includes:

• Recognising signs of modern slavery in the community and workplace
• Understanding how to respond to disclosures
• Reporting routes and legal obligations
• Supporting victims safely and compassionately
  Training is tailored to include real-life examples relevant to home care and is reviewed regularly for relevance and accuracy. Managers receive additional safeguarding and leadership training.

10. Supporting Victims of Modern Slavery

Where a person we support or a staff member is suspected or confirmed to be a victim of modern slavery, we will:

• Ensure their immediate safety and wellbeing
• Avoid confrontation with potential exploiters
• Refer to appropriate safeguarding and law enforcement authorities
• Record concerns factually and confidentially
• Provide emotional support and signpost to specialist services
  We will support individuals through the National Referral Mechanism (NRM) where appropriate, and ensure they are not re-traumatised by insensitive questioning or disruption to their care.

11. Efficient Management at {{org_field_name}}

{{org_field_name}} manages modern slavery risks efficiently through:

• A named Safeguarding Lead responsible for monitoring concerns
• Clear procedures embedded in recruitment and procurement systems
• Ongoing risk assessments and safeguarding supervision
• Transparent reporting channels for staff and service users
• Collaboration with local authorities, police, and safeguarding boards
• Annual audits of workforce and supplier compliance
  Our management team maintains a culture of openness, awareness, and proactive prevention.

12. Policy Review

This policy will be reviewed annually by the Registered Manager or sooner if legislation changes, guidance is updated, or an incident of modern slavery is identified. The review will ensure that procedures remain effective and that all staff are aware of their responsibilities in preventing exploitation and abuse.

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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}}
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