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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 set out {{org_field_name}}’s zero-tolerance approach to modern slavery, human trafficking, slavery, servitude, forced or compulsory labour and exploitation, and to explain the arrangements in place to prevent, identify, report and respond to concerns affecting people who use the service, staff and workers within our operations and supply chains.

{{org_field_name}} will comply with the Modern Slavery Act 2015 and all other legislation applicable to its activities. Where {{org_field_name}} meets the statutory criteria in section 54 of the Modern Slavery Act 2015, including the applicable turnover threshold, it will also comply with the statutory requirements relating to the preparation, approval, signing and publication of an annual slavery and human trafficking statement.

This policy also supports compliance with Regulation 13 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, which requires people who use the service to be protected from abuse and improper treatment, and with the provider’s safeguarding responsibilities under the Care Act 2014.

{{org_field_name}} will take appropriate action without delay where modern slavery, exploitation or other abuse is suspected, identified, disclosed or reported.

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 lawful, safe and ethical recruitment and employment practices. Recruitment procedures will be established and operated effectively in accordance with Regulation 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and other applicable employment and immigration legislation.

Before a person is employed or otherwise engaged for the purposes of carrying on a regulated activity, {{org_field_name}} will obtain, verify and retain the information and checks required by law and applicable to that individual and role. This will include, where applicable:

• satisfactory proof of identity;
• appropriate Disclosure and Barring Service and barred-list checks where the role and legislation require them;
• satisfactory evidence relating to conduct in previous employment concerned with health or social care, children or vulnerable adults;
• satisfactory verification, so far as reasonably practicable, of the reason why relevant previous employment involving children or vulnerable adults ended;
• satisfactory evidence of qualifications relevant to the role, so far as reasonably practicable;
• a full employment history together with a satisfactory written explanation of any gaps;
• information relevant to the individual’s ability, after reasonable adjustments where required, to perform the tasks intrinsic to their role;
• verification of professional registration where registration is legally required; and
• evidence of the individual’s right to work in the United Kingdom where required by immigration legislation.

Where recruitment checks are undertaken by an employment agency or another third party, {{org_field_name}} will obtain sufficient assurance that all checks required for the role have been completed and are satisfactory before the worker is permitted to undertake duties for the service.

{{org_field_name}} will not knowingly use recruitment arrangements that subject workers to coercion, deception, debt bondage or unlawful recruitment practices. Workers must not be required to surrender possession of their passport, immigration document or other personal identity document to {{org_field_name}} or an employment intermediary as a condition of employment. Copies may be taken and retained where required for lawful recruitment, right-to-work or regulatory purposes.

Workers will receive the pay, documentation and employment information to which they are entitled under applicable UK employment legislation. Any indication that a worker is being controlled, threatened, coerced, charged unlawful fees, deprived of their documents or wages, or otherwise exploited will be treated as a potential safeguarding and/or modern slavery concern and investigated and escalated without delay.

The Registered Manager {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}} is responsible for ensuring that recruitment arrangements relevant to the regulated service comply with applicable legal and CQC requirements and that any concerns indicating exploitation are acted upon promptly.

6. Protecting People We Support from Exploitation

{{org_field_name}} will maintain effective systems and processes to protect people who use the service from modern slavery, exploitation, abuse and improper treatment. Staff must remain alert to indicators of exploitation and must take concerns, disclosures and changes in a person’s circumstances seriously.

Possible indicators may include:

• unexplained injuries, malnourishment or poor hygiene;
• fear, anxiety, withdrawal or appearing to be under the control of another person;
• restricted freedom of movement or communication;
• lack of access to, or control over, money, wages, bank accounts or personal documents;
• another person speaking for the individual or refusing to allow them to speak privately;
• signs that the individual is being threatened, intimidated, coerced or deceived;
• unexplained changes in relationships, accommodation or social contacts;
• working excessive hours, in unsafe conditions or without appropriate pay;
• indications of debt bondage, forced labour, servitude or trafficking; or
• any other circumstances that give staff reasonable cause to suspect exploitation or abuse.

Staff must report any concern immediately in accordance with CH13 – Safeguarding Adults from Abuse and Improper Treatment Policy to the Safeguarding Lead {{org_field_safeguarding_lead_name}} and/or the Registered Manager {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}.

Where an adult has needs for care and support, is experiencing or is at risk of abuse or neglect and, as a result of those needs, is unable to protect themselves from the abuse or neglect or the risk of it, the concern will be referred without delay to the relevant local authority safeguarding team in accordance with the Care Act 2014 and local safeguarding procedures.

The registered person will also ensure that the Care Quality Commission is notified without delay where the circumstances constitute a notifiable abuse or allegation of abuse concerning a person who uses the service under Regulation 18 of the Care Quality Commission (Registration) Regulations 2009. Where an incident is reported to or investigated by the police, any separate CQC notification requirement will also be considered and complied with.

Where there is an immediate risk to life or serious harm, emergency services must be contacted without delay.

All actions, decisions, referrals, notifications and the reasons for them must be recorded accurately, contemporaneously and confidentially in accordance with the organisation’s safeguarding, record-keeping and information-governance procedures.

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 who uses the service, member of staff or other person is suspected or identified as a potential victim of modern slavery, {{org_field_name}} will take a victim-centred and safeguarding-led approach.

We will:

• take immediate and proportionate action to protect the person’s safety and wellbeing;
• contact emergency services where there is an immediate risk to life or serious harm;
• avoid confronting a suspected trafficker or exploiter where doing so could increase the risk to the potential victim or others;
• listen to the person and avoid unnecessary or repeated questioning;
• record concerns, disclosures, observations, decisions and actions factually and confidentially;
• make any required adult safeguarding referral to the relevant local authority;
• make any statutory notification required to the Care Quality Commission where a person who uses the service is involved;
• consider referral to or involvement of the police in accordance with safeguarding requirements, the circumstances of the case and applicable duties concerning confidentiality and information sharing; and
• provide or facilitate access to appropriate emotional, practical, advocacy and specialist support.

{{org_field_name}} is not automatically a designated First Responder organisation for the purposes of the National Referral Mechanism simply because it is a registered care provider. Where there are reasonable grounds to suspect that an adult may be a victim of modern slavery, the Registered Manager or Safeguarding Lead will contact an appropriate designated First Responder organisation, such as the relevant local authority or police, so that referral through the National Referral Mechanism can be considered.

An adult must give informed consent before being referred into the National Referral Mechanism. The individual must be given sufficient information to understand the purpose of the National Referral Mechanism, the support that may be available and the possible consequences of referral. Where an adult does not consent to an NRM referral, {{org_field_name}} will continue to safeguard and support the individual and will liaise with an appropriate designated First Responder regarding any applicable Duty to Notify requirements.

Nothing in the requirement for consent to an NRM referral prevents {{org_field_name}} from taking immediate safeguarding action where this is necessary to protect the person or another person from serious harm, or from sharing information where there is another lawful basis or legal requirement to do so.

The wishes, feelings, safety, mental capacity, communication needs and individual circumstances of the potential victim will be considered throughout the response. Staff must avoid actions that could unnecessarily re-traumatise the person or increase the risk from suspected exploiters.

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. Modern Slavery Statement Requirements

Where {{org_field_name}} meets the requirements of section 54 of the Modern Slavery Act 2015, including the applicable statutory turnover threshold, it will prepare a slavery and human trafficking statement for each financial year.

The statement will set out the steps {{org_field_name}} has taken during the relevant financial year to ensure that slavery and human trafficking are not taking place in its supply chains or in any part of its own business, or, if applicable, will state that no such steps have been taken.

Where {{org_field_name}} is a body corporate other than a limited liability partnership, the statement will be approved by the board of directors or equivalent management body and signed by a director or equivalent.

Where a different statutory approval and signature requirement applies because of the organisation’s legal structure, the statement will be approved and signed in accordance with section 54 of the Modern Slavery Act 2015.

Where {{org_field_name}} has a website, the statement will be published on that website and a prominent link to the statement will be placed on the website homepage in accordance with section 54 of the Modern Slavery Act 2015.

The Company Director {{org_field_company_director_first_name}} {{org_field_company_director_last_name}} is responsible for ensuring that the organisation determines annually whether section 54 applies and, where it does, that the statutory statement is prepared, approved, signed and published in accordance with the Act.

13. 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}}
Copyright © {{current_year}} – {{org_field_name}}. All rights reserved.