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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Modern Slavery Policy

1. Purpose

This policy sets out {{org_field_name}}’s commitment to preventing, identifying, and responding to all forms of modern slavery, human trafficking, forced labour, and exploitation. Modern slavery is a serious crime and a gross violation of human rights. It encompasses slavery, servitude, forced or compulsory labour, and human trafficking.

In accordance with the Modern Slavery Act 2015, the Regulation and Inspection of Social Care (Wales) Act 2016, and associated Welsh Government safeguarding guidance, this policy outlines our zero-tolerance approach to modern slavery and how we uphold the rights and dignity of all individuals in our care, our staff, and those we work with.

Modern slavery can affect anyone, including vulnerable adults receiving care or individuals working in low-paid roles across care, cleaning, catering, and agency staffing. This policy ensures our processes are robust, vigilant, and compliant with the latest Care Inspectorate Wales (CIW) expectations and standards on safeguarding and well-being.

2. Scope

This policy applies to all staff, agency workers, volunteers, contractors, suppliers, and partners who work for or with {{org_field_name}}. It also applies to the people who use our services, particularly those who may be at risk of exploitation due to cognitive impairment, communication barriers, or dependency.

3. Related Policies

This policy must be read alongside the following:

• CHW13 – Safeguarding Adults from Abuse and Improper Treatment Policy
• CHW18 – Risk Management and Assessment Policy
• CHW26 – Recruitment, Selection, and Retention Policy
• CHW29 – Whistleblowing (Speaking Up) Policy
• CHW30 – Equality, Diversity, and Inclusion Policy
• CHW34 – Confidentiality and Data Protection (GDPR) Service User Policy

4. Policy Details

4.1 Understanding Modern Slavery and Indicators
Modern slavery takes many forms, including forced labour, debt bondage, domestic servitude, and human trafficking. In a care home setting, both staff and residents could be vulnerable.

Staff must remain alert to signs that an individual may be a victim, which can include:

• Appearing fearful, withdrawn, or under the control of someone else
• Showing signs of physical abuse, malnourishment, or poor hygiene
• Unpaid or withheld wages, or unusual debt arrangements
• Working excessive hours under threat or coercion
• Lack of access to personal documents or being accompanied everywhere
• A resident who is unusually secretive about their home or employment situation

Staff will receive safeguarding training that includes recognising these signs, particularly as they relate to adults at risk.

4.2 Staff Recruitment and Right to Work Checks
Our recruitment processes are designed to prevent modern slavery by ensuring that all employment is freely chosen and that individuals are recruited transparently, legally, and ethically.

At {{org_field_name}}, we:

• Conduct right-to-work checks on all staff
• Verify original documentation such as passports or biometric residence permits
• Do not retain personal documents or withhold wages
• Work only with reputable recruitment agencies who confirm their compliance with the Modern Slavery Act 2015
• Issue clear contracts and terms of employment
• Provide induction and regular training, including how to raise concerns

This is supported by our Recruitment Policy (CHW26), which includes reference checks, DBS vetting, and interview protocols to detect signs of coercion or third-party control.

4.3 Safeguarding People Using the Service
Our Safeguarding Policy (CHW13) includes specific reference to exploitation and modern slavery as forms of abuse. Our staff are trained to consider the risk of exploitation in assessments and when reviewing care plans.

If a resident is suspected to be a victim of trafficking or forced labour (e.g., domestic servitude in their past or a coercive relationship now), staff must:

• Record observations factually and sensitively
• Immediately report concerns to the Safeguarding Lead: {{org_field_safeguarding_lead_name}}, {{org_field_safeguarding_lead_role}}
• Follow safeguarding procedures and refer to {{org_field_local_authority_authority_name}}, via the Adult Safeguarding Team
• Consider whether advocacy, interpretation, or additional support is required for the individual to communicate safely

All concerns must also be escalated to the Registered Manager and logged securely.

4.4 Ethical Procurement and Third-Party Accountability
{{org_field_name}} expects all contractors and suppliers to uphold the principles of the Modern Slavery Act 2015. We:

• Work with providers who can demonstrate compliance through modern slavery statements or supplier declarations
• Review supply chains for high-risk industries such as cleaning, maintenance, food, and textiles
• Do not knowingly procure from organisations that exploit or traffic individuals
• Maintain a record of due diligence checks on third-party contracts

If a supplier is suspected of unethical or unlawful practices, the relationship is suspended pending investigation, and safeguarding and law enforcement agencies are notified as appropriate.

4.5 Training and Raising Awareness
All staff receive mandatory safeguarding training which includes:

• What modern slavery is and the forms it can take
• How to identify victims and respond appropriately
• Reporting lines within the organisation and externally
• The National Referral Mechanism and support available to victims

Refresher training is provided annually, and materials are available in accessible formats and languages. Posters and leaflets on modern slavery are displayed in staff areas and made available to residents and families in suitable formats.

4.6 Reporting Concerns and the Duty to Act
Any member of staff who suspects or witnesses signs of modern slavery has a duty to act. This can be done through:

• Reporting directly to the Registered Manager: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
• Speaking to the Safeguarding Lead: {{org_field_safeguarding_lead_name}}
• Using our Whistleblowing Procedure (CHW29) to report anonymously if needed
• Contacting the Modern Slavery Helpline on 08000 121 700 or reporting online at https://www.modernslaveryhelpline.org
• Informing CIW under Regulation 60 where appropriate

No one will suffer any detriment or disciplinary action for raising a genuine concern in good faith.

4.7 Record Keeping and Confidentiality
All concerns relating to modern slavery must be documented, dated, and securely stored. Access is limited to senior management and safeguarding leads. Information will be shared with statutory agencies in line with our GDPR Policy (CHW34), the Data Protection Act 2018, and the principle of safeguarding over confidentiality when risk is present.

4.8 Continuous Improvement and Quality Assurance
We review our safeguarding and modern slavery procedures as part of our internal audits and the annual Quality of Care Review. Trends in concerns, staff feedback, or regulatory changes will lead to immediate updates in policy and practice.

5. Policy Review

This policy will be reviewed annually, or sooner if required due to:

• Legislative changes to the Modern Slavery Act 2015
• Amendments in CIW guidance
• Outcomes from audits, investigations, or safeguarding reports
• Feedback from staff, residents, or professionals

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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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