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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 ensure that our domiciliary care organisation upholds the highest ethical standards in preventing and combatting modern slavery and human trafficking within our business and supply chains. We recognise that modern slavery is a severe violation of human rights and are committed to identifying, mitigating, and preventing any instances of forced labour, servitude, or exploitation in accordance with the Modern Slavery Act 2015.

As a provider of domiciliary care services, we are committed to safeguarding our workforce, service users, and supply chains from the risks associated with modern slavery. This policy outlines our approach to compliance, risk management, training, and reporting mechanisms to ensure that modern slavery has no place in {{org_field_name}}.

2. Scope

This policy applies to all employees, agency workers, volunteers, contractors, suppliers, and any third parties associated with {{org_field_name}}. It covers:

• Recruitment and employment practices.
• Supply chain management.
• Staff training and awareness.
• Reporting mechanisms for suspected instances of modern slavery.
• Governance and compliance monitoring.

3. Legal and Regulatory Framework

This policy is informed by, and must be read alongside, the following legislation, statutory guidance and regulatory requirements as applicable to domiciliary care services in England:

• Modern Slavery Act 2015, including offences relating to slavery, servitude, forced or compulsory labour and human trafficking, and the statutory guidance issued under section 49.
• Care Act 2014, including the safeguarding duties relevant to adults with care and support needs and referral to the local authority where abuse, neglect or exploitation is suspected.
• Health and Social Care Act 2008 and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014, in particular:
  • Regulation 13 – Safeguarding service users from abuse and improper treatment;
  • Regulation 16 – Receiving and acting on complaints;
  • Regulation 17 – Good governance;
  • Regulation 18 – Staffing;
  • Regulation 19 – Fit and proper persons employed;
  • Regulation 20 – Duty of candour.
• Care Quality Commission (CQC) guidance for providers and managers, including guidance relevant to safeguarding, governance, staffing, recruitment and candour.
• Equality Act 2010.
• Employment Rights Act 1996 and whistleblowing protections, together with our Whistleblowing Policy.
• Gangmasters (Licensing) Act 2004, where relevant to labour exploitation and unlawful labour supply practices.
• Data Protection Act 2018 and UK GDPR in relation to information sharing, record keeping and confidentiality.

We recognise modern slavery as a safeguarding, human rights, employment and governance issue. We will respond in a way that protects service users, staff and others at risk, supports lawful information sharing, and demonstrates compliance with CQC’s regulatory expectations.

4. Our Commitment to Preventing Modern Slavery

{{org_field_name}} has a zero-tolerance approach to modern slavery, servitude, forced or compulsory labour, debt bondage, human trafficking and labour exploitation in any part of its service, workforce or supply chain.

We are committed to:

• protecting service users, workers, volunteers and others from abuse, neglect, exploitation and improper treatment;
• operating robust recruitment, induction, supervision and workforce monitoring systems so that people employed for the purposes of regulated activity are fit, safe and supported in their roles;
• identifying and responding promptly to concerns that a service user, employee, worker, volunteer or another person may be a victim of modern slavery or human trafficking;
• working in partnership with the local authority, police, safeguarding teams and other relevant agencies where concerns arise;
• maintaining accurate records, oversight, audit and learning so that concerns are acted on, reviewed and used to improve practice; and
• promoting a culture of openness, speaking up and psychological safety so that concerns can be raised without fear of detriment.

Modern slavery concerns will be treated seriously as potential safeguarding concerns and, where relevant, as serious incidents requiring immediate risk assessment, protection planning, escalation and inter-agency referral.

5. Safer Recruitment, Employment and Workforce Assurance

We will operate robust recruitment and employment procedures to reduce the risk of exploitation and to comply with our duties as a regulated provider. This includes employees, agency staff, bank staff, volunteers, contractors and any other person engaged for the purposes of carrying on a regulated activity.

Our arrangements include:

• verifying identity, right to work in the UK and, where applicable, professional registration, references, employment history and DBS checks in line with role requirements and safer recruitment procedures;
• ensuring written contracts, role descriptions, rates of pay, working hours, holiday entitlement and other employment terms are explained clearly and provided in a format the worker can understand;
• prohibiting the charging of recruitment fees to workers, unlawful deductions, retention of passports or identity documents, coercive tied accommodation, forced transport arrangements, debt bondage and control over a worker’s bank account or wages;
• checking for indicators of exploitation during recruitment, onboarding, supervision, return-to-work discussions, audits and routine workforce monitoring;
• making sure workers know how to raise concerns confidentially through management, safeguarding routes and whistleblowing routes;
• monitoring agency and overseas recruitment arrangements where used, including confirmation that recruitment partners are acting lawfully and ethically; and
• taking prompt action where information suggests a worker may no longer be fit, safe or free from coercion, including safeguarding referral, disciplinary action, suspension of unsafe arrangements and referral to external agencies as appropriate.

No person will be disadvantaged for raising a genuine concern in good faith about suspected exploitation or modern slavery.

6. Supply Chain Due Diligence and Procurement Controls

We recognise that modern slavery risks may arise in labour supply, temporary staffing, recruitment, cleaning, transport, training, technology, uniforms, consumables and other contracted services.

We will take proportionate due diligence steps before engaging, renewing or materially varying arrangements with suppliers, agencies and contractors. These steps may include:

• checking the supplier’s business identity, ownership, reputation and relevant policies;
• assessing whether the supplier uses agency labour, overseas recruitment, subcontracting or other higher-risk labour models;
• obtaining assurance about recruitment fees, wages, deductions, accommodation arrangements, right to work checks and worker welfare;
• requiring compliance with anti-slavery, safeguarding, whistleblowing and employment law expectations in contracts;
• seeking evidence of training, audits, investigations or corrective actions where concerns have previously arisen;
• escalating concerns where a supplier refuses to cooperate or where exploitation indicators are identified; and
• suspending, reviewing or terminating arrangements where risks cannot be adequately managed.

The level of due diligence will be risk-based. Higher-risk arrangements will be subject to enhanced scrutiny, monitoring and documented review.

7. Identifying, Responding to and Reporting Concerns

Modern slavery may affect service users, staff, relatives, visitors, contractors or other people connected to our service. Concerns may arise from disclosure, observed behaviour, injuries, fearfulness, signs of control by another person, restricted freedom, lack of access to money or documents, poor living conditions, unusual transport or work arrangements, excessive deductions from wages, debt, or inconsistent explanations.

Any member of staff who suspects modern slavery, trafficking or labour exploitation must treat this as a safeguarding concern and take immediate action to reduce risk. Staff must not ignore, investigate alone, confront suspected perpetrators in an unsafe way, or place a person at further risk.

Immediate action

• If there is an immediate risk of harm, contact 999.
• If urgent but not life-threatening police action is required, contact 101 or use the relevant police reporting route.
• If the concern relates to a service user or another adult who may have care and support needs and may be experiencing abuse or neglect, make an urgent referral to the Local Authority Adult Safeguarding / Adult Social Care Team in line with local safeguarding procedures.
• If the concern involves a child, follow child safeguarding procedures immediately and contact children’s social care and/or police as required.

Internal reporting

Concerns must be reported without delay to the Registered Manager, the Safeguarding Lead, or the on-call manager. Staff may also raise concerns under the Whistleblowing Policy where appropriate.

Where to report internally

1. Verbally to the Registered Manager or Safeguarding Lead
2. By email to: {{org_field_registered_manager_email}}
3. By telephone to: {{org_field_phone_no}}
4. Out of hours: {{org_field_out_of_hours}}

External support and reporting routes

Depending on the circumstances, concerns may also be reported or referred to:

• the police;
• the Local Authority Adult Safeguarding Team;
• the Modern Slavery and Exploitation Helpline: 08000 121 700;
• the Gangmasters and Labour Abuse Authority (GLAA) where labour exploitation is suspected;
• CQC, where concerns raise issues about safe care, safeguarding or provider compliance.

Adults and consent

Where the potential victim is an adult, staff must work in a person-centred and trauma-informed way, taking account of the adult’s wishes, safety, mental capacity, consent and immediate protection needs. Where appropriate, the matter should be discussed with safeguarding professionals and consideration given to referral through the National Referral Mechanism or any applicable duty to notify process.

Record keeping

All concerns, actions taken, referrals made, decisions, rationales, advice received and outcomes must be recorded promptly, factually and securely. Records must include the date, time, persons involved, immediate risks identified, protective actions taken and any follow-up required.

Allegations involving staff or suppliers

Where the concern involves a staff member, worker, manager, agency, contractor or supplier, the organisation will take immediate steps to protect people from risk, preserve evidence, seek safeguarding advice, and consider suspension of duties or contractual review while enquiries are undertaken.

All reports will be taken seriously, reviewed promptly and managed in partnership with relevant agencies as appropriate.

8. Support for Victims and Potential Victims

Where a person may be a victim of modern slavery or trafficking, {{org_field_name}} will respond in a way that prioritises safety, dignity, privacy and wellbeing.

We will, where appropriate:

• listen carefully and take disclosures seriously;
• avoid actions that could place the person at further risk;
• support access to emergency medical care or urgent protection;
• involve safeguarding professionals and other agencies as required;
• consider communication needs, advocacy needs, cultural needs and any mental capacity issues; and
• support the person to understand available reporting and referral options, including specialist support routes where appropriate.

We will not require a person to provide proof before taking safeguarding concerns seriously.

9. Staff Training and Awareness

All staff will receive training and guidance appropriate to their role on recognising, preventing and responding to modern slavery, trafficking and labour exploitation.

Training will include, as relevant:

• indicators of modern slavery affecting service users and workers;
• immediate safety actions and emergency escalation;
• safeguarding referral pathways for adults and children;
• person-centred and trauma-informed responses;
• consent, mental capacity and information sharing considerations;
• whistleblowing and speaking up routes;
• recording requirements; and
• how concerns relating to staff, agency workers, contractors or suppliers must be escalated.

Training will be provided at induction and refreshed at regular intervals. Managers, recruiters, HR staff, safeguarding leads and others in higher-risk roles will receive additional role-specific training.

10. Governance, Oversight and Quality Assurance

We will maintain effective governance systems to assess, monitor and improve our response to modern slavery risks within the service and our supply chain.

This will include:

• periodic review of incidents, concerns, referrals, outcomes and themes;
• audit of recruitment files, right to work checks, supervision records and training compliance;
• review of agency and supplier assurance documentation where relevant;
• monitoring whether safeguarding referrals, escalation and record keeping are timely and appropriate;
• identifying lessons learned and making service improvements; and
• providing information to CQC or other authorities when required.

Responsibility for oversight of this policy sits with the Registered Manager and, where applicable, the Nominated Individual / senior leadership team. Findings from audits, incidents or safeguarding concerns will be reported through the organisation’s governance arrangements and acted upon without delay.

Where the organisation is legally required to do so, it will publish an annual slavery and human trafficking statement in accordance with section 54 of the Modern Slavery Act 2015. Where there is no legal duty to publish such a statement, the organisation may still choose to publish one voluntarily as evidence of transparency and good governance.

11. Confidentiality, Information Sharing and Record Keeping

Information about modern slavery concerns will be shared on a need-to-know basis and in accordance with safeguarding duties, data protection law and the need to protect people from harm.

Staff must make clear, where appropriate, that confidentiality cannot be absolute if there is a safeguarding risk, risk of serious harm, or a legal basis to share information with relevant authorities.

Records must be accurate, contemporaneous, factual, signed or attributable, and stored securely. Managers must ensure that referrals, decisions, external advice, outcomes and follow-up actions are clearly documented and available for governance review.

12. Policy Review and Updates

This policy will be reviewed at least annually and sooner where there are changes in legislation, statutory guidance, CQC guidance, safeguarding procedures, operational learning, incidents, audits or service delivery arrangements.

This policy should be read alongside our Safeguarding Adults Policy, Safeguarding Children Policy, Safer Recruitment Policy, Whistleblowing Policy, Complaints Policy, Incident Reporting Policy, Disciplinary Policy, Equality and Human Rights Policy, and any local authority safeguarding procedures applicable to the areas in which we operate.

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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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