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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 aligns with the following legislation and regulatory requirements:

• Modern Slavery Act 2015 – Establishes the legal framework to prevent slavery, human trafficking, and forced labour.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – Ensures safe and ethical employment practices within the care sector.
• Equality Act 2010 – Prevents discrimination and ensures fairness in recruitment and employment.
• Care Quality Commission (CQC) Fundamental Standards – Requires care providers to have robust governance, employment, and safeguarding policies in place.
• The Gangmasters (Licensing) Act 2004 – Prevents worker exploitation through illegal recruitment practices.

4. Our Commitment to Preventing Modern Slavery

We are committed to:

• Ensuring that all staff are employed voluntarily, with fair wages, legal contracts, and transparent working conditions.
• Verifying that all suppliers and third-party service providers adhere to ethical employment practices.
• Providing clear reporting mechanisms to detect and act upon any suspicions of modern slavery.
• Promoting an organisational culture where all staff feel safe, valued, and empowered to report concerns.
• Conducting regular risk assessments to identify potential vulnerabilities in our workforce and supply chain.

5. Recruitment and Employment Practices

We implement strict policies to ensure ethical recruitment and employment practices:

• Right to Work Checks: All employees must provide valid documentation proving their legal right to work in the UK.
• Fair Contracts: All employees receive contracts that clearly outline their terms of employment, wages, working hours, and rights.
• No Recruitment Fees: We do not charge or allow third-party agencies to charge recruitment fees to employees.
• Freedom of Movement: Employees must not be required to surrender passports, identification documents, or bank cards as a condition of employment.
• Safe and Inclusive Work Environment: We promote fair working conditions, equal pay, and zero tolerance for harassment or exploitation.
• Whistleblowing Protections: Employees are encouraged to report any concerns regarding unethical employment practices without fear of retaliation.

6. Supply Chain Due Diligence

As part of our commitment to ethical business practices, we conduct due diligence on all suppliers and contractors, ensuring that they:

• Comply with the Modern Slavery Act 2015 and related legislation.
• Have ethical employment practices in place.
• Provide fair wages and working conditions to their employees.
• Have transparent supply chains free from forced or bonded labour.
• Undergo regular audits and assessments to confirm compliance.

Contracts with suppliers include provisions requiring compliance with modern slavery laws, and any supplier found in violation will be subject to termination of the business relationship.

7. Identifying and Reporting Modern Slavery

We recognise that modern slavery can be difficult to detect. Therefore, all staff are trained to identify signs of exploitation, including:

• Workers showing signs of fear, distress, or reluctance to speak freely.
• Individuals who appear to be under the control of others.
• Employees living in poor, overcrowded conditions or having excessive wage deductions.
• Individuals without access to their own identification documents or financial resources.

If modern slavery is suspected, the following reporting procedures apply:

• Internal Reporting: Staff should report concerns to their line manager or designated safeguarding lead.

Where to report:

1) Verbally to the Registered Manager or Safeguarding Lead

2) Inform the Registered Manager by email: {{org_field_registered_manager_email}}

3) Call the office and inform the Registered Manager or Safeguarding Lead: {{org_field_phone_no}}

4) Out of hours phone number: {{out_of_hours}}

5) Online via our website: {{org_field_website}}

• External Reporting: Serious concerns may be reported to the police, the Gangmasters and Labour Abuse Authority (GLAA), or the Modern Slavery Helpline (08000 121 700).

All reports are taken seriously and investigated promptly to ensure the safety and well-being of affected individuals.

8. Staff Training and Awareness

To ensure that all employees understand the risks of modern slavery and how to report concerns, we provide:

• Modern Slavery Training: Staff receive training on recognising and responding to modern slavery indicators.
• Regular Refresher Training: Annual updates to reinforce best practices and new legal requirements.
• Specialist Training for Managers and HR Staff (where applicable): Enhanced training on ethical recruitment and handling suspected cases of modern slavery.
• Accessible Learning Materials: Leaflets, posters, and digital resources available in multiple languages to ensure inclusivity.

9. Governance and Compliance Monitoring

We maintain robust governance structures to ensure compliance with modern slavery regulations:

• Annual Modern Slavery Risk Assessments: Reviewing policies, supplier contracts, and employment practices for vulnerabilities.
• Quarterly Management Reviews: Senior leadership evaluates effectiveness and addresses any identified risks.
• Audit of Supply Chains: Conducting supplier assessments to confirm ethical practices.
• Compliance Reports: Annual statements are published in line with Section 54 of the Modern Slavery Act 2015.

10. Policy Review and Updates

This policy is reviewed annually or when significant changes occur in legislation or operational practices. Any updates are communicated to all staff, and additional training is provided as necessary to ensure continued compliance.

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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.