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Modern Slavery Policy

1. Purpose

The purpose of this policy is to ensure that our domiciliary care service takes a zero-tolerance approach to modern slavery and human trafficking in line with the Modern Slavery Act 2015 and Care Inspectorate Wales (CIW) regulations. Our organisation is committed to preventing, identifying, and responding to modern slavery risks, ensuring that all service users, employees, and supply chain workers are protected from exploitation, forced labour, and human trafficking.

We recognise that modern slavery can occur in various forms, including:

• Forced labour – where individuals are compelled to work against their will.
• Human trafficking – where individuals are moved and exploited.
• Debt bondage – where individuals are forced to work to repay debt.
• Domestic servitude – where individuals are forced to work under poor conditions with little or no pay.

This policy outlines the preventative measures, reporting mechanisms, and safeguarding procedures we have in place to combat modern slavery effectively.

2. Scope

This policy applies to:

• All staff, including care workers, supervisors, and managers, within our organisation.
• Service users and their families, ensuring they are not subjected to exploitation.
• Third-party providers and suppliers, ensuring ethical practices in recruitment and procurement.
• External agencies, including local authorities, law enforcement, and safeguarding teams.

It covers:

• Identifying modern slavery and human trafficking.
• Screening and due diligence in recruitment and supply chains.
• Preventative measures and safeguarding responsibilities.
• Reporting mechanisms and responding to modern slavery concerns.
• Staff training and ongoing compliance.

3. Identifying Modern Slavery and Human Trafficking

Modern slavery is often hidden, and victims may be unable or afraid to seek help. Staff must be trained to identify warning signs, including:

3.1 Signs of Modern Slavery in Service Users

• Unexplained injuries or signs of physical abuse.
• Fearful behaviour, appearing withdrawn, anxious, or frightened.
• Lack of personal identification or documents being controlled by someone else.
• Being accompanied or monitored by someone who speaks on their behalf.
• Poor living conditions or reports of being forced to work.

3.2 Signs of Modern Slavery in Staff or Workers

• Unusual dependency on an employer or agency (e.g., working excessive hours without choice).
• Withholding of wages or deductions that are unexplained.
• Confiscation of personal documents (passport, bank details).
• Living in overcrowded or unsuitable conditions.
• Fear of authorities or reluctance to discuss personal matters.

If any red flags are identified, staff must report concerns immediately to the Safeguarding Lead ({{org_field_safeguarding_lead_name}}).

4. Preventing Modern Slavery in Our Organisation

4.1 Ethical Recruitment and Employment Practices

We ensure that all employees are recruited fairly and transparently, with:

• Right-to-work checks on all employees and agency workers.
• No recruitment fees charged to staff.
• No withholding of wages, personal documents, or contracts.
• Freedom for employees to leave their job or refuse work without penalty.
• Access to clear employment terms and conditions.

All external recruitment agencies must comply with ethical hiring practices, and we will only partner with agencies that meet CIW and UK labour standards.

4.2 Safe and Ethical Supply Chains

To prevent exploitation in our supply chain, we ensure:

• All suppliers provide a modern slavery statement and comply with UK employment laws.
• Procurement policies prioritise ethical suppliers, particularly for uniforms, cleaning products, and recruitment services.
• Regular audits and supplier checks to ensure compliance with anti-slavery measures.

Any supplier found engaging in modern slavery practices will have their contract terminated immediately.

5. Reporting and Responding to Modern Slavery Concerns

5.1 Internal Reporting Mechanisms

If staff suspect modern slavery or exploitation, they must:

1. Report concerns immediately to the Registered Manager ({{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}) or the Safeguarding Lead ({{org_field_safeguarding_lead_name}}).
2. Complete an internal incident report, detailing observations and concerns.
3. Avoid direct confrontation with suspected perpetrators to protect the victim.
4. Ensure confidentiality and handle concerns sensitively.

5.2 External Reporting and Multi-Agency Collaboration

If modern slavery is suspected, we will:

• Contact the Local Authority Safeguarding Team ({{org_field_local_authority_authority_name}}).
• Report the case to the Modern Slavery Helpline (08000 121 700).
• In urgent cases, contact the police via 999.
• Cooperate fully with law enforcement, social services, and NGOs.

All safeguarding referrals will be documented, and action plans will be reviewed to prevent recurrence.

6. Supporting Victims of Modern Slavery

6.1 Immediate Safety and Protection

If a service user or staff member is believed to be a victim of modern slavery, we will:

• Ensure immediate safety, providing emergency accommodation if needed.
• Contact social services or specialist support organisations.
• Ensure access to medical and psychological support.

6.2 Long-Term Support

We will work with local authorities, advocacy groups, and mental health professionals to:

• Help victims regain independence through access to benefits, housing, and employment support.
• Provide emotional and psychological support, including trauma-informed counselling.
• Ensure integration into safe working conditions and communities.

7. Staff Training and Compliance

7.1 Mandatory Training on Modern Slavery

All staff must complete modern slavery awareness training, covering:

• How to identify modern slavery and signs of exploitation.
• How to report concerns safely and effectively.
• Legal obligations and responsibilities under the Modern Slavery Act 2015.

7.2 Ensuring Ongoing Compliance

To maintain compliance, our organisation will:

• Conduct annual reviews of modern slavery risks.
• Ensure regular audits of recruitment and supply chain policies.
• Keep updated on CIW and UK government guidelines on modern slavery.

Failure to adhere to this policy may result in disciplinary action, including termination of employment or contracts.

8. Related Policies

This policy should be read alongside:

• Safeguarding Adults from Abuse and Improper Treatment Policy (DCW13).
• Whistleblowing (Speaking Up) Policy (DCW29).
• Recruitment, Selection, and Retention Policy (DCW26).
• Staff Conduct and Code of Ethics Policy (DCW28).
• Confidentiality and Data Protection Policy (DCW34).

9. Policy Review

This policy will be reviewed annually or sooner if there are changes in legislation, best practices, or CIW guidance. The Registered Manager is responsible for ensuring compliance.

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Responsible Person: {{org_field_registered_manager_first_name}} {{org_field_registered_manager_last_name}}
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