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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Modern Slavery Policy

1. Purpose

This policy outlines {{org_field_name}}’s commitment to preventing modern slavery and human trafficking in our operations and supply chains. Modern slavery is a crime that violates fundamental human rights, encompassing slavery, servitude, forced or compulsory labour, and human trafficking. This policy sets out how we ensure our business and supply chains are free from modern slavery and what actions we take when concerns arise.

At {{org_field_name}}, we recognise that the care sector can be vulnerable to exploitation. Therefore, we are committed to creating a safe and transparent working environment where all individuals are treated with dignity, respect, and fairness. We take a zero-tolerance approach to modern slavery and expect the same high standards from our employees, suppliers, and stakeholders.

2. Scope

This policy applies to all employees, contractors, suppliers, and any other stakeholders working with or on behalf of {{org_field_name}}. It is relevant to all aspects of our service provision, including staff recruitment, procurement, and relationships with external providers.

It covers all individuals working at all levels within the organisation, including but not limited to, senior management, employees, agency workers, volunteers, interns, apprentices, suppliers, and service providers. We are committed to ensuring that our operations and those of our supply chain do not contribute to any form of modern slavery.

3. Related Policies

To support the implementation of this policy, the following policies provide additional guidance and should be referred to when necessary:

• Safeguarding Adults and Children Policy – Ensures the protection of vulnerable individuals against harm and exploitation.
• Whistleblowing Policy – Provides guidance for employees to report concerns safely and confidentially.
• Recruitment and Selection Policy – Outlines ethical recruitment practices to prevent forced labour.
• Equality, Diversity, and Inclusion Policy – Supports a culture of respect and fairness.
• Health and Safety Policy – Ensures safe working conditions that mitigate the risk of exploitation.

4. Legislative and Regulatory Framework

This policy aligns with UK and Scottish legal frameworks and industry regulations, including:

• The Modern Slavery Act 2015, which establishes legal requirements for organisations to prevent modern slavery.
• The Human Trafficking and Exploitation (Scotland) Act 2015, which criminalises human trafficking and related offences.
• The SSSC Codes of Practice for Social Service Workers and Employers (2024), ensuring ethical conduct in care services.
• The Health and Social Care Standards: My Support, My Life, which outlines quality expectations in care provision.
• The National Care Standards: Care at Home, ensuring dignity, choice, and safety for individuals receiving care.

5. Our Commitments

5.1 Recruitment Practices

{{org_field_name}} ensures that all recruitment processes are ethical and transparent by:

• Conducting thorough pre-employment checks, including right-to-work verification and enhanced DBS/PVG checks.
• Ensuring all job offers include a detailed written contract, clearly outlining roles, responsibilities, and rights.
• Prohibiting unlawful recruitment fees, ensuring that no worker has to pay for employment opportunities.
• Engaging only with reputable recruitment agencies that adhere to fair labour practices.
• Verifying that agency workers receive fair treatment and are not subjected to coercion or threats.

5.2 Worker Welfare and Support

• Fair Pay: Ensuring all employees are paid at least the National Minimum Wage or Living Wage and are provided with clear payslips.
• Safe Working Conditions: Implementing regular audits to maintain a safe, supportive, and ethical working environment.
• Confidential Support System: Establishing secure and anonymous reporting channels for workers to raise concerns.
• No Forced Labour: Prohibiting withholding of wages, excessive working hours, or control over personal identification documents.

5.3 Training and Awareness

• Mandatory Modern Slavery Training: Educating all staff on how to recognise, prevent, and report modern slavery.
• Management and HR Training: Providing additional training for leadership teams on ethical employment practices.
• Staff Induction and Continuous Development: Ensuring all new employees are made aware of their rights and responsibilities from day one.

5.4 Supply Chain Management

• Supplier Due Diligence: Conducting regular risk assessments to evaluate supplier compliance with ethical labour standards.
• Contractual Obligations: Including anti-slavery clauses in all contracts to enforce compliance.
• Audits and Compliance Reviews: Conducting supplier visits and monitoring working conditions.
• Zero-Tolerance Approach: Taking immediate action against suppliers found to be in breach of modern slavery laws.

5.5 Identifying and Reporting Concerns

All employees and external stakeholders are encouraged to report any suspected cases of modern slavery.

Reporting Mechanism

• Concerns should be reported to the Registered Manager at {{org_field_registered_manager_email}} or via the whistleblowing hotline.
• Reports can also be made to external bodies such as:
  • Local Safeguarding Teams: {{org_field_local_authority_information_link}}
  • Modern Slavery Helpline: 08000 121 700
  • Police (non-emergency): 101

All reports will be taken seriously, investigated promptly, and appropriate actions will be taken.

5.6 Responding to Modern Slavery Cases

If modern slavery is suspected or identified within {{org_field_name}}, the following actions will be taken:

• Immediate Intervention: Ensuring the safety of the individual affected.
• Law Enforcement Engagement: Reporting the case to relevant authorities.
• Victim Support: Providing access to counselling, housing, and financial assistance if needed.
• Internal Investigation: Conducting a full review to prevent future occurrences.
• Corrective Action: Terminating relationships with any suppliers or agencies found guilty of violations.

6. Monitoring and Compliance

To ensure the policy remains effective, {{org_field_name}} will:

• Conduct annual internal audits to assess compliance.
• Perform supplier reviews to maintain ethical standards.
• Keep detailed records of reports and investigations.
• Embed modern slavery risk assessments into governance and risk management strategies.

7. Policy Review

This policy will be reviewed annually or sooner if there are changes in legislation, regulatory requirements, or identified risks related to modern slavery.

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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.