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{{org_field_name}}

Registration Number: {{org_field_registration_no}}

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Modern Slavery Policy

{{org_field_name}}

1. Purpose

The purpose of this Modern Slavery Policy is to outline the firm commitment of {{org_field_name}} to combat modern slavery, human trafficking, servitude, and forced or compulsory labour within our operations, supply chains, and the provision of services. Modern slavery is a violation of fundamental human rights and is a criminal offence under the Modern Slavery Act 2015. We recognise the vital role we play, as a healthcare staffing agency supplying temporary registered nurses and healthcare assistants to care homes, in identifying, preventing, and responding to any risks of modern slavery. This policy aims to establish clear systems and controls to ensure that modern slavery has no place within our organisation or in those we do business with.

2. Scope

This policy applies to:

• All directors, managers, staff, and workers engaged directly by {{org_field_name}}, including zero-hours workers and bank staff.
• All agency workers engaged via {{org_field_name}} and supplied to external clients (care homes).
• All third-party suppliers, umbrella companies, and service providers with whom we have a commercial relationship.

This policy must be adhered to by all employees and is equally applicable when working on assignments at client locations.

3. Related Policies

• Recruitment Policy
• Whistleblowing Policy
• Safeguarding Adults and Children Policy
• Equality, Diversity and Inclusion Policy
• Complaints Policy
• Grievance and Disciplinary Policy
• Code of Conduct
• Health and Safety Policy

4. Policy Statement

{{org_field_name}} strictly prohibits the use of modern slavery, human trafficking, forced or compulsory labour, and all forms of servitude. We are committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or supply chains.

5. Legal Framework

This policy has been developed in line with the following legislation:

• Modern Slavery Act 2015
• The Health and Social Care Act 2008 (Regulated Activities) Regulations 2014
• The Employment Rights Act 1996
• The Agency Workers Regulations 2010
• The Equality Act 2010
• The Health and Safety at Work etc. Act 1974

6. Responsibilities

Directors and Senior Management
The directors of {{org_field_name}} are responsible for ensuring that this policy is implemented effectively. This includes:

• Conducting annual modern slavery risk assessments of the business and supply chains.
• Overseeing the development and delivery of mandatory training to all staff.
• Allocating sufficient resources to maintain compliance with the Modern Slavery Act 2015.
• Ensuring all contracts with third parties include clauses to prevent modern slavery.
• Reviewing all recruitment practices to ensure compliance and fairness.
• Approving annual Modern Slavery Statements (where legally required).

Managers

• Ensure staff understand and comply with this policy.
• Monitor agency workers on assignments to identify potential signs of modern slavery.
• Ensure all recruitment is done transparently and that no worker is charged recruitment fees.
• Report any concerns regarding modern slavery to the Registered Manager immediately.

All Staff

• Must not engage in or facilitate modern slavery practices.
• Must immediately report any suspicion of modern slavery or exploitation.
• Must comply with the Whistleblowing Policy and be prepared to act without fear of reprisal.

7. Managing Risks

Recruitment and Vetting

• All candidates undergo strict pre-employment checks, including proof of right to work, identity verification, DBS checks, and reference checks, as outlined in our Recruitment Policy.
• We will not work with third-party recruitment agencies that charge workers fees.
• Employment contracts are issued in clear and understandable terms to all workers.
• Zero-hours workers are informed of their rights regarding rest breaks, holiday pay, minimum wage, and protection from unfair treatment under the Working Time Regulations 1998 and the Employment Rights Act 1996​.

Supply Chain Due Diligence

• All suppliers, umbrella companies, and subcontractors must comply with our Supplier Code of Conduct, which includes clauses against modern slavery.
• We will conduct annual reviews of suppliers to ensure ongoing compliance.
• Any supplier found to be engaging in modern slavery will have their contract terminated immediately.

Training

• All staff, including directors, managers, nurses, and healthcare assistants, will complete annual modern slavery awareness training.
• The training will cover:
  • Identifying signs of modern slavery
  • Reporting concerns
  • The role of agency staff in safeguarding
  • Compliance with whistleblowing obligations

Monitoring of Workers on Assignments

• Regular welfare checks will be undertaken for agency workers, including informal one-to-one discussions during supervision.
• We will pay particular attention to indicators such as:
  • Workers appearing fearful or distressed
  • Workers being accompanied or controlled by third parties
  • Poor accommodation or living conditions
  • Retention of personal documents by third parties

8. Reporting Concerns

Internal Reporting

• All concerns must be reported to the director of {{org_field_name}}

External Reporting

• In cases where immediate safety is at risk, staff must contact the police via 999.
• For advice, the Modern Slavery Helpline (08000 121 700) is available 24/7.
• Staff may also raise concerns via the Care Quality Commission (CQC) or the Employment Agency Standards Inspectorate.

9. Confidentiality and Protection for Whistleblowers

All reports made under this policy will be handled sensitively and confidentially. {{org_field_name}} guarantees that no worker will suffer any detriment or retaliation for raising concerns about modern slavery, provided the report is made in good faith.

10. Continuous Improvement

Annual Review

• This policy and associated procedures will be reviewed annually by the Board of Directors and the Registered Manager.
• It will also be reviewed immediately following any legislative change, regulatory update, or if incidents related to modern slavery arise.

Audit and Feedback

• Periodic internal audits will be carried out to ensure ongoing compliance.
• Staff will be invited to give feedback on the implementation of this policy through surveys and training sessions.

11. Policy Review

This policy will be reviewed every 12 months or sooner if there is a change in legislation, regulatory guidance, or operational need.

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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.