{{org_field_logo}}

{{org_field_name}}

Registration Number: {{org_field_registration_no}}

---

Modern Slavery Policy

1. Purpose

The purpose of this policy is to ensure that {{org_field_name}} is committed to the prevention of modern slavery and human trafficking within our organisation and supply chains. We recognise our legal and ethical responsibilities to prevent and address modern slavery in any form.

Modern slavery encompasses slavery, servitude, forced or compulsory labour, and human trafficking. These serious crimes exploit vulnerable individuals, including those who use our services, employees, and third parties within our supply chains.

This policy is designed to:

• Establish a zero-tolerance approach to modern slavery.
• Outline preventative measures embedded in our governance, recruitment, procurement, and safeguarding processes.
• Ensure compliance with the Modern Slavery Act 2015, CQC Fundamental Standards, and Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.
• Provide clear reporting procedures for concerns related to modern slavery.
• Promote awareness and training to staff to identify and prevent modern slavery risks.

2. Scope

This policy applies to:

• All staff (including permanent, temporary, and agency staff).
• Volunteers and contractors providing services for {{org_field_name}}.
• Suppliers, partners, and any third-party organisations we engage with.
• People who use our services and their families, ensuring they are safeguarded from exploitation.

3. Legal and Regulatory Framework

This policy aligns with:

• Modern Slavery Act 2015 – requires businesses to disclose steps taken to prevent slavery in their operations.
• Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 – mandates safeguarding of service users.
• Care Act 2014 – imposes a duty to prevent neglect, abuse, and exploitation.
• Equality Act 2010 – protects against discrimination and exploitation.
• CQC Regulations (Regulation 13: Safeguarding and improper treatment)– requires robust safeguarding procedures to prevent abuse and exploitation.

4. Commitment to Prevention and Detection

4.1 Leadership and Governance

{{org_field_name}} is committed to ensuring our leadership actively monitors and enforces our anti-slavery commitments. We achieve this by:

• Ensuring our Board and senior management take full responsibility for addressing modern slavery risks.
• Designating a Modern Slavery Lead within our Safeguarding team.
• Conducting annual reviews of modern slavery risks and mitigation strategies.
• Including modern slavery as a standing agenda item in governance meetings.

4.2 Risk Assessments and Due Diligence

We proactively assess and mitigate risks of modern slavery within our organisation and supply chains by:

• Conducting annual risk assessments to identify high-risk areas (e.g., recruitment, suppliers, contractors).
• Implementing enhanced checks for suppliers operating in high-risk regions or industries.
• Requiring all suppliers to comply with our Supplier Code of Conduct, which includes anti-slavery provisions.
• Conducting spot-checks and audits to ensure compliance.

4.3 Ethical Recruitment Practices

We ensure that all staff are recruited legally, fairly, and ethically, preventing forced labour by:

• Conducting enhanced DBS checks and verifying right-to-work documentation.
• Prohibiting recruitment agencies that charge workers fees or retain their identity documents.
• Implementing a Whistleblowing Policyto enable staff to report unethical recruitment practices.
• Providing contracts in accessible formats to ensure staff fully understand their rights.

4.4 Training and Awareness

We provide regular training to ensure all employees understand and can identify modern slavery risks. Our training includes:

• Induction training for all new employees on recognising modern slavery.
• Annual safeguarding refresher courses that cover modern slavery indicators.
• Specialised modern slavery training for managers, HR teams, and procurement staff.

5. Identifying and Reporting Modern Slavery

5.1 Signs of Modern Slavery

All staff must remain vigilant to signs of modern slavery, including:

• Restricted movement or isolation of individuals.
• Poor living conditions or signs of being controlled by another person.
• Reluctance to speak or lack of access to personal identification documents.
• Working excessively long hours for low or no pay.
• Unexplained injuries or signs of physical abuse.

5.2 Reporting Concerns

Staff who suspect modern slavery must report concerns immediately to:

• Their line manager or Modern Slavery Lead.
• The Safeguarding Team if the concern involves a service user.
• Local authorities or the Modern Slavery Helpline (08000 121 700).

Reports will be handled confidentially and sensitively, ensuring no staff member faces retaliation for reporting concerns.

6. Managing Modern Slavery Risks in Our Supply Chains

6.1 Supplier Expectations

We expect all suppliers to uphold ethical labour practices and comply with our Supplier Code of Conduct, which requires:

• Adherence to the Modern Slavery Act 2015.
• Regular risk assessments and compliance checks.
• A commitment to fair wages and working conditions.

6.2 Auditing and Compliance

We conduct regular supplier audits to verify compliance. Any supplier found in violation will:

• Be required to take immediate corrective action.
• Face contract termination if non-compliance persists.

7. Supporting Victims of Modern Slavery

If an individual within our service is identified as a potential victim of modern slavery, we will:

• Prioritise their safety and engage safeguarding teams.
• Refer them to specialist support organisations, such as the Salvation Army or local safeguarding boards.
• Work closely with law enforcement and social services to ensure proper intervention.

8. Continuous Improvement and Monitoring

8.1 Performance Indicators

We will measure our progress through:

• The number of modern slavery reports received and resolved.
• Training completion rates among staff.
• Supplier audit results and compliance levels.

8.2 Board Oversight

Our Board of Directors will receive an annual modern slavery report, outlining key risks, actions taken, and future improvements.

9. Policy Review

• This Policy will be reviewed annually or in response to any legislative changes.
• Updates will be communicated to all staff and stakeholders.

---

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.