Our Commitment
 
Modern slavery is a serious crime and a violation of human rights. We are committed to preventing slavery, servitude, forced or compulsory labour, and human trafficking in our organisation and supply chains. We act with honesty, integrity, and fairness in all relationships and expect the same from our partners.
 
 
Scope
 
This policy explains the steps we take to ensure modern slavery and human trafficking are not occurring within our business or supply chains. It links directly to our Safeguarding Adults and Safeguarding Children in an Adult Settingpolicies.
 
 
Equality Statement
 
We promote equal rights, person-centred care, independence, and respect for all. We work to identify and remove discrimination across protected characteristics (Equality Act 2010) and uphold the Human Rights Act 1998.
 

Key Points
 

• Modern slavery abuses human rights and often involves violence and coercion.

• Human trafficking involves the movement of people through force, fraud, or deception for exploitation.

• Forced/compulsory labour is any work done under threat of penalty without freely given consent.

• We train staff to recognise indicators and report concerns promptly.

• We extend our values to service users and families, suppliers, commissioners, and stakeholders.

 

What We Do (Policy in Practice)
 

• Recruitment: Safer recruitment compliant with UK law; right-to-work, identity, employment history, and qualifications verified.

• Agency Workers: We check agencies’ practices before accepting workers.

• Pay: Employees are paid fairly and directly to personal bank accounts.

• Business Planning: Safeguarding risks, including trafficking, are addressed in our plans.

• Safeguarding: Policies integrated with local authority procedures and kept up to date.

• Training: Mandatory induction includes safeguarding for adults and children; competence monitored via supervision and spot checks.

• Whistleblowing: Protected disclosures per Public Interest Disclosure Act 1998; concerns can be raised anonymously.

• Complaints: Complaints are investigated and used to drive continuous improvement.

 

Definitions & Indicators

Modern slavery includes sexual exploitation, domestic servitude, forced labour, criminal exploitation, child exploitation (e.g., forced begging, drug cultivation), forced marriage/illegal adoption (where applicable), and organ harvesting.

ILO indicators include abuse of vulnerability, deception, restricted movement, isolation, violence, threats, retention of documents, withholding wages, debt bondage, abusive conditions, and excessive overtime.
 

Supply Chains & Due Diligence
 

• We expect suppliers to comply with the Modern Slavery Act 2015 and ethical employment practices.

• Procurement is audited at each stage with modern slavery checks; findings are reported to leadership with action plans.

• Annual supply-chain mapping identifies high-risk suppliers for enhanced due diligence (policies, statements, recruitment practices, remedial actions).

• Where suppliers won’t meet required standards, we will seek alternatives and may terminate contracts.

 
Modern Slavery Statements
 

• UK organisations with turnover £36m+ must publish an annual Modern Slavery Statement.

• Although below the threshold, we commit to transparency that is proportionate to our size and risk profile and will review this position as we grow.

 

Reporting Concerns
 
If you suspect modern slavery (in our organisation or a supplier), report it immediately.
 
Internally: Tell your line manager (or use Whistleblowing/Grievance routes to remain anonymous).
Externally (as appropriate):
 

• Unseen – Modern Slavery Helpline: 08000 121 700

• Gangmasters & Labour Abuse Authority (GLAA): 0800 432 0804 or intelligence@glaa.gsi.gov.uk

• Home Office (immigration crime): 0300 123 7000

• National Crime Agency (MSHTU)

• Police: 101 (non-emergency) or 999 (emergency)

• Local Safeguarding: Wiltshire SVPP 0300 456 0108; Somerset SCP 0300 123 2224

• Care Quality Commission (CQC): 03000 616 161 | enquiries@cqc.org.uk

 
We will support staff to raise concerns and ensure access to appropriate advice and agencies.
 

Quality Statements (CQC)
 

• Learning culture: We investigate safety events thoroughly and share learning.

• Safeguarding: We protect people’s right to live free from abuse, neglect, and discrimination.

• Safe & effective staffing: Sufficient, skilled staff with effective supervision and development.

• Workforce wellbeing: We promote staff wellbeing to enable person-centred care.

• Shared direction & culture: Our vision is rooted in transparency, equity, and inclusion.

• Inclusive leadership: Leaders act with integrity and embody our values.

• Freedom to speak up: People feel safe to raise concerns.

• Workforce EDI: We value diversity and work towards an inclusive, fair culture.

• Governance: Clear roles, accountability, risk management, and secure information sharing.