MODERN SLAVERY ACT 2015 OVERVIEW
In accordance with the Modern Slavery Act 2015, Companies must ensure that their company and supply chains are free from slavery which includes:
- Paying less than the minimum wage in that country
- Providing poor conditions or work practice
- Domestic Servitude
- Sex Trafficking
- Forced Labour
- Bonded Labour
- Child Labour
- Forced Marriage
- Trafficking in human beings
In accordance with Section 54 of the Act, all organisations with a turnover over £36 million or more must prepare and publish a slavery and human trafficking statement each financial year
Our annual turnover is less than £36 million. We are a domiciliary care agency providing care to a range of clients who are all classified as vulnerable adults. We recruit and employ staff from within the UK and internationally. We are committed to ensuring that there is no modern slavery or human trafficking in our recruitment or supply chain or in any part of our business. Our Anti-slavery policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing robust systems and controls to ensure slavery and human trafficking are not taking place anywhere in our recruitment, supply chain or our operations.
PURPOSE AND AIM
The purpose of this policy is to outline Versacare’s commitment to maintaining and enforcing effective systems and controls to ensure that slavery is not taking place anywhere within its business and those of its consultants, agents, suppliers and associated others.
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our recruitment or supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our recruitment and supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners and check to ensure they have an Anti-Slavery Policy in place and use and a zero tolerance to modern slavery.
This policy applies to all staff and people working for us or on our behalf in any capacity, including staff at all levels, directors, managers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.
The Managing Director has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The Registered Managers have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. All staff at all levels are responsible for reporting any suspicions or concerns to Registered Managers at the earliest opportunity. We expect our staff to abide by this policy and help create a transparent environment regarding Anti-Slavery within Versacare, in line with the Modern Slavery Act 2015.
COMMUNICATiON AND AWARENESS OF THIS POLICY
Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
IDENTIFYING AND REPORTING MODERN SLAVERY CONCERNS
Staff are advised to report any incidents they know or hear of in the workplace and/or through their association with others by reporting their concerns to a Registered Manager at Versacare at the earliest opportunity by phone or email. The detection and reporting of slavery is the responsibility of us all. Concerns should be raised about any issue or suspicion of modern slavery in any part of our business at the earliest possible stage.
To ensure that we are being effective, the actions which we take and will continue to take are:
- Identify and assess potential risk areas in our recruitment and supply chain, so that we can mitigate the risk of slavery and human trafficking occurring.
- Make sure our worker documentation is up to date, and our verification systems are robust and designed to highlight any areas of concern within current staff or applicants
- Maintain open communication within our recruitment and supply chain to ensure understanding of expectation and compliance.
- Ensure that staff and managers are advised of the organisation’s ethos and principles in relation to anti-slavery and human trafficking via this policy, staff training and staff newsletters.
- Ensure that staff and managers are advised how to report any incidents they know about or hear of in the workplace and/or through their association with others, via this policy, staff training and staff newsletters.
- Encourage and remind all staff to that they the can report any concerns in strictest confidence and remain anonymous throughout if requested/needed.
COMPLIANCE WITH THIS POLICY
All staff must ensure that they read, understand and comply with this policy.
Any questions or concerns about whether a particular act, the treatment of staff more generally, or their working conditions within any area of our business or supply chains constitutes any of the various forms of modern slavery, should be raised with the Registered Manager.
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our recruitment or supply chains.
Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern – if you believe that you have suffered any such treatment, you should inform a Registered Manager immediately.
The prevention, detection and reporting of modern slavery in any part of our organisation is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy, and encouraged to raise any concerns with the Registered Manager.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify a Registered Manager as soon as possible.
The Managing Director we engage with and provide guidance to our suppliers to help them address coercive, abusive and exploitative work practices in their own business and supply chains, if it is identified or suspected.
We do not employ subcontractors but before working with subcontractors our Managing Director would ensure that we:
- Assess the modern slavery and human trafficking risks of each new supplier.
- Engage with our suppliers both to convey to the modernslavery and human trafficking policy and to gain an understanding of the measures taken by them to ensure modern slavery is not occurring in their businesses.
BREACHES OF THIS POLICY
Any member or staff who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy, and report our findings or suspicions to the relevant authorities.