MODERN SLAVERY AND HUMAN TRAFFICKING POLICY
1. INTRODUCTION
1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty for personal or commercial gain.
1.2 Someone is in slavery if they are:
● Forced to work through coercion, or mental or physical threat;
● Owned or controlled by an employer through mental or physical abuse or the threat of abuse;
● Dehumanized, treated as a commodity, or bought and sold as ‘property’;
● They face physical confinement or restrictions on their freedom of movement.
1.3 Human trafficking involves the recruitment, harboring, or transporting of people into situations of exploitation through the use of violence, deception, or coercion, forcing them to work against their will.
1.4 Victims often seek to escape poverty and improve their lives, sometimes accepting offers of work in other regions or abroad. Traffickers may manipulate them through debt, threats, or exploitation of vulnerability.
1.5 The social care sector employs a significant number of workers from abroad, placing a responsibility on us to take robust measures to prevent modern slavery and human trafficking in our operations and supply chains.
2. ORGANIZATION STRUCTURE, BUSINESS, AND SUPPLY CHAINS
2.1 Warren Homecare Ltd is a provider of care and support services, including domiciliary care, supported living, complex care, and related services to vulnerable individuals. 2.2 Our supply chains include the procurement of goods (such as care equipment, medical supplies, and office resources) and services (such as training, recruitment, and maintenance). We engage with UK-based and, where relevant, international suppliers.
2.3 We operate with a clear hierarchy led by the Managing Director, supported by senior managers, team leaders, and operational care staff. All procurement and recruitment decisions are made under our corporate governance framework.
3. POLICY STATEMENT
3.1 Warren Homecare Ltd pledges to prevent modern slavery and human trafficking in its operations and supply chains.
3.2 We will act ethically and with integrity in all our business relationships and implement effective systems and controls to ensure slavery and human trafficking are not taking place.
4. DUE DILIGENCE PROCESSES
4.1 We undertake due diligence when considering taking on new suppliers and regularly review existing suppliers. This includes:
● Evaluating the modern slavery and human trafficking policies of suppliers; ● Risk assessing potential suppliers based on location, industry, and reputation;
● Ensuring all recruitment agencies we engage with are compliant with the Modern Slavery Act 2015;
● Maintaining supplier records and conducting periodic checks.
5. RISK ASSESSMENT AND MANAGEMENT
5.1 Parts of our business and supply chain where there is a higher risk include: ● Recruitment of overseas staff;
● Use of third-party labour agencies;
● Procurement from suppliers based in higher-risk countries or industries. 5.2 Steps we take to assess and manage these risks include:
● Only working with reputable, registered recruitment agencies;
● Conducting identity verification and right-to-work checks for all employees; ● Requiring suppliers to confirm their compliance with anti-slavery legislation; ● Periodic supplier audits.
6. EFFECTIVENESS MEASURES
6.1 We measure our effectiveness in ensuring modern slavery and human trafficking are not taking place by:
● Monitoring supplier compliance through questionnaires and reviews;
● Recording and investigating any reported concerns or breaches;
● Tracking the number of staff trained on modern slavery awareness;
● Reporting annually to the Board on compliance with the Modern Slavery Act 2015.
7. TRAINING AND CAPACITY BUILDING
7.1 Training on modern slavery and human trafficking is provided to all staff as part of induction and refresher programmes.
7.2 Managers and senior staff receive additional training on identifying signs of modern slavery, reporting mechanisms, and supplier due diligence.
7.3 We maintain resources and guidance for staff to support awareness and reporting.
8. PREVENTATIVE MEASURES
8.1 We will not knowingly support or cooperate with any business involved in slavery or human trafficking.
8.2 Any member of staff found to be involved in modern slavery or human trafficking will be subject to disciplinary procedures.
8.3 This policy is communicated to all employees, suppliers, and contractors.
This policy will be reviewed annually or sooner if there are significant changes in legislation or our business operations