Policy Statement

This policy applies to all Organisation’s within the Optimo Care Group including,
WarrenCare, TLC Homecare, Town & Local Care, Choices Homecare and Care with
Choices.

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 supply chains.

This policy has been written to comply with Regulation 19 of the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014 and should be read in conjunction with the Whistleblowing Policy.

Aim of the Policy

The aim of this policy is to create awareness of modern slavery, including; servitude, forced and compulsory labour and human trafficking. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, agency workers, seconded workers, volunteers, contractors, external consultants, third-party representatives and business partners.

Access to this Policy

This policy can be made available in other languages and alternative formats e.g. large print, easy read, computer disk, via email. For more information please contact the Registered Manager.

Legal Requirements
The Organisation will establish and maintain policies to ensure compliance with the
Modern Slavery Act 2015, the Care Act 2014 and the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

Responsibility

The Senior Management Team and Board of Directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Modern Slavery Definition

Modern slavery can take many forms including the trafficking of people, forced labour, servitude and slavery. Any consent victims have given to their treatment will be irrelevant where they have been coerced, deceived or provided with payment or benefit to achieve that consent.

The term ‘modern slavery’ captures a whole range of types of exploitation, many of
which occur together. These include but are not limited to:

• Sexual exploitation – this includes but is not limited to sexual exploitation and abuse, forced prostitution and the abuse of children for the production of child abuse images/ videos. Whilst women and children make up the majority of victims, men can also be affected. Adults are coerced often under the threat of force, or other penalty
• Domestic servitude – this involves a victim being forced to work, usually in private households, performing domestic chores and child care duties. Their freedom may be restricted and they may work long hours often for little pay or no pay, often sleeping where they work
• Forced labour – victims may be forced to work long hours for little or no pay in poor conditions under verbal or physical threats of violence to them or their
  families
• Criminal exploitation – this is the exploitation of a person to commit a crime, such as pick pocketing, shop-lifting, cannabis cultivation, drug trafficking and other similar activities
• Other forms of exploitation may include organ removal, forced begging, forced benefit fraud, forced marriage and illegal adoption
• Human trafficking – for a person to have been a victim of human trafficking there must have been: action (e.g. recruitment, transportation); means (threat or use of force, coercion, abduction, fraud. NB. there does not need to be a means for children as they are not able to give informed consent); purpose of exploitation (e.g. sexual exploitation, forced labour or domestic servitude, slavery, financial exploitation, illegal adoption, removal of organs).

There are many different characteristics that distinguish slavery from other human rights violations, however only one needs to be present for slavery to exist. Someone is in slavery if they are:

• Forced to work – through mental or physical threat
• Owned or controlled by an ’employer’, usually through mental or physical abuse or the threat of abuse
• Dehumanised, treated as a commodity or bought and sold as ‘property’
• Physically constrained or has restrictions placed on his/her freedom of movement
• Humans who are trafficked, recruited and transported for example using threats, to coerce or force a person into sexual exploitation, forced labour or domestic servitude.

Contemporary slavery takes various forms and affects people of all ages, gender and
races. Adults who are enslaved are not always subject to human trafficking. Recent
court cases have found homeless adults promised paid work opportunities enslaved and forced to work and live in dehumanised conditions, and adults with a learning difficulty restricted in their movements and threatened to hand over their finances and work for no gains.

Taking Action

If you believe a person is being trafficked and is in immediate danger, you should call 999 straight away.

You can also report suspicions of trafficking by calling 101 or visiting your local police station.

You can also provide information to Crimestoppers anonymously on 0800 555 111.

If the person has needs for care and support, and is unable to protect themselves as a result, a safeguarding concern must also be raised. For information on the National Referral Mechanism go to: www.gov.uk/government/publications/duty-to-notify-the-home-office-of-potentialvictims-of-modern-slavery

For information and advice, refer to the Modern Slavery Helpline:

08000 121 700
www.modernslavery.co.uk

Compliance

The Organisation is devoted to ensuring that:

• Slavery and human trafficking is considered and addressed in our approach to
  corporate social responsibility
• Any concerns about slavery or human trafficking can be raised by employees
  through our Whistleblowing Policy
• Regular audits are carried out by the Organisation to ensure that our employees are paid at the legal minimum wage
• Our Central Service Departments are aware of suspicious activities, such as; bank accounts not being in the employee’s name and the same emergency contact being provided for multiple employees
• All employees have the legal right to work in the UK
• All commercial agreements include an obligation on our suppliers to operate in accordance with the Modern Slavery Act 2015, and ensure that any of their
  suppliers and sub-contractors also operate in accordance with the Act
• Any ‘high risks’ in our supply chain are identified and addressed
• Training on issues relating to slavery and human trafficking is provided for all employees.

All employees must comply with the below:

• The prevention, detection and reporting of modern slavery in any part of our
  business or supply chains 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
• You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future
• You are encouraged to raise concerns about any issue or suspicion of modern
  slavery in any parts of our business or supply chains at the earliest possible stage
• If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible
• If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions constitutes any of the various forms of modern slavery, raise it with your 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 in good faith 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 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 your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure.

Breaches

Any employee 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.

Training

Our zero-tolerance approach to modern slavery must be communicated to all
employees, suppliers and business partners.

Review of this Policy

This policy will be reviewed by the Registered Manager or a representative in their
absence not later than October 2021. It will be reviewed in response to changing
legislative at least every three years.

Review of this Policy
Title: Registered Manager
Date: October 2018
Policy Review Date: October 2021