Modern Slavery and Human Trafficking Policy

Modern Slavery and Human Trafficking Policy and Procedure

Last Reviewed: 6 June 2025 Last Amended: 3 August 2023 Review Interval: Annual

1. Purpose

1.1 To ensure that everyone at Pride Home Care Limited is aware of the Modern Slavery and Human Trafficking Policy and Procedure and the procedures in place to identify, respond appropriately and report in line with local and national guidance. This policy refers to adults who may be at risk; the procedure for children is detailed in the Safeguarding Children and Child Protection Policy and Procedure.

1.2 This policy must be read alongside the Safeguarding Adults Policy and Procedure. Pride Home Care Limited will ensure that staff understand Norfolk County Council safeguarding reporting procedures and that these procedures are communicated to all staff. Other related policies include the Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure, Safeguarding Children and Child Protection Policy and Procedure, the Recruitment Policy and Procedure, the Right to Work Checks Policy and Procedure, and the Agency Staff Policy and Procedure.

1.4 Relevant Legislation: Health and Safety at Work etc. Act 1974 Human Rights Act 1998 The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012 The Modern Slavery Act 2015

2. Scope

Roles Affected: All Staff, Registered Manager, Other Management People Affected: Service Users Stakeholders Affected: Commissioners, Local Authority

3. Objectives

3.1 To promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of Pride Home Care Limited in addressing slavery and human trafficking in all its forms. An annual statement will be produced where applicable.

3.2 To ensure that identification, protection, care and support for victims of modern slavery and human trafficking is at the heart of our safeguarding procedures at Pride Home Care Limited.

4. Policy

4.1 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 include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

4.2 Pride Home Care Limited has a zero-tolerance approach to modern slavery within the business and supply chains and we are committed to acting ethically and with integrity in all our dealings and relationships. We will implement and enforce effective systems and controls to ensure that modern slavery is not taking place anywhere in Pride Home Care Limited or within any third parties (agencies) that we are associated with.

4.3 All staff will be made aware of the issues surrounding slavery and human trafficking, whilst being encouraged and supported to report any concerns to Pride Home Care Limited management. Pride Home Care Limited will also support any staff that may be subject to slavery or human trafficking.

4.4 Where modern slavery or human trafficking is identified, Pride Home Care Limited will share information with the Norfolk County Council Safeguarding Team to safeguard the individual from harm and with the objective of preventing future situations arising, to promote the elimination of routes and sources of slavery or human trafficking.

4.5 All line managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.

4.6 All employees who suspect any members of the workplace of being a victim of modern slavery must notify their line manager.

4.7 Pride Home Care Limited will take steps to ensure that sufficient communication and employee awareness training is undertaken with regards to Modern Slavery.

4.8 All employees will be made aware of the Raising Concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure at Pride Home Care Limited. The purpose of this policy is to enable Pride Home Care Limited to thoroughly investigate allegations of any wrongdoing raised by employees without fear of reprisal.

4.9 Pride Home Care Limited will use this policy to underpin and inform any statement on slavery and human trafficking that we may be required to produce to meet the requirements of Section 54 of the Modern Slavery Act 2015.

5. Procedure

5.1 Reporting Modern Slavery and Human Trafficking Concerns

The following procedure must take place where there are any concerns that someone is a victim of modern slavery or human trafficking. Staff must be aware that victims will often not self-identify and may present with a different issue.

A concern is identified – this could be the Service User as a victim or perpetrator, or the Service User informs us of a concern they have.
If an individual or group of people are in immediate risk of danger or harm, the police must be immediately notified on 999.
The staff member must discuss this with their line manager (where appropriate) and Sally Galloway immediately.
Sally Galloway contacts and escalates the concern immediately to Norfolk County Council Safeguarding Adults Team.
A notification is made to the CQC via the provider portal.

5.2 Safer Recruitment

All staff engaged with providing services at Pride Home Care Limited will be subject to thorough and rigorous recruitment procedures including a DBS check, identity check, confirmation of validity to work in the UK, employment history, suitability for the role, and references. Pride Home Care Limited will follow the Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times.

5.3 Pride Home Care Limited will only use staff provided by third-party organisations (such as agencies) that are either registered with the regulator or who can confirm that the staff being supplied are free to work in the UK and meet all the requirements for the role.

5.4 Training

All staff will undertake training on modern slavery and human trafficking. Indicators of modern slavery include:

Individuals not being paid for the work they undertake
Individuals being held in debt-bondage
An individual’s passport being held by their employer
Multiple benefit claimants having benefits paid into the same account
Clear exploitation of an individual for financial or sexual gain
Signs of physical or psychological abuse; looking malnourished or unkempt, anxious, withdrawn or neglected, with possible untreated injuries
Rarely allowed to travel alone; appearing under the control of others or unfamiliar with their neighbourhood
Relationships which do not seem right – for example, a young teenager appearing to be in a relationship with a much older adult
Living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address
No identification documents, few personal possessions, always wearing the same clothes; clothing may be unsuitable for their work
Little opportunity to move freely; travel documents may have been retained
Dropped off or collected for work regularly either very early or late at night
Unusual travel arrangements involving children being transported at unusual times
Avoiding eye contact; appearing frightened or hesitant to talk to strangers; fear of law enforcers, deportation, or violence to themselves or their family

5.5 Staff will be advised that if they are subject to slavery or human trafficking, or if they are aware of any individual that may be subject to slavery or has been trafficked, they must inform the Registered Manager of Pride Home Care Limited or the police as soon as possible.

If a member of staff is unsure whether a particular act, the treatment of workers, or working conditions constitutes a form of modern slavery, they should raise it with the Registered Manager.

5.6 Modern Slavery Annual Reporting

Under section 54 of the Modern Slavery Act 2015, certain businesses are required to publish an annual modern slavery statement setting out the steps taken to identify and address modern slavery risks. Pride Home Care Limited will continue to identify and address risks of modern slavery in its operations and supply chains, and will consider how fluctuations in demand and changes in the operating model may lead to new or increased risks of labour exploitation.

5.7 Recruitment Risks

Pride Home Care Limited will ensure that rigorous recruitment checks are maintained and that suppliers adhere to robust processes to ensure that vulnerable workers are not being exploited.

5.8 The Health and Safety of Workers

As a responsible organisation, it is important that relevant local or national government policies are implemented throughout the supply chain at Pride Home Care Limited.

5.9 Risk Assessment

Pride Home Care Limited will undertake a risk assessment of how suppliers are operating to highlight and identify where there are risks of Modern Slavery or Human Trafficking occurring.

5.10 Review of Effectiveness

Pride Home Care Limited intends to take further steps to identify, assess and monitor potential risk areas, particularly in the supply chains of our providers. We will also continue to:

Support staff to understand and respond to modern slavery and human trafficking
Ensure all staff have access to training on how to identify victims
Review the Safeguarding Adults Policy and Procedure to ensure Modern Slavery and Human Trafficking are integral within its content

5.11 Indicators of Forced Labour

Individuals may show signs of psychological or physical abuse; they might appear frightened, withdrawn or confused
Workers may not have free movement and may always be accompanied
Individuals often lack protective equipment or suitable clothing
The person may not have access to their own documents, such as ID or passport
Individuals may not have a contract and may not be paid National Minimum Wage or not paid at all
Workers are forced to stay in accommodation provided by the employer, which could be overcrowded
Individuals could live on site
Workers could be transported to and from work, potentially with multiple people in one vehicle
The person might not accept money or be afraid to accept payment
Workers may work particularly long hours

6. Definitions

6.1 Human Trafficking Human trafficking is defined as the recruitment, transportation, transfer, harbouring or receipt of persons by means of threat, force, coercion, abduction, fraud, deception, or abuse of power, for the purpose of exploitation. It is important not to confuse human trafficking with human smuggling, which is not a form of modern slavery.

6.2 Turnover “Turnover” means the amount derived from the provision of goods and services falling within the ordinary activities of the commercial organisation, after deduction of trade discounts, VAT, and any other taxes based on the amounts so derived.

6.3 Modern Slavery Modern slavery encompasses slavery, human trafficking, forced and compulsory labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment.

6.4 Exploitation

Sexual Exploitation – forced sex work or working in the commercial sex industry; those coerced into sexual activities for another person’s gain
Modern Slavery – human trafficking; forced labour; domestic servitude; organ harvesting
Financial Exploitation – debt bondage; finances controlled by others; financial scams; benefit fraud
Criminal Exploitation – those trafficked or coerced for illegal activity, including County Lines/drug trafficking, cuckooing, forced street crime, cannabis cultivation
Cultural Exploitation – those coerced using religious, social or cultural beliefs, e.g. FGM, radicalisation, forced marriage

6.5 Section 52 Modern Slavery Act This places a duty on Local Authorities to identify and refer modern slavery child victims and consenting adult victims through the National Referral Mechanism (NRM). The Council as a first responder has a duty to notify the Home Office if anyone identifies a person with indicators suggesting they may be trafficked or enslaved.

7. Key Facts – Professionals

An annual statement on modern slavery and human trafficking will be published on our website and approved by the senior management team, where applicable
Cases of slavery or human trafficking will be shared with Norfolk County Council, County Hall, Martineau Lane, Norwich, NR1 2DH – Tel: 0344 800 8020
The Modern Slavery Act 2015 details what organisations need to do about slavery and human trafficking
Staff will receive training on Modern Slavery and Human Trafficking, and will be supported if subject to, or reporting, cases of slavery or human trafficking
Only staff who have been through robust recruitment procedures will be employed at Pride Home Care Limited
If slavery or human trafficking is disclosed to you, this must be shared with the Registered Manager or the police if someone is in immediate danger

8. Key Facts – People Affected by the Service

If you are aware of or become part of any acts of modern slavery or human trafficking, this can be reported to Pride Home Care Limited and the necessary support will be provided
You will receive care from staff who have been through robust recruitment procedures

Further Reading