Policies & Procedures
Modern Slavery Policy v2.0
Document owner | Registered Manager / Director |
Approved by | Mrs. Tavleen Sharma (Registered Manager) |
Version | 2.0 |
Review frequency | Every 12 months or following any significant incident |
Next review date | 12 months from issue or earlier if required. Next formal review date: 01-04-2027 |
1. Policy Statement
VCare Consultancy Services Limited is committed to preventing modern slavery, servitude, forced labour, compulsory labour, human trafficking and exploitation in all aspects of its business operations and supply chains.
The organisation has zero tolerance towards any form of:
- slavery;
- servitude;
- forced or compulsory labour;
- debt bondage;
- human trafficking;
- labour exploitation;
- coercion;
- abuse of vulnerable workers.
VCare recognises its responsibilities under the Modern Slavery Act 2015 and is committed to conducting business ethically, transparently and with integrity.
The organisation is committed to safeguarding the human rights, dignity and wellbeing of:
- employees;
- temporary workers;
- agency staff;
- service users;
- contractors;
- suppliers;
- members of the public.
VCare expects all staff, suppliers, contractors and business partners to uphold the same high standards.
2. Purpose
The purpose of this policy is to:
- prevent modern slavery and exploitation within VCare operations;
- ensure compliance with the Modern Slavery Act 2015;
- establish safeguards during recruitment and employment;
- ensure ethical and lawful employment practices;
- identify and respond to potential indicators of exploitation;
- promote awareness amongst staff and management;
- ensure concerns are reported and investigated appropriately;
- support local authority and CQC safeguarding expectations.
3. Scope
This policy applies to:
- directors;
- managers;
- office staff;
- care staff;
- agency workers;
- volunteers;
- contractors;
- suppliers;
- recruitment partners.
The policy applies across all VCare activities including:
- recruitment;
- employment practices;
- procurement;
- subcontracting arrangements;
- supply chain management;
- care delivery services.
4. Legal and Regulatory Framework
This policy is informed by:
- Modern Slavery Act 2015
- Care Act 2014
- Human Rights Act 1998
- Equality Act 2010
- Employment Rights Act 1996
- Immigration, Asylum and Nationality Act 2006
- Health and Safety at Work Act 1974
- CQC Fundamental Standards
- Safeguarding Vulnerable Adults legislation
- Public Contracts Regulations 2015
5. Organisational Commitment
VCare Consultancy Services Limited is committed to:
- lawful and ethical recruitment practices;
- fair treatment of all workers;
- paying staff lawfully and transparently;
- ensuring all workers have freedom of movement;
- ensuring staff retain possession of personal documents;
- preventing coercion, intimidation or exploitation;
- ensuring safe working conditions;
- safeguarding vulnerable individuals;
- maintaining transparent employment arrangements.
The organisation will never knowingly engage with individuals or organisations involved in slavery, trafficking or exploitation.
6. Recruitment and Employment Controls
VCare operates robust recruitment procedures designed to prevent exploitation and unlawful employment practices.
These include:
6.1 Right to Work Checks
VCare conducts legally compliant right to work checks for all employees before employment commences.
Original documentation is verified and securely recorded.
6.2 Identity Verification
The organisation verifies:
- photographic identification;
- proof of address;
- employment history;
- references;
- DBS status where applicable.
6.3 Fair Recruitment Practices
VCare ensures:
- no worker is charged recruitment fees;
- employment terms are transparent;
- contracts are issued lawfully;
- wages are paid directly into worker bank accounts;
- staff understand their employment rights;
- workers can leave employment voluntarily subject to contractual notice.
6.4 Staff Welfare
VCare promotes staff wellbeing through:
- safeguarding support;
- whistleblowing arrangements;
- access to management support;
- fair treatment;
- dignity and respect at work;
- anti-bullying procedures;
- equality and diversity protections.
7. Supply Chain and Contractors
VCare expects suppliers and contractors to operate ethically and lawfully.
Where reasonably practicable, VCare will seek assurance that suppliers:
- comply with employment legislation;
- prevent labour exploitation;
- conduct lawful recruitment;
- maintain appropriate safeguarding standards;
- comply with modern slavery legislation.
VCare reserves the right to terminate relationships with suppliers or contractors where concerns regarding exploitation or unlawful practices arise.
8. Recognising Signs of Modern Slavery
VCare recognises that indicators of exploitation may include:
- fearfulness or anxiety;
- restricted freedom of movement;
- poor living conditions;
- lack of access to personal identification documents;
- signs of physical abuse or neglect;
- unusual control by another person;
- inability to communicate independently;
- excessive working hours;
- unpaid or underpaid work;
- dependency on another individual for transport or accommodation.
Staff are expected to remain vigilant and report concerns appropriately.
9. Safeguarding Responsibilities
VCare recognises that victims of modern slavery may be vulnerable adults requiring safeguarding intervention.
Any concerns regarding:
- exploitation;
- trafficking;
- abuse;
- coercion;
- neglect;
- forced labour
must be reported immediately in accordance with:
- safeguarding procedures;
- local authority safeguarding protocols;
- whistleblowing procedures;
- police reporting requirements where necessary.
Where immediate danger exists, emergency services will be contacted.
10. Reporting Concerns
All staff have a duty to report concerns relating to modern slavery or exploitation.
Concerns may be raised through:
- line managers;
- Registered Manager;
- safeguarding lead;
- whistleblowing procedures;
- external safeguarding authorities.
VCare will ensure:
- concerns are treated seriously;
- reports are investigated appropriately;
- whistleblowers are protected from victimisation;
- confidentiality is maintained where possible.
11. Training and Awareness
VCare will provide staff with awareness regarding:
- modern slavery risks;
- safeguarding responsibilities;
- indicators of exploitation;
- reporting procedures;
- whistleblowing protections;
- ethical employment practices.
Training may be delivered during:
- induction;
- safeguarding training;
- supervision sessions;
- policy updates.
12. Monitoring and Compliance
VCare will monitor compliance through:
- recruitment audits;
- personnel file reviews;
- safeguarding oversight;
- supplier reviews where appropriate;
- staff supervision;
- policy reviews.
Any identified concerns will be investigated promptly.
13. Responsibility
Overall responsibility for implementation of this policy rests with:
- Director;
- Registered Manager;
- Senior Management Team.
All staff share responsibility for preventing exploitation and reporting concerns.
14. Equality and Human Rights
VCare is committed to promoting:
- dignity;
- equality;
- inclusion;
- human rights;
- freedom from exploitation.
This policy operates alongside VCare’s:
- Safeguarding Policy;
- Equality and Diversity Policy;
- Whistleblowing Policy;
- Recruitment Policy;
- Disciplinary Policy.
15. Review
This policy will be reviewed:
- annually;
- following legislative updates;
- following safeguarding incidents;
- following tender or regulatory changes.
16. Declaration
VCare Consultancy Services Limited is fully committed to preventing modern slavery, human trafficking and exploitation within its organisation and wider business activities.
The organisation will continue to promote ethical, lawful and transparent working practices that protect the rights, safety and dignity of all individuals.