Modern Slavery

Modern slavery covers slavery, servitude, forced and compulsory labour and human trafficking. It is often intertwined with organised crime and victims are treated as commodities and exploited for criminal gain.

The Modern Slavery Act, (the “Act”), was published in 2015 and builds upon existing legislation, consolidating a number of different offences into a single act. These offences are set out and defined below:

Slavery Where a person exercises ownership over another

Servitude Where a person is coerced into providing services and is unable to effect a change in his/her circumstances

Forced Labour Where a person is forced to work or provide a service, fearing reprisal if he/she does not comply

Human Trafficking Where a person arranges or facilitates the travel of another person with the knowledge or intention to exploit that person

Section 54 of the Act also brings into effect a new requirement for large organisations with UK operations to provide a statement detailing the steps that they have taken to ensure that modern slavery and human trafficking are not taking place within their business or supply chains.

This is the statement of Alternative House Care Home.

Introduction

Alternative House Care Home recognizes that it has a responsibility to take a robust approach to slavery and human trafficking.

Alternative House Care Home is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

This statement sets out the actions that Alternative House Care Home has taken to understand potential slavery and human trafficking risks related to its business. It details a number of preventative measures put in place to minimise the risk of activity, which is prohibited under the Act, taking place within our business or supply chains.

This statement relates to actions and activities of Alternative House Care Home during the financial year ended 31 December 2017. It also contains key actions that will be taken over the next 12 months and reported on in 2018.

Organisational Structure

Alternative House Care Home 30 colleagues providing long-term residential and Dementia care, intermediate care, respite care and palliative care to more than 56 residents.

Responsibilities

Responsibility for the organisation’s anti-slavery initiatives is as follows:

  • Policies: The Manager is responsible for managing and leading the development of new, and the review of existing, policies and procedures across Alternative House Care Home All policies are ratified by the Governance and Risk Committee (GRC) and approved by the Care, Quality and Safety Committee (CQSC). The policies relevant to the Act are set out under the section entitled “Protecting our Employees” and are subject to review on an annual basis.
  • Training: The Learning and Development team are responsible for the training, development and coaching of all colleagues. The team will endeavour to adhere to “Modern Slavery Act – Preventing Exploitation” which we intend to roll-out in 2018. It is expected that training will be reviewed checking training needs on an annual basis and developing solutions relevant to our business and its needs.
  • Risk Assessments, Governance and Control: Alternative House Care Home maintains a strategic risk register which is designed specifically to ensure compliance with both regulatory and legislative requirements and is reviewed on a 3-monthly basis by the Management Team. This ensures that governance arrangements and controls, put in place to mitigate any risks identified, continue to be effective and fit for purpose.
  • Investigation/due diligence: Alternative House Care Home audit team is responsible for periodically reviewing any areas of significant risk to assess whether the agreed governance arrangements and controls have been implemented successfully and are working effectively. All members of the audit team will be required to complete the e-learning module entitled “Modern Slavery Act – Preventing Exploitation” so that they are suitably equipped for this task.

Protecting our Colleagues

Alternative House Care Home is committed to treating all its colleagues in a fair and consistent manner and in accordance with our values: respectful, trusted, caring and making a difference. Alternative House Care Home operates the following policies that describe its approach to modern slavery risks and the steps to be taken to prevent human trafficking within its operations:

  • Employee Code of Conduct: Alternative House Care Home is committed to achieving and maintaining high standards of professional and ethical conduct amongst our colleagues. Our expectations are made clear through a number of existing policies including, but not limited to, the Anti-Bribery and Corruption Policy, the Bullying and Harassment Policy, the Equality and Diversity Policy and the Disciplinary Policy.
  • Recruitment Policy: Alternative House Care Home Recruitment Policy requires any agency involved in the identification of candidates for The Healing Well Ltd to comply with all relevant legislation. The Healing Well Ltd actively reviews their policies and procedures on an on-going basis, and in light of emergent legislation, it only engages with reputable and compliant agencies.
  • Eligibility to Work Policy: Alternative House Care Home Eligibility to Work Policy recognises that illegal workers are often the most vulnerable and exploited workers in the UK. It has therefore been designed to ensure that all Alternative House Care Home colleagues are aware of their responsibilities in relation to tackling illegal working; namely to ensure that all current and prospective colleagues have had a right to work check, prior to them commencing work with Alternative House Care Home, confirming that they are legally entitled to work in the UK.
  • Whistleblowing Policy: FSC’s whistleblowing policy provides a mechanism for colleagues, (including agency staff and volunteers), residents/service users, relatives/visitors and others, to raise confidential concerns. Alternative House Care Home subscription to an external whistleblowing line, operated 24 hours a day by a reputable firm of healthcare solicitors, is designed to make it easy for people to make disclosures without fear of retaliation.
  • Employee Handbook: Alternative House Care Home employee handbook provides information to all colleagues on their statutory rights, inclusive of sick pay, holiday pay and any other benefits that they might be entitled to by virtue of their employment.

The company undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The companies’ due diligence reviews include:

• Evaluating the modern slavery and human trafficking risks of each new supplier

Training

It is planned that Alternative House Care Home will require all its Senior Leaders, HR professionals and internal auditors to complete the e-learning module entitled “Modern Slavery Act – Preventing Exploitation” by December 2018.

The e-learning module is intended to cover:

  • Alternative House Care Home purchasing practices which influence supply chain conditions, and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline
  • How to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available
  • How to identify the signs of slavery and human trafficking
  • What initial steps should be taken if slavery or human trafficking is suspected
  • How to escalate potential slavery or human trafficking issues to the relevant parties within Alternative House Care Home
  • What external help is available, for example through the Modern Slavery Helpline, Gang masters and Labour Abuse Authority and “Stronger Together” initiative
  • What messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies

Awareness Raising Programme

As well as training a select group of colleagues, Alternative House Care Home will be raising awareness of the Act by distributing documentation to all of its care homes and circulating a series of emails/notices on the Alternative House Care Home.

The documentation will explain:

  • The basic principles of the Act
  • How employers can identify slavery or human trafficking
  • What colleagues can do to flag up potential slavery or human trafficking issues to individuals within Alternative House Care Home