Policy In essence, compliance is necessary from 29th October 2015. However, if Compassionate Care Team Ltd's year end falls between 29th March 2015 and 30th March 2016, Compassionate Care Team Ltd will not be required to publish a statement for the 2015/2016 financial year.
Guidance suggests that statements should be published within six months of the financial year end. Therefore, those with a financial year end of 31st March 2016 will be the first required to publish a statement by 30th September 2016.
It is unlikely that Compassionate Care Team Ltd will experience cases of slavery or human trafficking, but this policy details the commitment to raise awareness and defines a process to address issues if they do arise.
The Modern Slavery Act 2015 states that every organisation providing goods and services in the UK with a total global annual turnover of £36m or more will be required to produce a slavery and human trafficking statement for each financial year.
This figure of £36 million is the total turnover of the organisation or its group not the individual location. As such the publication of an annual statement (if applicable) will primarily be the responsibility of the senior management of the organisation, but individual services will contribute to the content of the statement and have an awareness of the issues of slavery and human trafficking.
All staff will be made aware of the issues surrounding slavery and human trafficking and encouraged and supported to report any concerns to the management of Compassionate Care Team Ltd.
Compassionate Care Team Ltd will ensure that staff are only employed whose credentials can be confirmed.
Compassionate Care Team Ltd will be open and transparent with all staff and encourage discussion about slavery and human trafficking. The service will also support any staff that may be subject to slavery or human trafficking.
Slavery and human trafficking is classed as abuse and indicators could be: • Signs of physical or emotional abuse • Appearing to be malnourished, unkempt or withdrawn • Isolation from the community, seeming under the control or influence of others • Living in dirty, cramped or overcrowded accommodation and/or living and working at the same address • Lack of personal effects or identification documents • Always wearing the same clothes • Avoidance of eye contact, appearing frightened or hesitant to talk to strangers • Fear of law enforcers
In situations of slavery or human trafficking being identified, Compassionate Care Team Ltd will share this information with the appropriate authorities with the objective of preventing future situations arising, and to promote the elimination of routes and sources of slavery or human trafficking.
Procedure If Compassionate Care Team Ltd has a turnover of more than £36m then the annual statement will be published and will include detail on: • Its structure, business and supply chains • Its policies in relation to slavery and human trafficking • Its due diligence processes in relation to slavery and human trafficking in its business and supply chains • The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk • Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriate • The training about slavery and human trafficking available to its staff
The statement should be: • Written in simple language • Succinct, but cover all relevant points and link to relevant documents • In English, but may be provided in other languages that are relevant to the supply chain • The statement must include either a statement: of the steps Compassionate Care Team Ltd has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains and in any of its own business, or that Compassionate Care Team Ltd has taken no such steps
The statement needs to be published and any director signing the statement needs to be satisfied that the statement is true. This might include carrying out full investigations.
Charities and educational institutions are captured by the obligation. If the turnover is £36 million, goods or services are supplied, and it carries on business within the UK, it is irrelevant the purpose for which its profits are made. Both franchisors and franchisees may be captured if they meet the turnover thresholds.
The statement should be published on Compassionate Care Team Ltd's website and, where appropriate, linked through to any other relevant websites of Compassionate Care Team Ltd.
It must be obvious on the home page or clearly accessible by a drop down menu.
If a parent company meets the requirements, it must include in its statement the steps taken in relation to each of its subsidiaries if they form part of the parent’s supply chain or business (even if the subsidiaries themselves do not meet all the requirements).
A subsidiary organisation that meets the thresholds in its own right must produce its own slavery and human trafficking statement. However, a parent company may produce one statement that the subsidiaries also use.
All staff engaged with providing services at Compassionate Care Team Ltd will be subject to thorough and rigorous recruitment procedures that will include a DBS check, identity check, confirmation of validity to work in the UK, employment history, suitability for the role and references. This should minimise the chance of employing a person that has been / is subject to slavery or human trafficking.
Compassionate Care Team Ltd will only use staff provided by third party organisations (such as agencies) that are registered with the regulator and who can confirm that the staff being supplied are free to work in the UK and meet all the requirements for the role being provided for.
All staff will receive information about slavery and human trafficking.
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, or if slavery or human trafficking is disclosed to them they should inform the Registered Manager of Compassionate Care Team Ltd or the police.