Modern Slavery and Human Trafficking Policy

Policy Statement

Care Advocates LTD is committed to preventing modern slavery, servitude, forced labour and human trafficking in all aspects of its operations and supply chains.

We recognise our responsibility to operate ethically, transparently and in accordance with the Modern Slavery Act 2015. The organisation maintains a zero-tolerance approach to all forms of exploitation, abuse and unethical employment practices.

Care Advocates LTD is committed to safeguarding the rights, dignity and wellbeing of service users, staff, contractors and all individuals connected to our supported living and community support services.

Purpose

The purpose of this policy is to:

  • Prevent modern slavery and human trafficking within the organisation and its supply chains;
  • Promote ethical recruitment and employment practices;
  • Ensure staff understand how to identify and report concerns;
  • Support safeguarding arrangements and legal compliance;

Promote a culture of openness, accountability and protection.

Scope

This policy applies to:

  • All employees, agency workers and volunteers;
  • Directors and managers;
  • Contractors, suppliers and recruitment agencies;
  • Supported living and community support operations undertaken by Care Advocates LTD.

Legislative and Regulatory Framework

This policy is informed by:

  • Modern Slavery Act 2015;
  • Care Act 2014;
  • Human Rights Act 1998;
  • Equality Act 2010;
  • Health and Social Care Act 2008;
  • Employment Rights Act 1996;
  • Immigration legislation and Home Office guidance;
  • Care Quality Commission (CQC) Fundamental Standards.

Organisational Structure

Care Advocates LTD delivers supported living, domiciliary care and community support services within the United Kingdom.

The organisational structure includes:

  • Lewis Khaka – Director;
  • Farirayi Khaka – Head of Compliance;
  • Dominic Laval – Head of Operations;
  • Tinashe Chivandire – Team Leader;
  • Senior Support Workers;
  • Support Workers.

Our supply chains include recruitment agencies, training providers, payroll providers, IT service providers, equipment suppliers and operational contractors.

Commitment to Ethical Practices

Care Advocates LTD maintains a zero-tolerance approach to:

  • Forced labour;
  • Human trafficking;
  • Servitude;
  • Debt bondage;
  • Exploitative recruitment practices;
  • Withholding of wages or identification documents;
  • Coercion, abuse or intimidation.

The organisation is committed to fair treatment, lawful employment practices and safeguarding vulnerable individuals.

Risk Areas

Care Advocates LTD recognises that certain areas within the health and social care sector may present increased risks of exploitation, including:

  • Overseas recruitment;
  • Agency and temporary staffing arrangements;
  • Outsourced services and contractors;
  • Vulnerable workers or individuals with limited understanding of their rights.

The organisation assesses and manages these risks through robust governance, recruitment and safeguarding arrangements.

Safer Recruitment and Due Diligence

Care Advocates LTD operates safer recruitment procedures designed to minimise the risk of exploitation and unsuitable employment practices.

Measures include:

  • Verification of identity and right to work in the UK;
  • Enhanced DBS checks where applicable;
  • Employment history and reference checks;
  • Compliance with National Minimum Wage requirements;
  • Monitoring of working hours and employment conditions;
  • Oversight of recruitment agencies and suppliers.

As a licensed sponsor of overseas workers, Care Advocates LTD ensures that international recruitment practices are ethical, transparent and compliant with Home Office requirements.

The organisation:

  • Prohibits unlawful recruitment fees;
  • Does not retain workers’ passports or personal documents;
  • Ensures contracts and employment terms are clearly explained;
  • Supports overseas staff with induction and welfare arrangements.

Safeguarding and Reporting Concerns

Care Advocates LTD maintains safeguarding and whistleblowing procedures to support the reporting and management of concerns relating to exploitation or modern slavery.

Staff are expected to:

  • Remain alert to signs of exploitation or abuse;
  • Report concerns promptly;
  • Cooperate with investigations and safeguarding procedures.

Potential indicators of modern slavery may include:

  • Fearful or withdrawn behaviour;
  • Restricted freedom of movement;
  • Poor living or working conditions;
  • Unexplained injuries or signs of abuse;
  • Lack of control over personal identification or finances.

All concerns will be:

  • Taken seriously;
  • Reported appropriately;
  • Investigated where necessary;
  • Escalated to safeguarding authorities, the police or other agencies where required.

Training and Awareness

All staff will receive safeguarding training which includes awareness of:

  • Modern slavery and human trafficking;
  • Exploitation and coercion indicators;
  • Reporting procedures;
  • Ethical employment practices.

Managers and senior staff will receive additional guidance relevant to recruitment, safeguarding and workforce oversight.

Training compliance will be monitored through supervision, audits and governance processes.

Monitoring and Effectiveness

Care Advocates LTD monitors the effectiveness of its arrangements through:

  • Recruitment and compliance audits;
  • Safeguarding and incident reviews;
  • Staff supervision and welfare monitoring;
  • Feedback and whistleblowing processes;
  • Supplier and contractor oversight;
  • Policy and governance reviews.

The organisation aims to identify risks early and take prompt action to prevent exploitation.

Supplier Expectations

Care Advocates LTD expects suppliers, contractors and recruitment partners to:

  • Operate ethically and lawfully;
  • Comply with employment legislation;
  • Promote fair working conditions;
  • Prevent exploitation and modern slavery within their operations.

Where concerns arise regarding suppliers or contractors, appropriate action will be taken which may include review, escalation or termination of arrangements.

Confidentiality and Protection

This policy will be reviewed annually or sooner if required due to:

  • Legislative or regulatory changes;
  • Learning from incidents or safeguarding concerns;
  • Organisational developments;
  • Best practice guidance updates.