Review Sheet

1. Purpose

1.1 To ensure that everyone at Angelus Homecare 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 the national guidance. This policy refers to adults who may be at risk, the procedure for children is detailed in the Child Protection Policy and Procedure.

1.2 This policy must be read alongside CR03 - Safeguarding Policy and Procedure . Angelus Homecare will ensure that staff understand Kent county council & East Sussex County Council safeguarding reporting procedures and that these procedures are communicated to all staff. Other policies that relate to Modern Slavery and Human Trafficking include but are not limited to PM11 - Whistleblowing Policy and Procedure , AR01 - 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.

1.3 To support Angelus Homecare in meeting the following Key Lines of Enquiry:

1.4 To meet the legal requirements of the regulated activities that Angelus Homecare is registered to provide:

• The Modern Slavery Act 2015

• Health and Safety at Work etc. Act 1974

• Human Rights Act 1998

• The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012

2. Scope

2.1 The following roles may be affected by this policy:

• All staff

• Registered Manager

• Other management

2.2 The following Service Users may be affected by this policy:

• Service Users

2.3 The following stakeholders may be affected by this policy:

• Commissioners

• Local Authority

3. Objectives

3.1 To promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of Angelus Homecare 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 Angelus Homecare.

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 Angelus Homecare 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 Angelus Homecare 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 Angelus Homecare management. Angelus Homecare will also support any staff that may be subject to slavery or human trafficking.

4.4 Where modern slavery or human trafficking is identified, Angelus Homecare will share information with the Kent county council & East Sussex 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 being victim of modern slavery must notify their line manager.

4.7 Angelus Homecare 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 PM11 - Whistleblowing Policy and Procedure at Angelus Homecare. The purpose of this policy and associated procedure is to enable Angelus Homecare to thoroughly investigate allegations of any wrongdoing raised by employees within Angelus Homecare without fear of reprisal.

4.9 Angelus Homecare 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 (MSA).

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. Angelus Homecare must ensure that staff are aware that victims of modern slavery or trafficking will often not self-identify. Many will present with a different issue.

5.2 Safer Recruitment

All staff engaged with providing services at Angelus Homecare 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 will minimise the chance of employing a person that has been, or is subject to, slavery or human trafficking. Angelus Homecare will follow PR16 - Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times.

5.3 Angelus Homecare 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 being provided for.

5.4 Training

All staff will undertake training on Modern Slavery and Human Trafficking. This will ensure that they are aware of the indicators of modern slavery which include:

• Individuals not being paid for the work they undertake

• Individuals being held in debt-bondage (being told they “still” owe money after having paid off a previous debt)

• An individual’s passport being held by their “employer” in order to keep the individual at work

• Multiple benefit claimants having their benefits being paid into the same account

• An individual not having the freedom of movement (i.e. passport being taken)

• Clear exploitation of an individual by another for financial or sexual gain

• Shows signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated injuries

• Rarely be allowed to travel on their own, seem under the control, the influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work

• Relationships which do not seem right - for example, a young teenager appearing to be the boyfriend/girlfriend of a much older adult

• Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address

• Have no identification documents, have few personal possessions and always wear the same clothes day in and day out. What clothes they do wear may not be suitable for their work

• Have little opportunity to move freely and may have had their travel documents retained, e.g. passports

• Be dropped off/collected for work on a regular basis either very early or late at night

• Unusual travel arrangements - children being dropped off/picked up in private cars/taxis at unusual times and in places where it is not clear why they would be there

• Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family

5.5 Staff will be advised that if they are subject to slavery or human trafficking, 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 must inform the Registered Manager of Angelus Homecare or the police.

5.6 Modern Slavery Annual Reporting during COVID

The Government guidance states that under section 54 of the Modern Slavery Act 2015, certain businesses are required to publish an annual modern slavery statement setting out the steps they have taken to identify and address their modern slavery risks. During the coronavirus pandemic, it is essential that Angelus Homecare continues to identify and address the risks of modern slavery in operations and supply chains. As well as focusing on the health and safety of workers, Angelus Homecare will consider how fluctuations in demand and changes in the operating model may lead to new or increased risks of labour exploitation.

If Angelus Homecare needs to delay the Modern Slavery statement

The challenges presented by the coronavirus pandemic may mean that Angelus Homecare will not be able to publish the statement within the usual timeframe. Where Angelus Homecare needs to delay the publication of the modern slavery statement by up to 6 months due to coronavirus-related pressures, Angelus Homecare understands that we will not be penalised. In the statement, Angelus Homecare will state the reason for any delay.

5.7 Recruitment risks during COVID-19

Some suppliers may be seeking to recruit additional workers in order to meet increases in demand. Angelus Homecare will ensure that rigorous recruitment checks are maintained and that suppliers adhere to the same robust processes to ensure that vulnerable workers are not being exploited by third parties seeking to profit from heightened demand.

5.8 The Health and Safety of Workers

As a responsible organisation, it is important that the relevant local or national government policies are implemented throughout the supply chain at Angelus Homecare. Angelus Homecare will ensure that suppliers adopt social distancing measures and pay statutory sick pay in order to prevent the spread of coronavirus as part of due diligence processes.

5.9 Risk Assessment during COVID-19

Angelus Homecare will undertake a risk assessment of how suppliers are operating during COVID-19 to highlight and help identify where there are risks of Modern Slavery or Human Trafficking occurring. A Template in the QCS Management system will be used where appropriate.

5.10 Review of Effectiveness

Angelus Homecare intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers. We will also continue to:

• Support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working in Care can have in keeping present and potential future victims of modern slavery and human trafficking safe

• Gain assurance that all staff at Angelus Homecare have access to training on how to identify victims of modern slavery and human trafficking

• Review the Safeguarding Policy and Procedure at Angelus Homecare to ensure that Modern Slavery and Human Trafficking are integral within the content and staff are directed to support and advice as needed

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 and have not been trained to safely fulfil the requirements of the role

• The person may not have access to their own documents, such as ID or their passport, with the employer having confiscated them

• 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. This accommodation 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 the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation

• It is important not to confuse human trafficking with human smuggling. Human smuggling is also called people smuggling. Human smuggling occurs when an individual seeks the help of a facilitator to enter a country illegally, and the relationship between both parties ends once the transaction ends. Many of those who enter the UK illegally do so by this route. Human smuggling 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 or subsidiary undertaking, after deduction of

  • Trade discounts

  • Value added tax

  • Any other taxes based on the amounts so derived (HM Government - 'Transparency in Suppy Chains')

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

• A large number of active organised crime groups are involved in modern slavery. But it is also committed by individual opportunistic perpetrators

• There are many different characteristics that distinguish slavery from other human rights violations, however only one needs to be present for slavery to exist

6.4 Exploitation (Modern Slavery and Human Trafficking)

• Sexual Exploitation – forced sex work or working in the commercial sex industry (pornography, lap dancing, telephone lines etc.); those manipulated or coerced into sexual activities of any kind 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 manipulated or coerced or trafficked for the purpose of any illegal activity i.e., County Lines/drug trafficking; cuckooing (taking over of a person’s property); forced street crime (shoplifting, begging etc.); cannabis cultivation

• Cultural Exploitation – those manipulated or 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) This responsibility identifies a local authority as a First Responder. The Council as a first responder (FR) into the NRM process has a duty to notify the Home Office if anyone working within the council identifies a person with indicators suggesting they may be trafficked or enslaved

Key Facts - Professionals

Professionals providing this service should be aware of the following:

• The Modern Slavery Act 2015 details what organisations need to do about slavery and human trafficking

• Staff will receive training on Modern Slavery Human Trafficking, and be supported by Angelus Homecare if subject to, or reporting of, cases of slavery or human trafficking

• Only staff that have been through robust recruitment procedures will be employed at Angelus Homecare

• If there are cases of slavery or human trafficking then the service will share this information with Kent County Council

• If slavery or human trafficking is disclosed to you then this must be shared with the Registered Manager or the police if someone is in immediate danger

• Where applicable, an annual statement on modern slavery and human trafficking will be published by Angelus Homecare on our website and approved by the senior management team e.g. the board of Directors and signed by a Director

Key Facts - People affected by the service

People affected by this service should be aware of the following:

• If you are aware of or become part of any acts of modern slavery or human trafficking, this can be reported to Angelus Homecare and the necessary support will be provided

• You will receive Care from staff who have been through robust recruitment procedures

Further Reading

As well as the information in the 'underpinning knowledge' section of the review sheet we recommend that you add to your understanding in this policy area by considering the following materials:

E-Learning: https://www.e-lfh.org.uk/programmes/modern-slavery/

Recommended content for a modern slavery statement: https://corporate-responsibility.org/wp-content/uploads/2017/06/Core_RecommendedcontentFINAL-1.pdf

Modern Slavery Awareness Booklet: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/655504/6.3920_H

Unseen: https://www.unseenuk.org/

Outstanding Practice

To be ‘ outstanding ’ in this policy area you could provide evidence that:

• Specific training is provided on slavery and human trafficking

• The publishing of a statement on slavery and human trafficking even if this is not a legal requirement

• A very high level of understanding and awareness demonstrated in all areas of the service

• Angelus Homecare shares its practice in this area with other organisations and is seen as a 'best practice resource'

• Angelus Homecare regularly audits and conducts thorough due diligence on its supply chain

• The wide understanding of the policy is enabled by proactive use of the QCS App

Forms

Physical Appearance

• Shows signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated injuries

Isolation

• Rarely be allowed to travel on their own, seem under the control, the influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work

• Relationships which do not seem right - for example, a young teenager appearing to be the boyfriend/girlfriend of a much older adult

Poor Living Conditions

• Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address

Restricted Freedom of Movement

• Have no identification documents, have few personal possessions and always wear the same clothes day in and day out. What clothes they do wear may not be suitable for their work

• Have little opportunity to move freely and may have had their travel documents retained, e.g. passports

Unusual Travel Times

• Be dropped off/collected for work regularly either very early or late at night

• Unusual travel arrangements - children being dropped off/picked up in private cars/taxis at unusual times and in places where it is not clear why they would be there

Reluctant to Seek Help

• Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family

The Following Signs Could Indicate a Situation of Labour Exploitation:

• 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 and have not been trained to safely fulfil the requirements of the role

• The person may not have access to their documents, such as ID or their passport, with the employer having confiscated them

• 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. This accommodation 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

The Following Signs Could Indicate a Situation of Sexual Exploitation:

• Sex workers may appear scared or intimidated

• The individual may be transported to and from clients

• Individuals may be closely guarded

• The person may be 'branded' with a tattoo indicating ownership

• Sex workers may show signs of physical abuse, including bruising, scarring and cigarette burns

• The individual may be unable to keep payment and may have restricted or no access to their earnings

• The person may have a limited English vocabulary, restricted to sexualised words

• Multiple female foreign nationals may be living at the same address

• The person may sleep in the premise in which they work, which could indicate a brothel is operating

• A property might have male callers day and night who only stay for a short time

• There may be details of sexual activity such as cards and advertisements found nearby

The Following Signs Could Indicate a Situation of Domestic Servitude:

• The individual may be held in their employer's home and forced to carry out domestic tasks such as providing childcare, cooking and cleaning

• The individual may not be able to leave the house on their own, or their movements could be monitored

• The person may work over normal working hours

• The individual may not have access to their belongings, including their ID, but also items such as their mobile phone, which can isolate them

• The employer may be abusive, both physically and verbally

• The person may not interact often with the family they are employed by

• The person may be deprived of their personal living space, food, water, or medical care

• The individual may stand out from other family members, noticeable as they may wear poorer quality clothing

The Following Signs Could Indicate a Situation of Criminal Exploitation:

• A large group of adult or children beggars might be moved daily to different locations but return to the same location every night. This could indicate forced begging

• An individual might be transported to or from the scene of a crime, including shoplifting, pickpocketing or forced begging

• An individual may not benefit from the money or items they have obtained through the crimes they have been forced to commit

• A person may be forced to cultivate cannabis with their freedom of movement restricted; including being locked in a room. Commonly, the individual may not be able to speak English or have a limited vocabulary

• A vulnerable person may be forced or manipulated out of their home by drug dealers who use the home as a base to sell drugs

• Young people may be forced to transport and sell drugs across county borders, which is known as County Lines

The Following Signs Could Indicate a Situation of Child Exploitation:

• The child may have mood swings, including being angry, upset or withdrawn

• The child may show signs of inappropriate sexual behaviour

• They may be dressed inappropriately for their age

• The child may go missing at night or weekends and may not be clear about their whereabouts

• They may not attend school

• The child may have gifts, presents or expensive items which they cannot explain

Who needs to publish a statement?

A commercial organisation is required to publish an annual statement if all the criteria below apply:

• It is a ‘body corporate’ or a partnership, wherever incorporated or formed

• It carries on a business, or part of a business, in the UK

• It supplies goods or services

• It has an annual turnover of £36 million or more

Organisations are responsible for determining whether the legislation applies to them. You may wish to seek legal advice to decide if your organisation needs to produce an annual statement.

If Angelus Homecare meets the criteria, the modern slavery statement must;

• Be published on the organisation’s UK website with a link in a prominent place on the UK homepage. The emphasis on visibility is intended to enhance reporting standards, encouraging companies to publicly demonstrate their commitment to addressing modern slavery

• Be approved by the board or directors and signed by a director. This assigns ownership to senior-level management and encourages their proactive involvement in tackling abusive practices in business operations

Companies that do not meet these basic requirements are breaking the law

• Angelus Homecare structure, business and supply chains

• Its policies in relation to slavery and human trafficking

• The due diligence processes of Angelus Homecare 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 Angelus Homecare 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 Angelus Homecare staff

The statement must be:

• Written in simple language

• Succinct, but cover all relevant points and link to relevant documents within Angelus Homecare

• In English, but may be provided in other languages that are relevant to the supply chain

What else must it include?

• The statement must include either a statement of the steps Angelus Homecare 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 Angelus Homecare has taken no such steps

• The statement must be true, referring to actual steps undertaken or begun and must be built upon year after year to evolve and improve over time

• 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 a full investigation

• Charities and educational institutions are captured by the obligation. If the turnover is £36m, 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 will be published on the website of Angelus Homecare and, where appropriate, linked through to any other relevant websites of Angelus Homecare

• It must be obvious on the home page or clearly accessible by a drop-down menu. Historical statements can also be retained online when the new statements are published, to allow comparisons to be made and monitoring of Angelus Homecare over time

• 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 company'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

THIS STATEMENT IS A TEMPLATE AND MUST BE UPDATED TO REFLECT Angelus Homecare

This statement sets out the steps that Angelus Homecare has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Angelus Homecare has a zero- tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains.

[Insert what your organisation does e.g. provide homecare services to xxx number of people, with xx number of staff at xx number of locations. State if you work with any particular partners e.g. Local Authorities.]

Angelus Homecare implements its business strategy in an ethically, socially and environmentally responsible manner. We fully acknowledge our responsibility to respect human rights as set out in the International Bill of Human Rights. The IBHR informs all of our policies related to the rights and freedoms of every individual who works for us, either as a direct employee, agency worker or indirectly through our supply chain. We are also committed to implementing the United Nations Guiding Principles on Business and Human Rights throughout our operations. Respect for the dignity of the individual – and the importance of each individual’s human rights – form the basis of the behaviours we expect in every workplace nationally.

We will not accept any form of discrimination, harassment or bullying and we require all of our managers to implement policies designed to increase equality of opportunity and inclusion for all employees including agency workers. We have also developed and implemented policies and processes which are intended to extend these commitments through our supply chain.

Policies

We have several internal policies to ensure that we are conducting business ethically and transparently. These include:

• Human Rights policy and our Ethics Policy where we confirm that we will not tolerate or condone the abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected

• Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery. All reports will be fully investigated and appropriate remedial actions are taken and we will work closely with social care and health providers ensuring that our policies and procedures dovetail with local procedures and best practice

• A robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard

• Employee Code of Conduct consistent with any professional codes of conduct

Direct Communication

The Company encourages members of the public or people not employed by us to write, in confidence, to raise any concern, issue or suspicion of modern slavery in any part of our business.

Suppliers

[Insert what you think are your risk levels and what you do to mitigate those risks]

We conduct due diligence on all suppliers before allowing them to become a preferred supplier. We include an online search to ensure that particular organisations have never been convicted of offences relating to modern slavery and we include our modern slavery policy as part of our contract with all suppliers. Suppliers are required to confirm that no part of their business operations contradicts this policy. As part of our contract with suppliers, they confirm to us that:

Risk Assessments

Our supply chains include procurement of staff, consumables, facilities maintenance, utilities and waste management [add further areas]. We have conducted a risk assessment and will ensure that we will take further steps to ensure that we support the eradication of modern slavery, that staff understand how to recognise modern slavery and the appropriate safeguarding reporting processes are followed should there be concerns within our supply chains, with customers or suppliers.

Performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery is not taking place within our business or supply chain if:

• No reports are received from employees, the public, or law enforcement agencies or local safeguarding teams to indicate that modern slavery practices have been identified

Safeguards

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. Angelus Homecare will accept and take seriously concerns communicated anonymously.

However, retention of anonymity does render investigations and makes validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

Responsibility for this Statement

The ultimate responsibility for the prevention of modern slavery rests with the [insert who at Senior Management level has responsibility] for ensuring that this policy and its implementation complies with our legal and ethical obligations. Managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

Assessment of effectiveness in preventing Modern Slavery

We understand that modern slavery risk is not static, and will continue our approach to mitigating this risk. We will assess the risk via our internal auditing processes.

This statement is made according to section 54(1) of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement of Angelus Homecare for the financial year ending xxxx. [State who has approved] of Angelus Homecare has approved this statement.

Approval for this statement Marie Moody

This statement was approved by the Registered

Manager

Date 22-10-2020