Anti-Slavery & Human Trafficking Policy

• To ensure that Little Wakering House – Eastern County Care Limited is aware of the issues surrounding slavery and human trafficking and has a policy and process in place to identify, and if applicable report on, issues surrounding slavery and human trafficking.
• To support Little Wakering House – Eastern County Care Limited in meeting the following Key Lines of Enquiry.
• To meet the legal requirements of the regulated activities that Little Wakering House – Eastern County Care Limited is registered to provide: the Modern Slavery Act 2015; the Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2015; and the Human Rights Act 1998.

The following roles may be affected by this policy:

• All staff
• Registered Manager
• Owner, Proprietor or Responsible Individual

• To promote awareness of concerns surrounding slavery and human trafficking.
• To publicly state Little Wakering House – Eastern County Care Limited’s commitment to addressing slavery and human trafficking in all its forms.
• To define Little Wakering House – Eastern County Care Limited’s response to any incidence of slavery or human trafficking.
• If applicable, to publish an annual statement on slavery and human trafficking.

In essence, compliance is necessary from 29th October 2015. It is unlikely that Little Wakering House – Eastern County Care Limited 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 Little Wakering House – Eastern County Care Limited.

Little Wakering House – Eastern County Care Limited will ensure that staff are only employed whose credentials can be confirmed. The service will be open and transparent with all staff and encourage discussion about slavery and human trafficking, and 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, Little Wakering House – Eastern County Care Limited 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.

If Little Wakering House – Eastern County Care Limited 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, be succinct but cover all relevant points, and be in English (though it may be provided in other languages relevant to the supply chain). The statement must include either a statement of the steps 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 no such steps have been taken.

The statement needs to be published and any director signing the statement needs to be satisfied that the statement is true. The statement should be published on Little Wakering House – Eastern County Care Limited’s website and must be obvious on the home page or clearly accessible by a drop-down menu.

All staff engaged with providing services 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 or is subject to slavery or human trafficking.

Little Wakering House – Eastern County Care Limited 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 or the police.

Slavery: Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/she did own the person, which deprives the victim of their freedom.

Human Trafficking: An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being exploited. The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job, or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed.