Category: Human Resources Sub-category: Equality and Human Rights

Policy Review Sheet

Last Reviewed: 18/07/19 Last Amended: 18/07/19

Next planned review in 12 months, or sooner as required.

Note: The full policy change history is available in your online management system.

Business Impact:

Low Medium High Critical
Changes are important, but urgent implementation is not required, incorporate into your existing workflow.
Reason for this review: Scheduled review
Were changes made? Yes
    Summary: A scheduled review of this policy has been undertaken. A new procedure was added in relation to the process to follow when there are incidences of slavery or human trafficking. Key facts were also added in relation to ‘people affected by the service’ and additional references added to the Further Reading section of the policy. An information flyer from the Salvation Army on Domestic Slavery was added to Forms.
Relevant Legislation:
  • The Modern Slavery Act 2015
  • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2015
  • Human Rights Act 1998
Underpinning Knowledge – What have we used to ensure that the policy is current:
  • HM Government, (2017), Modern Slavery Act 2015. [Online] Available from: [Accessed: 18/07/2019]
  • HM Government, (2018), Slavery and human trafficking in supply chains – guidance for businesses. [Online] Available from: practical-guide [Accessed: 18/07/2019]
  • Home Office, (2016), Victims of modern slavery frontline staff guidance. [Online] Available from: slavery-frontline-staff-guidance-v3.pdf   [Accessed: 18/07/2019]
  • Social Care Institute for Excellence, (2018), SCIE at a glance 69: Safeguarding adults – Types and indicators of abuse. [Online] Available from:

-indicators-of-abuse.asp  [Accessed:  18/07/2019]

  • Home Office, (2018), 2018 UK Annual Report on Modern Slavery. [Online] Available from: report-on-modern-slavery  [Accessed:  18/07/2019]
  • HM Government, (2019), National referral mechanism guidance: Adult (England and Wales) [Online] Available from: and-assessment-forms/guidance-on-the-national-referral-mechanism-for- potential-adult-victims-of-modern-slavery-england-and-wales [Accessed: 18/07/2019]
  • Salvation Army, (2019), Modern Slavery. [Online] Available from:   [Accessed:  18/07/2019]

Suggested action:

  Encourage sharing the policy through the use of the QCS App

  • Add the policy to the planned team meeting agendas
  • Develop training sessions for relevant staff
  • Ensure relevant staff are aware of the content of the whole policy
  • Purpose
    • To ensure that Fairway Homecare Ltd 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.
    • This policy must be read alongside the Safeguarding Policy and Procedure of Fairway Homecare Ltd, and Fairway Homecare Ltd will ensure that staff understand

Birmingham City Council safeguarding reporting procedures and that these procedures are communicated to all staff.

    • To support Fairway Homecare Ltd in meeting the following Key Lines of Enquiry:
Key Question Key Line of Enquiry (KLOE)
SAFE S1: How do systems, processes and practices keep people safe and safeguarded from abuse?
WELL-LED W1: Is there a clear vision and credible strategy to deliver high-quality care and support, and promote a positive culture that is person-centred, open, inclusive and empowering, which achieves good outcomes for people?
WELL-LED W2: Does the governance framework ensure that responsibilities are clear and that quality performance, risks and regulatory requirements are understood and managed?
    • To meet the legal requirements of the regulated activities that Fairway Homecare Ltd is registered to provide:
      • The Modern Slavery Act 2015
      • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2015
      • Human Rights Act 1998

 2. Scope

    • The following roles may be affected by this policy:
      • All staff
      • Registered Manager
      • Owner, Proprietor or Responsible Individual
    • The following people may be affected by this policy:
      • Service Users
    • 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 Fairway Homecare Ltd in addressing slavery and human trafficking in all its forms. An annual statement will be produced, where applicable.

  • Policy
    • It is unlikely that Fairway Homecare Ltd will experience cases of slavery or human trafficking, but this policy details the commitment of Fairway Homecare Ltd to raise awareness and defines a process to address issues if they do arise, and to acknowledge that human trafficking and modern slavery are a safeguarding matter.
    • 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, 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
    • All staff will be made aware of the issues surrounding slavery and human trafficking, whilst being encouraged and supported to report any concerns to Fairway Homecare Ltd management. Fairway Homecare Ltd will

also support any staff that may be subject to slavery or human trafficking.

    • Fairway Homecare Ltd will ensure that only staff whose credentials can be confirmed are employed.
    • In situations of slavery or human trafficking being identified, Fairway Homecare Ltd will share this information with the

Birmingham City 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.

    • Section 54 of the Modern Slavery Act 2015 states that every organisation providing goods and services in the UK with a total global annual turnover of £36 million (m) or more will be required to produce a slavery and human trafficking statement for each financial year. Organisations with an annual turnover below £36m can choose to voluntarily produce a statement.
    • This figure of £36m 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 Fairway Homecare Ltd, but individual services will contribute to the content of the statement and have an awareness of the issues of slavery and human trafficking.

    • Guidance suggests that statements must be published within six months of the financial year end. Therefore, those with a financial year end of 31st March will be required to publish a statement by 30th September.

 5. Procedure

    • The Annual Statement

If Fairway Homecare Ltd has a turnover of more than £36m, then the annual statement will be published and will include detail on:

      • Fairway Homecare Ltd structure, business and supply chains
      • Its policies in relation to slavery and human trafficking
      • The due diligence processes of Fairway Homecare Ltd 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 Fairway Homecare Ltd 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 Fairway Homecare Ltd staff
    • The statement will be:
      • Written in simple language
      • Succinct, but cover all relevant points and link to relevant documents within Fairway Homecare Ltd
      • 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 Fairway Homecare 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 Fairway Homecare Ltd 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 Fairway Homecare Ltd and, where appropriate, linked through to any other relevant websites of Fairway Homecare Ltd.
    • 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 Fairway Homecare Ltd 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.
    • Staff Requirements

All staff engaged with providing services at Fairway Homecare 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 will minimise the chance of employing a person that has been, or is subject to, slavery or human trafficking.

    • Fairway Homecare 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, 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 Fairway Homecare Ltd or the police.

    • Incidences of Slavery and Human Trafficking

The Resonsible Individual, Alex O& 39;Neill is the main point of contact within Fairway Homecare Ltd for the reporting of cases and with the ability to act and advise on actions to be taken.

If a specific case of slavery or human trafficking is identified it must be reported to the Registered Manager and Alex O& 39;Neill at Fairway Homecare Ltd, as well as the police in the first instance. Where applicable, the

Birmingham City Council

must be informed and a notification submitted to the Care Quality Commission.

In the UK, mechanisms are in place to assist victims of slavery and human trafficking and they can be offered government-funded support. The National Referral Mechanism, or the Modern Slavery Helpline on 0800 0121 700 are two such sources of support.

    • Review of Effectiveness

Fairway Homecare Ltd 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 Fairway Homecare Ltd have access to training on how to identify victims of modern slavery and human trafficking
      • Review Fairway Homecare Ltd Safeguarding Policy and Procedure to ensure that Modern Slavery and Human Trafficking are integral within the content and staff are directed to support and advice as needed

 6. Definitions

    • 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. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation
    • 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’)

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 information about slavery and human trafficking, and be supported by Fairway Homecare Ltd 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 Fairway Homecare Ltd
  • If there are cases of slavery or human trafficking then the service will share this information with the appropriate authorities
  • If slavery or human trafficking is disclosed to you then this must be shared with the Registered Manager or the police
  • Where applicable, an annual statement on modern slavery and human trafficking will be issued by Fairway Homecare Ltd

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 Fairway Homecare Ltd 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:

Help for adult victims of Modern Slavery – Your immigration options if you’ve been trafficked into exploitation in the UK: This website contains videos and a lot more information about modern slavery:

See also:

Slavery in the UK

Core Coalition Short Guides on Modern Slavery Reporting: Ethical Trading Iniative – Base Code Guidance: Modern Slavery:

Respect International Resource Centre:


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
  • Fairway Homecare Ltd shares its practice in this area with other organisations and is seen as a ‘best practice resource’
  • The wide understanding of the policy is enabled by proactive use of the QCS App
  • Fairway Homecare Ltd regularly audits and conducts thorough due diligence on its supply chain


The following forms are included as part of this policy:

Title of form When would the form be used? Created by
Domestic Slavery – PE07 When undertaking safeguarding training. The Salvation Army



To report concerns, seek advice or get help call the confidential UK

Modern Slavery Helpline or visit the website













Or seem to be on call 24 hours a day?


Have they ever been harmed or deprived of food, water, sleep, medical care?


Are they quieter, wearing

poorer quality clothing etc?