Modern Slavery Policy Statement
This statement sets out National Care Group’s actions to understand all potential modern slavery risks related to its organisation and to ensure steps are in place that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains.
This statement relates to actions and activities for the financial year ending 31st March 2023.
We recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously.
National Care Group (NCG) is committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains, including sub-contractors and partners, are free from slavery and human trafficking.
For the avoidance of doubt, the term NCG throughout this statement refers to National Care Group and all
constituent companies managed under the NCG operational management structure. Organisational structure and supply chains.
This statement covers the activities of NCG.
Through its network of locally managed services, NCG supports over 1200 individuals with complex support needs including mental health, learning disabilities, and acquired brain injury in both residential care and supported living settings across England and Wales as well as providing adult learning services within our specialist further education college.
As part of the organisation’s due diligence processes into slavery and human trafficking, our supplier approval process incorporates a review of the controls undertaken by our suppliers.
Imported goods from sources outside of the UK and EU are potentially more at risk for slavery/human trafficking issues.
The level of management control required for these sources will be regularly monitored.
We will not support or deal with any business knowingly involved in slavery or human trafficking.
As part of our procurement process, we will only engage with suppliers, contractors and partners who confirm their compliance with the Modern Slavery Act 2015. Responsibility for our anti-slavery initiatives is set out as follows:
• Supply chain assessments: We have reviewed the risks that our supply chains can present and whilst we consider our exposure to modern slavery to be limited, we expect our suppliers and contractors to demonstrate a zero-tolerance approach to exploitation.
To this end, all new contracts and those renewing, now include a clause requiring our suppliers and their subcontractors, comply with the Modern Slavery Act 2015 (the Act).
• Due Diligence: We undertake due diligence when considering taking on new suppliers. Our due diligence and reviews include:
o mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking;
o evaluating the modern slavery and human trafficking risks of each new supplier; and
o reviewing on a regular basis all aspects of the supply chain.
• Training: We have re-promoted our existing Group policies to incorporate modern slavery and human trafficking issues, including in our Whistleblowing policy which allows colleagues and workers to report any concerns confidentially.
We require managers and colleagues within our organisation to complete annual training on modern slavery which is incorporated in our Safeguarding training.
This training covers:
o how to identify the signs of slavery and human trafficking; and
o what steps should be taken if slavery or human trafficking is suspected.
• Awareness-raising programme: We have raised awareness of modern slavery issues by circulating our Modern Slavery Statement via our internal communication platform accessible to all colleagues/workers.
The communication explains to colleagues:
o the basic principles of the Modern Slavery Act 2015;
o how colleagues/workers can identify and prevent slavery and human trafficking;
o what colleagues/workers can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and
o what external help is available, for example through the Whistleblowing hotline.
We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in our operations:
• Whistleblowing Policy: We encourage our colleagues, workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation.
This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking.
Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation.
Colleagues, workers, customers, or others who have concerns can use our confidential helpline.
• Colleague Code of Conduct: Our code makes clear to colleagues the actions and behaviour expected of them when representing our organisation.
We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.
• Supplier/Procurement: We are committed to ensuring that our suppliers adhere to the highest standards of ethics.
Suppliers are required to demonstrate that they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour.
We work with suppliers to ensure that they meet the required standards. However, serious violations of our contractor or supplier policies will lead to the termination of the business relationship.
• Recruitment and Agency workers: We use only specified, reputable employment agencies and verify the practices of any new agency before accepting workers from that agency which will also be set out in their terms and conditions.
• Safeguarding Adults Policy: We highlight the obligation for colleagues to raise any concerns in relation
to modern slavery and human trafficking within our Safeguarding Adults Policy.
This statement was approved on 31 August 2023 by our Board of Directors, who review and update it annually.
Claire Leake, People Director
Date: August 2023