Introduction

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 within the organisation, or it supply chains. This statement relates to actions and activities for the financial year ending 31st March 2026 and reflects our continued compliance with Section 54 of the Modern Slavery Act 2015.

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, a national provider of specialist support and accommodation for adults with a learning disability, autism, mental health illness or acquired brain injury. Over 1350 adults are supported, almost 3000 colleagues employed, and our services operate over 241 locations 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 of slavery and human trafficking activities.  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.  National Care Group’s Corporate Social Responsibility strategy includes objectives developed to measure and embed ethical behaviour across the organisation.

Taking action

As part of NCG’s 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 below:

• Supply chain assessments: 
  We regularly review 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:
  • mapping the supply chain broadly to assess product or geographical risks of modern slavery and human trafficking;
  • evaluating the modern slavery and human trafficking risks of each new supplier; and
  • reviewing on a regular basis all aspects of the supply chain.
• Training:
  We ensure that existing NCG-wide policies incorporate modern slavery and human trafficking issues where appropriate, including our Whistleblowing policy which allows colleagues and workers to report any concerns anonymously and 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:
  • how to identify the signs of slavery and human trafficking; and
  • what steps should be taken if slavery or human trafficking is suspected or witnessed.

A new training course has been developed for senior leadership and colleagues with procurement/buying responsibilities to attend an Anti-Bribery and Corruption Workshop. This workshop also included education and awareness of human trafficking and modern slavery.  This additional course reflects NCG’s commitment to embedding ethical working practices and will continue to be delivered throughout the current financial year ended 31 March 2026.

• Awareness-raising programme:
  We maintain awareness of modern slavery issues by circulating our Modern Slavery Statement annually via our internal communication platform accessible to all colleagues/workers.  The communication explains to colleagues:
  • the basic principles of the Modern Slavery Act 2015;
  • how colleagues/workers can identify and prevent slavery and human trafficking;
  • what colleagues/workers can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation;
  • what external help is available, for example through the Whistleblowing hotline; and
  • facilitated through the communications platform/app (Engage) colleagues can directly access senior management to raise issues or concerns. This also presents an avenue for ensuring the modern slavery statement is shared transparently.

• Safe Recruitment

NCG continues to offer workplace sponsorship for eligible colleagues.  We recognise that modern slavery, including forced labour and human trafficking, is a pervasive global issue and an issue presented within the UK adult social care sector through poor hiring practices of some private providers and temporary worker agencies. National Care Group is dedicated to taking proactive steps to combat these practices and to promote fair and ethical treatment of all workers/colleagues within our organisation and supply chain. This commitment is reflected in our policies, due diligence processes, and ongoing efforts to enhance transparency and accountability.

To ensure that NCG eliminates any risks associated with sponsorship, the following procedures are regularly conducted:

• • NCG is managing its sponsored and non-EU/British national colleagues via a digital platform called Borderless. This platform provides us with full visibility of our non-UK colleagues and ensures we remain compliant with right to work requirements. Regular audits are conducted to ensure equal pay and due diligence monitoring of colleagues sponsored.
  • Pre-hire due diligence is conducted for colleagues working on another employer’s Certificate of Sponsorship (CoS) to evidence compliance under their right to work status (CoS).
  • The Safe Recruitment policy is reviewed annually to ensure there is no element of bias or discriminatory practice within the hiring process.
  • Line manager training and coaching is delivered, reinforcing the importance of sponsorship compliance, reporting and eliminating bias through the recruitment and employment lifecycle process.
  • NCG works with a neutral vendor in relation to managing temporary workers. The neutral vendor conducts due diligence checks on every agency that is assigned to NCG’s panel and performs annual audits to ensure full compliance in relation to its workforce and ethical working practices.  NCG has removed agencies from its panel based on unsatisfactory audit compliance levels and will continue to take this position for the foreseeable future.

Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and the 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 of our organisation, or within the supply chains supporting 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 colleagues or workers to make disclosures, without fear of retaliation. Colleagues, workers, customers, or others who have concerns, are encouraged to use our confidential helpline.
• Colleague Code of Conduct:
  Our code makes clear to colleagues the actions, responsibilities and behaviours expected of them when representing our organisation. We strive to maintain the highest standards of 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:
  Through a neutral vendor provider, we use only on panel, reputable employment agencies.  On panel agencies go through a robust due diligence process which they are required to pass prior to joining the NCG panel.  Checks are performed in relation to financial sustainability, verification of practices including employment legislation and modern slavery and human trafficking.  The neutral vendor also conducts an annual audit of all agencies on panel to ensure ongoing compliance.
• 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, where this sets out the importance and the responsibility of colleagues.

This statement was approved on 28 August 2025 by our Board of Directors, who review and update it annually.