National Care Group (NCG) recognises its responsibility to take a robust approach to slavery and human trafficking and will continue to take this responsibility very seriously. 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.

This statement sets out NCG’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 there is no slavery or human trafficking within the organisation, or its supply chains. This statement relates to actions and activities for the financial year ending 31st March 2024.

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 including Regent College.

Organisational structure and supply chains

This statement covers the activities of NCG.  Through its network of locally managed services, NCG supports over 1,400 people with support needs including mental health, learning disabilities, autistic people and acquired brain injuries. This is provided in both residential and supported living settings across England and Wales, as well as providing learning services for young adults at Regent College.

As part of the organisation’s due diligence processes into slavery and human trafficking, its 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/human trafficking activities.  The level of management control required for these sources will be regularly monitored.  NCG will not support or deal with any business knowingly involved in slavery or human trafficking.  NCG’s Corporate Social Responsibility strategy includes objectives developed to measure and embed ethical behaviour across the organisation.

Taking action

As part of the procurement process, NCG will only engage with suppliers, contractors and partners who confirm their compliance with the Modern Slavery Act 2015. Responsibility for anti-slavery initiatives is set out as follows:

Supply chain assessments: NCG has reviewed the risks that its supply chains can present and whilst it considers its exposure to modern slavery to be limited, it expects 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 suppliers and their subcontractors to comply with the Modern Slavery Act 2015 (the Act).

Due Diligence: NCG will undertake due diligence when considering taking on new suppliers. The 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 regularly all aspects of the supply chain.

Training: NCG has re-promoted its existing Group policies to incorporate modern slavery and human trafficking issues, including the Whistleblowing policy which allows colleagues and workers to report any concerns anonymously and confidentially.  It requires managers and colleagues within the 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.

Awareness-raising programme: NCG has raised awareness of modern slavery issues by circulating our Modern Slavery Statement via its internal communication platform (Engage) 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 the organisation;
• what external help is available, for example through the Whistleblowing hotline; and
• facilitated through the Engage platform, colleagues can directly access senior management to raise issues or concerns. Engage also presents a channel for ensuring the modern slavery statement is shared transparently.

Overseas Recruitment

Through the offer of workplace sponsorship, NCG recognises modern slavery, including forced labour and human trafficking, is a pervasive global issue. NCG is dedicated to taking proactive steps to combat these practices and to promote fair and ethical treatment of all workers within the organisation and supply chain. This commitment is reflected in 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:

• Weekly, quarterly and annual audits are conducted to ensure equal pay and due diligence monitoring of colleagues sponsored.
• Pre-hire due diligence was conducted for colleagues working on another employer’s Certificate of Sponsorship to ensure they were meeting Home Office requirements.
• Annual review of the Safe Recruitment policy has been reviewed to ensure there is no element of bias or discriminatory practice within the hiring process.
• Implementation of Line manager training, reinforcing the importance of sponsorship compliance, reporting and eliminating bias through the recruitment and employment lifecycle process.

Relevant policies

NCG operates the following policies to describe its approach to the identification of modern slavery risks and the steps to be taken to prevent slavery and human trafficking in its operations:

Whistleblowing Policy: NCG encourages colleagues, customers and other business partners to report any concerns related to the direct activities of the organisation, or within the supply chains supporting the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Its whistleblowing procedure is designed to make it easy for colleagues to make disclosures, without fear of retaliation. Colleagues, customers, or others who have concerns, are encouraged to use its confidential helpline.

Colleague Code of Conduct: NCG’s code makes clear to colleagues the actions, responsibilities and behaviours expected of them when representing the organisation. NCG strives to maintain the highest standards of conduct and ethical behaviour when operating and managing its supply chain.

Supplier/Procurement: NCG is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate they provide safe working conditions, treat workers with dignity and respect, and act ethically and within the law in their use of labour. NCG works with suppliers to ensure they meet the required standards. However, serious violations of the contractor or supplier policies will lead to the termination of the business relationship

Recruitment and Agency workers: Through a neutral vendor provider, NCG uses only ‘on panel’, reputable employment agencies.  ‘On panel’ agencies go through a robust due diligence process which they are required to pass before joining the NCG panel.  Various checks are performed including 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: NCG highlights the obligation for colleagues to raise any concerns about modern slavery and human trafficking within its Safeguarding Adults Policy, where this sets out the importance and responsibility of colleagues.

This statement was approved on 31 August 2024 by the NCG Board of Directors, who review and update it annually.

Claire Leake, Chief People Officer