National Care Group Modern Slavery Policy Statement
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 describes the steps taken by National Care Group during the financial year from 1 April 2025 to 31 March 2026, to identify, prevent and address the risks of modern slavery in operations and supply chains.
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) recognises that modern slavery risks can arise in any organisation or supply chain and may not always be immediately visible. We are committed to identifying areas of heightened risk, strengthening preventative controls, responding appropriately where concerns arise and reporting transparently on our progress.
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. With 1390 adults supported, almost 3000 colleagues employed, and services operating over 242 locations across England and Wales as well as providing adult learning services within our specialist further education college.
Our supplier approval process incorporates a review of the controls undertaken by our suppliers. 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. The following have been identified as potential risk categories which are subject to enhanced scrutiny:
- Temporary labour and recruitment agencies, including off-panel agencies;
- Sponsored colleagues and people whose immigration status may increase vulnerability; and
- Construction, refurbishment and property maintenance contractors.
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.
The senior leadership team as well as colleagues with procurement/buying responsibilities attended an Anti-bribery and Corruption Workshop. The workshop 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 2027.
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 renewal of sponsorship for eligible colleagues however we no longer offer new sponsorship. 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. The following operating model is applied in the management of sponsored colleagues:
- NCG prohibits the charging of colleagues in relation to recruitment or sponsorship fees.
- Sponsored colleagues are made aware of confidential routes to raise concerns.
- Regular pay auditing and contractual compliance is undertaken.
- NCG has engaged with an external immigration partner to provide additional oversight.
Sponsored colleagues are made aware of their rights and the freedom to leave NCG should they wish.
NCG works with a neutral vendor in relation to managing temporary workers. The neutral vendor conducts due diligence checks on panel agencies and performs annual audits to ensure full compliance in relation to its workforce and ethical working practices. NCG will continue to remove agencies from panel if they fail to pass the audits.
Effectiveness
For the financial year ending March 2026, we can report:
- 99% of colleagues are compliant with their safeguarding training which includes Modern Slavery.
- 6 sponsored colleague pay audits were completed with corrective actions closed.
During the reporting year, NCG recorded 0 concerns potentially relevant to modern slavery.
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.
Our Priorities for 2026/27
During the year ahead, NCG will continue to strengthen its approach to identifying and addressing modern slavery risks. Our priorities are to complete a documented risk assessment across our operations and supply chains; extend consistent due diligence to all recruitment agencies and labour providers; introduce enhanced checks for suppliers operating in higher-risk categories; strengthen direct communication and confidential reporting routes for agency and sponsored colleagues; and develop a Board-level dashboard to monitor training, supplier assurance, concerns raised, remediation and progress against agreed actions.
We will review the effectiveness of these measures during the year and report transparently on progress, challenges and any lessons learned in our next statement.
This statement was approved on 27 August 2026 by our Board of Directors, who review and update it annually.
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