Hales Group is committed to the principles of the Modern Slavery Act 2015 and the abolition of modern slavery and human trafficking.

This policy describes the values, principles and procedures that underpin Hales Group’s approach to any situation where it becomes aware of, or has evidence of, involvement or the risk of involvement, direct or indirect, in enterprises that subject people to conditions that meet current definitions of modern slavery, human trafficking and forced labour. It applies to this organisation, all of its services and all other organisations with which it has dealings.

As an equal opportunities employer, we’re committed to creating and ensuring a non-discriminatory and respectful working environment for our staff. We want all our staff to feel confident that they can expose wrongdoing without any risk to themselves.

Our recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the UK and to safeguard employees from any abuse or coercion.

This policy is written in line with the safeguarding duties of local authorities under the Care Act 2014 (and equivalent applicable devolved government laws) to ensure any vulnerable adult is not subject to abuse by being a victim of modern slavery or forced labour, nor to any form of human trafficking or, for example, being coerced into such as “county line” drug trafficking.

It is also written to reflect the aims of the Modern Slavery Act 2015 that sets out the responsibilities and duties of corporate businesses and charities to prevent and avoid any dealings with any network or organisation implicated in modern slavery or human trafficking and to alert the police and other responsible authorities if they come across it.

Modern slavery includes, under its definition, forced and compulsory labour, human trafficking of children and adults and organised activities that involve people being coerced, controlled and exploited to carry out work to which they do not freely consent for the financial gain of their controllers.

We do not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Hales Group have a zero-tolerance approach to modern slavery and are committed to acting ethically and with integrity in all our business dealings and relationships. We are committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

Due to the nature of our business, we assess ourselves to have a low risk of modern slavery in our business and supply chains. Our supply chains are limited and we procure goods and services from a restricted range of UK and overseas suppliers.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all our contractors, suppliers and other business partners, and we expect that our suppliers will hold their own suppliers in the same high standards. This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

The UK’s Modern Slavery Act 2015 (MSA) includes a range of measures to combat modern slavery, including:

Law enforcement

Gives law enforcement the tools to pursue, disrupt, and punish those involved in modern slavery

Business reporting

Requires companies with a turnover of over £36 million to publish a Modern Slavery Statement annually. This statement must detail the actions the company is taking to combat modern slavery in its operations and supply chains. Our Modern Slavery Statement can be found on our websites and intranet portal.

Procurement regulations

Allows the mandatory exclusion of bidders from public procurements for certain modern slavery offenses

Responsibility for the policy

The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The People Services department has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on our expectations and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the People Services department via talktous@halesgroup.co.uk.

People Using the Service

As an organisation that provides, amongst other things, a care service, we ensure no vulnerable young person or adult in our care is subject to any conditions that meet the Care Act (and similar) definitions of modern slavery. If the service has any suspicions, information or evidence that any of the people using its services are victims of, or at risk of, becoming victims of modern slavery, exploitation or forced labour, we will take immediate protective action by alerting the appropriate safeguarding authority or police and apply all safeguarding procedures that then follow.

Staff

We also do not employ staff under any conditions that might make us vulnerable to accusations or suspicions that we are employing people under conditions that would amount to modern slavery and exploitation as defined. All staff are subject to recruitment procedures that comply with both employment law and registration requirements with pay and conditions of employment that meet or exceed all statutory requirements.

If we have evidence that any of our employees are subject to exploitation and forced labour by third parties, we will exercise our duty of care to our employees by reporting our concerns as whistleblowers to the police or local unit responsible for investigating modern slavery to decide on further investigation or action. We will not act or discriminate against the employee if they are meeting all the required employment conditions and had been recruited in line with the service’s recruitment procedures.

Contractors and Suppliers

As an organisation we deal with a number of outside organisations as suppliers of goods and services. We know that these organisations might form part of a longer supply chain. We make all reasonable efforts to ensure that no link in the supply chain is producing goods and services made under conditions of modern slavery or which might involve human trafficking.

We expect all our contractors and suppliers to have a similar zero-tolerance and due diligence approach to modern slavery and human trafficking and only work with organisations that have robust anti-modern slavery policies that operate in other parts of their supply chain and who comply with the Modern Slavery Act 2015.

We explain in our replies to businesses who respond to tenders and requests for goods and services that we will check if they employ people under conditions of modern slavery and if they do similar checks with other businesses in their supply chain. In doing so, we expect those businesses to have taken all reasonable efforts to exclude their suppliers from colluding with modern slavery practices.

All staff members, particularly those responsible for procuring goods and services, are expected to report any concerns about any issue or suspicion of modern slavery in any parts of their dealings at the earliest possible stage.

Anyone raising concerns about slavery or human trafficking that affects the care service will be protected by the service’s whistleblowing policy.

Compliance with the policy

All staff, contractors, volunteers and suppliers must ensure that they read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager as soon as possible if you believe or suspect that a conflict with or breach of this policy has occurred, or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform People Services immediately. If the matter is not remedied, and you are an employee you should raise it formally using our Grievance Procedure.

Communication and awareness of this policy

All staff are made familiar with the anti-slavery policy particularly in respect of the safeguarding of vulnerable people and they are expected to report any concerns in line with the service’s safeguarding policies and procedures.

Staff responsible for the procurement of goods and services will receive training so that they can ensure that the service is never implicated in any dealings that would render it vulnerable to accusations or charges that it might have breached modern anti-slavery law and how to respond to any suspicions or evidence of breaches in the law

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for us, and regular training will be provided as necessary. We will adopt a continuous improvement approach to our training and development, sharing learning and best practice through bulletins, our intranet, policy updates, newsletters, peer meetings and themed activities.

We will continue to embed the principles through:

• providing awareness training to staff on the Modern Slavery Act 2015 and informing them of the appropriate action to take if they suspect a case of slavery or human trafficking
• ensuring staff involved in procurement activity are aware of and follow modern slavery procurement guidance on GOV.UK
• ensuring that consideration of the modern slavery risks and prevention are added to our policy review process as an employer and procurer of goods and services
• making sure procurement strategies and contract terms and conditions include references to modern slavery and human trafficking
• continuing to take action to embed a zero tolerance policy towards modern slavery
• ensuring that staff involved in buying or procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices

Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. All suppliers are required to complete a supplier approval form, the process of which requests information about their own modern slavery policies and practices. This information will be subject to audit and regular review, in order to remain an approved supplier to Hales Group Ltd.

Breaches of this policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with suppliers, contractors, business partners and any other individuals and organisations working with us or on our behalf if they breach this policy.

Stakeholder Consultation/Involvement

The Hales Group Board have a vision of openness, transparency and value the feedback of our service users, staff, stakeholders and regulators. We therefore strive to consult with a number of individuals when developing and reviewing polices to ensure that not only do we meet the Legislative, Regulatory and Contractual requirements, but the local needs of the people this policy will impact upon.

During reviews of this policy, we take feedback; from our annual quality assurance surveys from Service Users, Stakeholders and Staff; from lessons learnt following complaints or incidents; from best practice shared within and external to this organisation. This allows us to identify weaknesses within our procedural processes which may be taken into account during reviews.

Accessible Information

For people with an accessible information need, this information can be provided in an alternative format to standard printed or handwritten English, for example large print, braille, or email. Additionally, we may be able to supply some documentation in other languages or an easy read pictorial format.

Our policies in relation to the Modern Slavery Act 2015

The following policies are available to all staff through the intranet:

• Code of conduct
• Whistleblowing policy
• Bullying and harassment policy
• Diversity and inclusion policy
• Safer Recruitment policy