Modern Slavery Policy

Every Step Social Care

Our Commitment to Ethical, Transparent, and Safe Practice

Version: 1.0

Effective Date: May 2025

Last Reviewed: May 2025

Next Review Due: May 2026

Policy Owner: Director / Registered Manager

Applies To: All staff, volunteers, contractors, and suppliers

1. Introduction and Purpose

Every Step Social Care is committed to acting ethically and with integrity in all our business relationships. We take a zero-tolerance approach to modern slavery, human trafficking, forced labour, and all forms of exploitation in any part of our organisation or supply chain.

This policy has been produced in accordance with the Modern Slavery Act 2015, which requires organisations providing services in the UK to be transparent about the steps they are taking to prevent modern slavery and human trafficking in their business and supply chains.

As a social care provider operating in South East London, we recognise that our sector — which employs vulnerable workers and serves vulnerable people — carries a heightened responsibility to be vigilant, proactive, and transparent in this area.

This policy applies to all individuals working for or on behalf of Every Step Social Care, including employees, managers, directors, agency workers, volunteers, contractors, and suppliers.

2. What Is Modern Slavery?

Modern slavery is a serious crime and a violation of fundamental human rights. It takes several forms, all of which involve one person depriving another of their liberty in order to exploit them for personal or commercial gain. Under the Modern Slavery Act 2015, modern slavery includes:

2.1 Human Trafficking

Recruiting, transporting, transferring, harbouring, or receiving a person through coercion, deception, or abuse of power, for the purpose of exploitation.

2.2 Forced or Compulsory Labour

Work or services extracted from a person under the threat of a penalty, where the person has not offered themselves voluntarily. This includes debt bondage, where a person is forced to work to pay off a debt that can never realistically be repaid.

2.3 Servitude

A severe form of forced labour where a person is obliged to live on another’s property and cannot leave or change their situation.

2.4 Domestic Servitude

Particularly relevant to the care sector — where individuals are forced to work in private homes or care settings with no freedom, no pay, and no right to leave.

2.5 Child Labour and Exploitation

Using children for work that deprives them of their childhood, their potential, and their dignity. Every Step Social Care has a specific safeguarding duty to identify and respond to children at risk of exploitation.

3. Our Legal Obligations

Every Step Social Care operates in full compliance with the following legislation and statutory guidance:

• Modern Slavery Act 2015 — the primary legal framework for preventing and prosecuting modern slavery in the UK
• Care Act 2014 — requires us to safeguard adults at risk of abuse and exploitation
• Children Act 1989 and 2004 — requires us to protect children from harm, including exploitation
• Employment Rights Act 1996 — protecting workers’ rights to fair pay and safe working conditions
• National Minimum Wage Act 1998 — ensuring all workers receive at least the legal minimum wage
• Equality Act 2010 — protecting workers and service users from discrimination
• Immigration, Asylum and Nationality Act 2006 — preventing exploitation of undocumented workers
• Home Office statutory guidance on the National Referral Mechanism (NRM)

We also follow guidance issued by the Care Quality Commission (CQC), Skills for Care, and the Social Care Institute for Excellence (SCIE) on ethical employment and safeguarding practice.

4. Our Business and Supply Chain

4.1 Our Business

Every Step Social Care provides independent social care services including family support, social work assessments, supported living, and adult home care across South East London. We directly employ trained social care professionals and support workers.

Given the nature of our work with vulnerable adults, children, and families, we recognise that our staff and the people we care for may themselves be at risk of exploitation. This makes our commitment to identifying and preventing modern slavery especially important.

4.2 Our Supply Chain

Our supply chain includes:

• Recruitment agencies and staffing providers who supply agency workers
• Training providers delivering mandatory and specialist training to our staff
• IT and software providers supporting our case management and administration
• Premises and facilities suppliers
• Professional services including legal, financial, and insurance providers

We acknowledge that supply chain risks exist, particularly in recruitment. Agency workers in care settings can be vulnerable to exploitation if recruitment agencies do not operate to high ethical standards. We take steps to ensure that all agencies we work with are reputable and compliant with UK employment law.

5. Risk Assessment

We have assessed the risk of modern slavery occurring in our business and supply chain. Our key risk areas are:

6. Our Commitments and Actions

6.1 Safer Recruitment

We are committed to safe and ethical recruitment practices. All staff employed by Every Step Social Care undergo:

• Enhanced Disclosure and Barring Service (DBS) checks before starting work
• Right to work verification in line with Home Office guidance
• Employment history verification and reference checks
• Identity document checks
• Induction training that includes awareness of modern slavery and exploitation

We do not use recruitment models that involve workers paying fees to secure employment. We do not engage with any agency that charges workers placement fees, as this is a recognised indicator of labour exploitation.

6.2 Fair Employment Practices

Every Step Social Care is committed to being a fair and ethical employer. We ensure:

• All workers receive at least the National Living Wage or National Minimum Wage
• All workers have a written contract of employment in plain English
• Workers are free to leave their employment at any time
• Workers are not required to live on our premises or surrender identity documents
• Wages are paid directly to workers and not withheld or deducted unlawfully
• Workers have access to trade union membership and know their rights
• Workers from overseas are fully informed of their rights under UK law

6.3 Staff Training and Awareness

We believe that prevention begins with awareness. All staff at Every Step Social Care receive:

• Mandatory modern slavery awareness training as part of their induction
• Regular refresher training at least once every two years
• Safeguarding training that includes recognition of exploitation indicators
• Clear guidance on how to report concerns internally and externally

Managers and senior staff receive enhanced training on the National Referral Mechanism (NRM) and how to make referrals when a potential victim is identified.

6.4 Supplier Due Diligence

We take a risk-based approach to managing our supply chain. We:

• Use only reputable, UK-registered suppliers and contractors
• Require all significant suppliers to confirm their compliance with the Modern Slavery Act 2015
• Include anti-slavery and anti-trafficking clauses in all supplier contracts
• Reserve the right to audit suppliers and terminate relationships where concerns are identified
• Prioritise suppliers who demonstrate visible commitment to ethical employment

6.5 Service User Safeguarding

Our work brings us into close contact with people who may be vulnerable to exploitation, including adults with care needs, children in families we support, and young people in our supported living services. We are committed to:

• Recognising and responding to signs of exploitation, trafficking, or modern slavery in the people we support
• Referring any concerns to the relevant statutory authority, including the local authority safeguarding team, the police, or the National Referral Mechanism
• Supporting potential victims sensitively and without judgment
• Not placing staff or service users in situations where exploitation risks are unmanaged

7. Indicators of Modern Slavery

All staff are trained to recognise potential indicators of modern slavery. These may include, but are not limited to:

7.1 In Workers or Job Applicants

• Appearing fearful, anxious, or reluctant to speak freely
• Being accompanied and controlled by another person
• Not being in possession of their own identity documents
• Living in overcrowded or unsuitable accommodation with their employer
• Showing signs of physical abuse, malnourishment, or exhaustion
• Unable to confirm their home address or speak without permission
• Working excessive hours for little or no pay

7.2 In Service Users or People We Support

• Appearing controlled, monitored, or fearful of a carer or family member
• Signs of physical harm, neglect, or malnourishment
• Being isolated from friends, family, or support networks
• Unexplained absences or sudden changes in behaviour
• Children who appear to be working or living in inappropriate conditions
• Adults who appear to have no control over their finances, movements, or decisions

8. How to Report a Concern

Every Step Social Care operates a safe and transparent reporting culture. Anyone — staff, service users, family members, or members of the public — who suspects modern slavery or human trafficking should report it immediately.

8.1 Internal Reporting

Report to: Your line manager, the Registered Manager, or the Designated Safeguarding Lead

Email: info@everystepsocialcare.co.uk

All reports will be treated seriously, investigated promptly, and handled with strict confidentiality. No member of staff will face any negative consequence for raising a genuine concern in good faith.

8.2 External Reporting

Concerns can also be reported directly to external agencies:

9. Our Response to Identified Cases

If a potential case of modern slavery or trafficking is identified — whether involving a worker, service user, or person known to us — Every Step Social Care will:

• Ensure the immediate safety of the individual and take emergency action if required
• Contact the police or relevant statutory authority without delay
• Make a referral to the National Referral Mechanism (NRM) where appropriate
• Provide sensitive, trauma-informed support to the individual
• Preserve any evidence and cooperate fully with investigations
• Review our policies and practices to prevent recurrence

We will not take any action that could compromise the safety of a potential victim or jeopardise a criminal investigation.

10. Whistleblowing Protection

Every Step Social Care fully supports the right of staff to raise concerns without fear. Our Whistleblowing Policy provides clear protection for anyone who reports a genuine concern about modern slavery, exploitation, or any other wrongdoing in good faith.

Any member of staff who raises a concern will be protected from dismissal, disciplinary action, or any other detriment as a result of their disclosure. This protection applies even if the concern turns out to be unfounded, provided it was raised honestly and in good faith.

Concerns can be raised anonymously if preferred. All reports will be treated with complete confidentiality.

11. Responsibilities

12. Policy Review and Transparency

This policy will be reviewed annually by the Director and Designated Safeguarding Lead, or sooner if:

• There is a change in relevant legislation or statutory guidance
• A modern slavery concern is identified within our organisation or supply chain
• There is a significant change to our business model or supply chain

Every Step Social Care will publish an annual Modern Slavery Statement on our website in accordance with the Modern Slavery Act 2015. This statement will describe the steps we have taken during the financial year to ensure modern slavery is not taking place in our business or supply chain.

13. Related Policies

This policy should be read alongside the following Every Step Social Care policies:

• Safeguarding Children Policy
• Safeguarding Adults at Risk Policy
• Safer Recruitment Policy
• Whistleblowing Policy
• Equal Opportunities and Diversity Policy
• Code of Conduct
• Data Protection and Privacy Policy

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Every Step Social Care — South East London, UK