Modern Slavery Policy

Policy Statement

AESN Care has zero tolerance for modern slavery, forced labour, human trafficking and exploitation. Care-sector workers and people receiving care may be vulnerable to exploitation, and AESN Care will seek to prevent, recognise and respond to concerns through safeguarding, recruitment, supplier due diligence and whistleblowing arrangements.

1. Introduction

Modern slavery can occur in many forms and may be hidden within employment, housing, financial arrangements or relationships. AESN Care recognises that people receiving care and migrant or otherwise vulnerable workers may face particular risks.

2. Purpose

This policy establishes responsibilities for prevention, recognition, reporting and learning.

3. Scope

The policy applies to AESN Care staff, recruitment activity, suppliers and relevant third parties acting for or with AESN Care.

4. Policy Objectives

• Prevent forced labour and exploitation.
• Maintain appropriate recruitment checks.
• Recognise indicators of trafficking and exploitation.
• Escalate concerns through safeguarding and other appropriate routes.
• Consider modern slavery risks in relevant supplier relationships.
• Support whistleblowing and safe reporting.

5. Definitions

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. Exploitation can involve coercion, deception, threats, debt or abuse of vulnerability.

6. Legal and Regulatory Framework

This policy reflects the Modern Slavery Act 2015 and relevant safeguarding, employment and criminal-law requirements. Any statutory statement or threshold-based reporting obligation will only be asserted where applicable to AESN Care.

7. Roles and Responsibilities

• Management promotes prevention and appropriate due diligence.
• Managers must act on indicators or concerns.
• Staff must remain alert to signs of exploitation and report concerns.
• Procurement personnel should consider relevant supplier risks.
• People we support should be treated with dignity and listened to.

8. Policy Requirements / Principles

• No person should be coerced into work or care arrangements.
• Recruitment checks must be completed appropriately.
• Workers must not be charged improper recruitment-related costs or subjected to coercion.
• Concerns about exploitation of people we support are safeguarding concerns.
• Supplier relationships should be reviewed proportionately for relevant risks.
• No one should be victimised for raising a genuine concern.

9. Procedures

Indicators may include fearfulness, restricted movement, control of identity documents, unexplained debt, threats, poor living conditions, unusual control of wages, injuries or inconsistent explanations. Staff should not investigate suspected trafficking themselves where doing so could increase risk. Concerns should be escalated promptly through safeguarding or appropriate external channels.

10. Reporting and Escalation

Immediate danger should be referred to emergency services. Safeguarding concerns should be escalated to the appropriate local authority or other relevant safeguarding route. Suspected criminal conduct may require police referral.

11. Records and Documentation

Concerns, actions and referrals should be recorded securely, objectively and without unnecessary detail.

12. Training and Competence

Relevant staff will receive awareness training appropriate to their role, including recognition of exploitation and reporting responsibilities.

13. Monitoring and Compliance

Management may monitor recruitment checks, supplier due diligence, safeguarding themes, whistleblowing concerns and training.

14. Breaches / Non-Compliance

Failure to report or deliberate involvement in exploitation may result in disciplinary action and, where appropriate, external referral.

15. Equality, Diversity and Human Rights

Modern slavery is fundamentally incompatible with dignity, equality, autonomy and human rights. Support will be person-centred and sensitive to communication and cultural needs.

16. Confidentiality and Data Protection

Information will be shared on a need-to-know and lawful basis, recognising that safeguarding may require information sharing without consent in appropriate circumstances.

17. Related Policies and Procedures

• Safeguarding Policy
• Whistleblowing Policy
• Anti-Bribery & Corruption Policy
• Equal Opportunities & Diversity Policy
• Data Protection Policy

18. Review and Continuous Improvement

Learning from safeguarding referrals, recruitment checks, supplier reviews and incidents will inform improvements.

19. Policy Review

This policy will be reviewed periodically and when legislation, safeguarding guidance or operational risks change.

Related Policies

• Safeguarding Policy
• Whistleblowing Policy
• Anti-Bribery & Corruption Policy
• Equal Opportunities & Diversity Policy

Review Arrangements

This policy will be reviewed by AESN Care Management at appropriate intervals and sooner where there is a significant change in legislation, regulation, service delivery, risk, guidance, learning from incidents or complaints, or organisational arrangements. Review findings and resulting actions will be documented.

Approval

Approved by: AESN Care Management