Modern Slavery Policy

1. Policy Statement

The Home Care Hub maintains a strict zero-tolerance approach to modern slavery, human trafficking, forced labour, and domestic servitude in all its operations and supply chains.

We are committed to acting ethically and with integrity in all our business relationships. We expect the same high standards from all suppliers, contractors, and business partners, ensuring that modern slavery has no place within our care delivery or procurement operations in compliance with the Modern Slavery Act 2015.

2. Risk Areas in Care & Operations

We recognise that the health and social care sector can face modern slavery risks, particularly in the recruitment of domestic and international care staff, agency staffing, and procurement.

Key risk factors include:

• Debt Bondage & Recruitment Fees: Workers being forced to pay illegal recruitment fees or sign exploitative contracts before or after entering the UK.

• Unfair Pay & Exploitation: Unlawful deductions from wages, non-payment of the National Minimum Wage, or forced overtime.

• Coercive Control & Restrictive Visas: Workers having their passports, visas, or personal documentation withheld by third parties or agencies.

• Substandard Accommodation: Care staff tied to inadequate or overpriced housing linked to their employment.

3. High-Standard Recruitment & Vetting Controls

To mitigate the risk of forced labour and human trafficking within our workforce:

• Direct Verification: We directly verify the identity, right-to-work status, and original documentation of all care personnel prior to engagement.

• Direct Salary Payment: All wages are paid directly into a verified bank account owned by the individual worker.

• Strict Agency Vetting: We only work with reputable, audited recruitment agencies and labour providers that fully comply with UK labour laws and do not charge candidate recruitment fees.

• Transparent Contracts: Every worker receives clear, written terms of employment that explain their duties, pay rates, working hours, and notice periods, in a language they understand.

4. Supply Chain Due Diligence

The Home Care Hub assesses risk across all aspects of its supply chain (including medical supplies, PPE, cleaning products, IT, and administrative services):

• Risk Assessments: Evaluating high-risk suppliers based on industry, geographic location, and labour intensity.

• Supplier Expectations: Requiring key suppliers to confirm their compliance with the Modern Slavery Act 2015.

• Audit Rights: Reserving the right to audit or review supplier practices where risks of modern slavery or poor labour standards are identified.

5. Identifying Indicators of Modern Slavery

All care personnel and staff are encouraged to remain vigilant for signs of potential modern slavery among colleagues or service users:

• Physical Signs: Signs of physical abuse, untreated injuries, malnutrition, or poor hygiene.

  Behavioural Signs: Extreme fear, anxiety, distrust of authority, or allowing someone else to speak for them.

• Restricted Freedom: Lack of access to personal identification documents (passports, IDs), mobile phones, or financial accounts.

• Living & Working Conditions: Transported to and from work under unusual supervision, living in overcrowded or inadequate housing, or working excessively long hours without rest breaks.

6. Reporting Mechanisms & Whistleblowing

Any employee or worker who suspects or identifies signs of modern slavery must report it immediately:

• Internal Reporting: Notify the Designated Safeguarding Lead (DSL) or senior management.

• Whistleblowing Protection: Reports made in good faith will be treated confidentially, and workers are fully protected under our Whistleblowing Policy from any form of retaliation.

• External Reporting & Escalation:

  If someone is in immediate danger, call 999.

  Report concerns to the UK Modern Slavery & Human Trafficking Helpline on 08000 121 700 or online at modernslaveryhelpline.org.

  Notify local authority safeguarding teams or statutory bodies where vulnerable care recipients are affected.

7. Policy Review

This policy is reviewed annually by management to ensure its ongoing effectiveness, compliance with evolving UK legislation, and alignment with industry best practices.

Responsible Lead: Lily Wright, Founder & CEO

Contact Email: hello@thehomecarehub.co.uk