CCS Care Modern Slavery Policy

CCS Care Recruitment Ltd

This statement sets out the steps that CCS CARE & CCS CARE RECRUITMENT LTD has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CCS CARE RECRUITMENT LTD has a zero- tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains.

We provide our services nationwide.

CCS CARE RECRUITMENT LTD implements its business strategy in an ethically, socially and environmentally responsible manner. We fully acknowledge our responsibility to respect human rights as set out in the International Bill of Human Rights. The IBHR informs all of our policies related to the rights and freedoms of every individual who works for us, either as a direct employee, agency worker or indirectly through our supply chain. We are also committed to implementing the United Nations Guiding Principles on Business and Human Rights throughout our operations. Respect for the dignity of the individual – and the importance of each individual’s human rights – form the basis of the behaviours we expect in every workplace nationally.

We will not accept any form of discrimination, harassment or bullying and we require all of our managers to implement policies designed to increase equality of opportunity and inclusion for all employees including agency workers. We have also developed and implemented policies and processes which are intended to extend these commitments through our supply chain.

Policies

We have several internal policies to ensure that we are conducting business ethically and transparently. These include:

  • Human Rights policy and our Ethics Policy where we confirm that we will not tolerate or condone the abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not properly respected
  • Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery. All reports will be fully investigated, and appropriate remedial actions are taken and we will work closely with social care and health providers ensuring that our policies and procedures dovetail with local procedures and best practice
  • A robust recruitment policy, including conducting eligibility to work in the UK checks for all employees to safeguard
  • Employee Code of Conduct consistent with any professional codes of conduct

Direct Communication

The Company encourages members of the public or people not employed by us to write, in confidence, to raise any concern, issue or suspicion of modern slavery in any part of our business.

Suppliers

We conduct due diligence on all suppliers before allowing them to become a preferred supplier. We include an online search to ensure that particular organisations have never been convicted of offences relating to modern slavery and we include our modern slavery policy as part of our contract with all suppliers. Suppliers are required to confirm that no part of their business operations contradicts this policy. As part of our contract with suppliers, they confirm to us that:

  1. They have taken steps to eradicate modern slavery within their business
  2. They hold their suppliers to account over modern slavery
  3. For UK based suppliers, they pay their employees at least the national minimum wage/national living wage (as appropriate) and to ensure that within their supply chains, where UK based suppliers have overseas supply chains, that their employees’ pay is consistent with their national minimum wage requirements.
  4. We may terminate the contract at any time should any instances of modern slavery come to light

Risk Assessments

Our supply chains include procurement of staff, consumables, facilities maintenance, utilities and waste management. We have conducted a risk assessment and will ensure that we will take further steps to ensure that we support the eradication of modern slavery, that staff understand how to recognise modern slavery and the appropriate safeguarding reporting processes are followed should there be concerns within our supply chains, with customers or suppliers.

Performance indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery is not taking place within our business or supply chain if:

  • No reports are received from employees, the public, or law enforcement agencies or local safeguarding teams to indicate that modern slavery practices have been identified

Safeguards

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 that 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 business. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. CCS CARE RECRUITMENT LTD will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and makes validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual.

Responsibility for this Statement

The ultimate responsibility for the prevention of modern slavery rests with the Managers for ensuring that this policy and its implementation complies with our legal and ethical obligations. Managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.

Assessment of effectiveness in preventing Modern Slavery

We understand that modern slavery risk is not static and will continue our approach to mitigating this risk. We will assess the risk via our internal auditing processes.

This statement is made according to section 54(1) of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement of CCS CARE RECRUITMENT LTD for the financial year ending 2021. Director of CCS CARE RECRUITMENT LTD has approved this statement. 

Approval for this statement

This statement was approved by the Munashe Ali

Operations Manager

Date 01/01/2021

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CCS CARE RECRUITMENT LTD has a zero- tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains. 

  • (This statement is made pursuant to the Modern Slavery Act 2015 s54(1) and constitutes our group statement for the current financial year.)
  • The Modern Slavery Act 2015
  • Health and Safety at Work etc. Act 1974
  • Human Rights Act 1998
  • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012

Introduction

CCS Care Recruitment Ltd is a company incorporated in England and Wales. Our company number is 12718648 and our registered address is 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX. CCS CARE RECRUITMENT LTD implements its business strategy in an ethically, socially, and environmentally responsible manner. We fully acknowledge our responsibility to respect human rights as set out in the International Bill of Human Rights. The IBHR informs all of our policies related to the rights and freedoms of every individual who works for us, either as a direct employee, agency worker or indirectly through our supply chain. We are also committed to implementing the United Nations Guiding Principles on Business and Human Rights throughout our operations. Respect for the dignity of the individual – and the importance of each individual’s human rights – form the basis of the behaviours we expect in every workplace nationally.

CCS Care and CCS Care Recruitment is a company that provides a range of flexible individualised care and support services for people with learning disabilities, mental health support needs and older people. Our services include supported living, domiciliary care, housing & care (extra care) schemes, care homes, day services and respite/short breaks. We provide support nationwide.

We will not accept any form of discrimination, harassment or bullying and we require all of our managers to implement policies designed to increase equality of opportunity and inclusion for all employees including agency workers. We have also developed and implemented policies and processes which are intended to extend these commitments through our supply chain.

Our Supply Chains

CCS Care Recruitment look to source from recognised organisations, vetting them wherever practicable. Our supply chain relates to the provision of goods and services that a social care organisation would normally require, e.g. business support and the supply of labour.

We are committed to ensuring that our supply chains are free of any suggestion of slavery or human trafficking. To ensure this, we seek to work with those organisations that share our values and can demonstrate that they too work ethically and with integrity. 

Due Diligence Processes

We undertake due diligence in respect of our purchasing activities and, wherever possible, we establish sound and long-standing relationships with our suppliers. 

We have a due diligence process in place in respect to our procurement, which requires potential suppliers to demonstrate that they operate under their own due diligence processes for those that they do business with. 

We ensure that our staff are not only competent and capable but are also eligible to undertake work on our behalf. We have systems in place to support and protect whistle-blower. 

Management Responsibility

We have ensured that our senior managers have been briefed in respect to this legislation, our organisational responsibility, and what checks we are required to carry out. 

Ensuring We Remain Compliant

To ensure we remain compliant we:

  • Undertake regular reviews of our purchasing processes
  • Ensure that our HR and payroll systems are effective to identify and report on any potential breach of this legislation
  • Maintain good and open communication within our supply chain to ensure that there is clear understanding of our expectations

Objectives  

  • To promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of CCS CARE RECRUITMENT LTD in addressing slavery and human trafficking in all its forms. An annual statement will be produced, where applicable.
  • To ensure that identification, protection, care and support for victims of modern slavery and human trafficking is at the heart of our safeguarding procedures at CCS CARE RECRUITMENT LTD of any wrongdoing raised by employees within CCS CARE RECRUITMENT LTD without fear of reprisal.
  • CCS CARE RECRUITMENT LTD will use Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour, and human trafficking, all of which include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
  • CCS CARE RECRUITMENT LTD has a zero-tolerance approach to modern slavery within the business and supply chains and we are committed to acting ethically and with integrity in all our dealings and relationships. We will implement and enforce effective systems and controls to ensure that modern slavery is not taking place anywhere in CCS CARE RECRUITMENT LTD or within any third parties (agencies) that we are associated with.
  • All staff will be made aware of the issues surrounding slavery and human trafficking, whilst
  • being encouraged and supported to report any concerns to CCS CARE RECRUITMENT LTD management. CCS CARE RECRUITMENT LTD will also support any staff that may be subject to slavery or human trafficking.
  • Where modern slavery or human trafficking is identified, CCS CARE RECRUITMENT LTD will share information with the Kent County Council and Medway Council Safeguarding Team to safeguard the individual from harm and with the objective of preventing future situations arising, to promote the elimination of routes and sources of slavery or human trafficking.
  • All line managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.
  • All employees who suspect any members of the workplace being victim of modern slavery must notify their line manager.
  • CCS CARE RECRUITMENT LTD will take steps to ensure that sufficient communication and employee awareness training is undertaken with regards to Modern Slavery.
  • All employees will be made aware of PM11 – Whistleblowing Policy and Procedure at CCS CARE RECRUITMENT LTD. The purpose of this policy and associated procedure is to enable CCS CARE RECRUITMENT LTD to thoroughly investigate allegations this policy to underpin and inform any statement on slavery and human trafficking that we may be required to produce to meet the requirements of Section 54 of the Modern Slavery Act 2015 (MSA).

Reporting Modern Slavery and Human Trafficking Concerns

The following procedure must take place where there are any concerns that someone is a victim of modern slavery or human trafficking. CCS CARE RECRUITMENT LTD must ensure that staff are aware that victims of modern slavery or trafficking will often not self-identify. Many will present with a different issue.

  1. A concern is identified -This could be a Service User as a victim or perpetrator, or a Service User informs us of a concern they have
  2. If an individual is, or group of people are, in immediate risk of danger or harm, the police must be immediately notified on 999
  3. The staff member must discuss this with their line manager (where appropriate) and the Nancy Ali immediately
  4. The Nancy Ali contacts and escalates the concern immediately to Kent County Council and Medway Council Safeguarding Adults Team
  5. A notification is made to the CQC via the provider portal

Safer Recruitment 

All staff engaged with providing services at CCS CARE RECRUITMENT LTD will be subject to thorough and rigorous recruitment procedures that will include a DBS check, identity check, confirmation of validity to work in the UK, employment history, suitability for the role and references. This will minimise the chance of employing a person that has been, or is subject to, slavery or human trafficking. 

CCS CARE RECRUITMENT LTD will follow PR16 – Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times. 

CCS CARE RECRUITMENT LTD will only use staff provided by third-party organisations (such as agencies) that are either registered with the regulator or who can confirm that the staff being supplied are free to work in the UK and meet all the requirements for the role being provided for. 

Training 

All staff will undertake training on Modern Slavery and Human Trafficking. This will ensure that they are aware of the indicators of modern slavery which include:

  • Individuals not being paid for the work they undertake
  • Individuals being held in debt-bondage (being told they “still” owe money after having paid off a previous debt)
  • An individual’s passport being held by their “employer” in order to keep the individual at work
  • Multiple benefit claimants having their benefits being paid into the same account
  • An individual not having the freedom of movement (i.e. passport being taken)
  • Clear exploitation of an individual by another for financial or sexual gain
  • Shows signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated injuries
  • Rarely be allowed to travel on their own, seem under the control, the influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they work
  • Relationships which do not seem right – for example, a young teenager appearing to be the boyfriend/girlfriend of a much older adult
  • Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address
  • Have no identification documents, have few personal possessions and always wear the same clothes day in and day out. What clothes they do wear may not be suitable for their work
  • Have little opportunity to move freely and may have had their travel documents retained, e.g. passports
  • Be dropped off/collected for work on a regular basis either very early or late at night
  • Unusual travel arrangements – children being dropped off/picked up in private cars/taxis at unusual times and in places where it is not clear why they would be there
  • Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their family

Staff will be advised that if they are subject to slavery or human trafficking, if they are aware of any individual that may be subject to slavery or has been trafficked, or if slavery or human trafficking is disclosed to them they must inform the Registered Manager of CCS CARE RECRUITMENT LTD or the police.

Modern Slavery Annual Reporting during COVID 

The Government guidance states that under section 54 of the Modern Slavery Act 2015, certain businesses are required to publish an annual modern slavery statement setting out the steps they have taken to identify and address their modern slavery risks. During the coronavirus pandemic, it is essential that CCS CARE RECRUITMENT LTD continues to identify and address the risks of modern slavery in operations and supply chains. As well as focusing on the health and safety of workers, CCS CARE RECRUITMENT LTD will consider how fluctuations in demand and changes in the operating model may lead to new or increased risks of labour exploitation.

If CCS CARE RECRUITMENT LTD needs to delay the Modern Slavery statement

The challenges presented by the coronavirus pandemic may mean that CCS CARE RECRUITMENT LTD will not be able to publish the statement within the usual timeframe. Where CCS CARE RECRUITMENT LTD needs to delay the publication of the modern slavery statement by up to 6 months due to coronavirus-related pressures, CCS CARE RECRUITMENT LTD understands that we will not be penalised. In the statement, CCS CARE RECRUITMENT LTD will state the reason for any delay.

Recruitment risks during COVID-19

Some suppliers may be seeking to recruit additional workers in order to meet increases in demand. CCS CARE RECRUITMENT LTD will ensure that rigorous recruitment checks are maintained and that suppliers adhere to the same robust processes to ensure that vulnerable workers are not being exploited by third parties seeking to profit from heightened demand.

The Health and Safety of Workers

As a responsible organisation, it is important that the relevant local or national government policies are implemented throughout the supply chain at CCS CARE RECRUITMENT LTD. CCS CARE RECRUITMENT LTD will ensure that suppliers adopt social distancing measures and pay statutory sick pay in order to prevent the spread of coronavirus as part of due diligence processes.

Risk Assessment during COVID-19

CCS CARE RECRUITMENT LTD will undertake a risk assessment of how suppliers are operating during COVID-19 to highlight and help identify where there are risks of Modern Slavery or Human Trafficking occurring. A Template in the QCS Management system will be used where appropriate.

Review of Effectiveness

CCS CARE RECRUITMENT LTD intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers. We will also continue to:

  • Support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working in Care can have in keeping present and potential future victims of modern slavery and human trafficking safe
  • Gain assurance that all staff at CCS CARE RECRUITMENT LTD have access to training on how to identify victims of modern slavery and human trafficking
  • Review the Safeguarding Policy and Procedure at CCS CARE RECRUITMENT LTD to ensure that Modern Slavery and Human Trafficking are integral within the content and staff are directed to support and advice as needed

Indicators of Forced Labour

  • Individuals may show signs of psychological or physical abuse. They might appear frightened, withdrawn or confused
  • Workers may not have free movement and may always be accompanied
  • Individuals often lack protective equipment or suitable clothing and have not been trained to safely fulfil the requirements of the role
  • The person may not have access to their own documents, such as ID or their passport, with the employer having confiscated them
  • Individuals may not have a contract and may not be paid National Minimum Wage or not paid at all
  • Workers are forced to stay in accommodation provided by the employer. This accommodation could be overcrowded Individuals could live on site
  • Workers could be transported to and from work, potentially with multiple people in one vehicle
  • The person might not accept money or be afraid to accept payment
  • Workers may work particularly long hours

Human Trafficking

  • Human trafficking is defined as the recruitment, transportation, transfer, harbouring or receipt of persons, by means of the threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation
  • It is important not to confuse human trafficking with human smuggling. Human smuggling is also called people smuggling. Human smuggling occurs when an individual seeks the help of a facilitator to enter a country illegally, and the relationship between both parties ends once the transaction ends. Many of those who enter the UK illegally do so by this route. Human smuggling is not a form of modern slavery

Turnover

  • “Turnover” means the amount derived from the provision of goods and services falling within the ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of
    • Trade discounts
    • Value added tax
    • Any other taxes based on the amounts so derived (HM Government – ‘Transparency in Suppy Chains’)

Modern slavery

  • Modern slavery encompasses slavery, human trafficking, forced and compulsory labour and domestic servitude. Traffickers and slave masters use whatever means they have at their disposal to coerce, deceive and force individuals into a life of abuse, servitude and inhumane treatment
  • A large number of active organised crime groups are involved in modern slavery. But it is also committed by individual opportunistic perpetrators
  • There are many different characteristics that distinguish slavery from other human rights violations, however only one needs to be present for slavery to exist

Exploitation (Modern Slavery and Human Trafficking)

  • Sexual Exploitation – forced sex work or working in the commercial sex industry (pornography, lap dancing, telephone lines etc.); those manipulated or coerced into sexual activities of any kind for another person’s gain
  • Modern Slavery – human trafficking; forced labour; domestic servitude; organ harvesting
  • Financial Exploitation – debt bondage; finances controlled by others; financial scams; benefit fraud
  • Criminal Exploitation – those manipulated or coerced or trafficked for the purpose of any illegal activity i.e., County Lines/drug trafficking; cuckooing (taking over of a person’s property); forced street crime (shoplifting, begging etc.); cannabis cultivation
  • Cultural Exploitation – those manipulated or coerced using religious, social or cultural beliefs e.g., FGM, radicalisation, forced marriage

Section 52 Modern Slavery Act

  • This places a duty on Local Authorities to identify and refer modern slavery child victims and consenting adult victims through the National Referral Mechanism (NRM) This responsibility identifies a local authority as a First Responder. The Council as a first responder (FR) into the NRM process has a duty to notify the Home Office if anyone working within the council identifies a person with indicators suggesting they may be trafficked or enslaved

Professionals providing this service should be aware of the following:

  • The Modern Slavery Act 2015 details what organisations need to do about slavery and human trafficking
  • Staff will receive training on Modern Slavery Human Trafficking, and be supported by CCS CARE RECRUITMENT LTD if subject to, or reporting of, cases of slavery or human trafficking
  • Only staff that have been through robust recruitment procedures will be employed at CCS CARE RECRUITMENT LTD
  • If there are cases of slavery or human trafficking then the service will share this information with Kent and Medway Safeguarding Adults Board
  • If slavery or human trafficking is disclosed to you then this must be shared with the Registered Manager or the police if someone is in immediate danger
  • Where applicable, an annual statement on modern slavery and human trafficking will be published by CCS CARE RECRUITMENT LTD on our website and approved by the senior management team e.g. the board of Directors and signed by a Director

 

People affected by this service should be aware of the following:

  • If you are aware of or become part of any acts of modern slavery or human trafficking, this can be reported to CCS CARE RECRUITMENT LTD and the necessary support will be provided
  • You will receive Care from staff who have been through robust recruitment procedures