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1. Policy Statement

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This statement and policy describes the values, principles and procedures that underpin The Right Healthcare Services Ltd's (RHS) approach to preventing modern slavery, human trafficking, forced labour, servitude and exploitation. It applies to the company's care services, employment practices, recruitment arrangements, contractors, suppliers and all other organisations with which it has dealings.

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It reflects the safeguarding duties under the Care Act 2014 and the aims of the Modern Slavery Act 2015. RHS has zero tolerance for modern slavery and will alert the police, local authority safeguarding services or other responsible authorities where concerns or evidence arise.

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RHS understands that an organisation with annual turnover below the statutory threshold may not be required to publish a statement under section 54 of the Modern Slavery Act 2015. The company nevertheless issues this document voluntarily to demonstrate its commitment to ethical care delivery, fair employment and responsible procurement.

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Modern slavery includes forced or compulsory labour, domestic servitude, debt bondage, human trafficking and activities in which a person is coerced, controlled, deceived or exploited to undertake work or services to which they have not freely consented.

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2. The Organisation's Structure, Business and Supply Chains

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The Right Healthcare Services Ltd is a private limited company registered in England and Wales and is registered with the Care Quality Commission to provide the regulated activity of personal care. The organisation is led by its Director and Registered Manager, Cynthia Arovo, and supported by a Deputy Manager, care, administrative and management staff. It provides person-centred care and support to adults in their own homes and community settings.

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The company's main supply chains include recruitment and temporary staffing agencies; training providers (including Your Hippo); personal protective equipment, uniforms and care consumables; office and IT equipment; software and telecommunications, including the OnCare electronic care management and call monitoring system; cleaning, waste, maintenance and transport services; and professional services. Suppliers may have their own subcontractors or overseas manufacturing chains. RHS therefore applies proportionate checks according to the type, location, labour arrangements and complexity of each supply chain.

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RHS holds a Home Office Sponsorship Licence (Class A), enabling it to sponsor skilled workers where a genuine need for additional workforce capacity arises. The company's recruitment strategy prioritises local recruitment, with sponsored international recruitment used only as a supplementary measure to support service capacity, ensuring the workforce does not become over-reliant on sponsored labour.

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3. Policies Relating to Modern Slavery and Human Trafficking

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This document is supported by RHS's safeguarding, safer recruitment, right-to-work, whistleblowing, equality and diversity, disciplinary, complaints, procurement and staff conduct arrangements. Together, these controls are intended to protect people who use the service, employees, applicants, agency workers and people working within the supply chain.

All workers are expected to report concerns promptly. A person who raises a genuine concern will be protected from victimisation or retaliation under the company's whistleblowing arrangements.

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4. Due Diligence Processes

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RHS applies reasonable and proportionate due diligence before appointing staff, agencies, contractors or suppliers and during the relationship. This includes, where relevant:

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• checking identity, right to work, employment history, references and required background checks (including DBS) before employment;

• providing clear written terms, lawful pay and deductions, and ensuring workers retain control of their passports, identity documents and personal bank accounts;

• prohibiting recruitment fees, deposits, debt arrangements or other practices that could bind a worker to an employer or recruiter, including in respect of any staff recruited under the company's Sponsorship Licence;

• checking recruitment agencies, including their licence or registration where applicable, worker-charging practices and contractual terms;

• asking higher-risk or key suppliers to confirm their approach to modern slavery, provide relevant policies or statements and explain checks within their own supply chains;

• including appropriate modern-slavery expectations in purchasing decisions, contracts and supplier reviews; and

• investigating concerns, requiring corrective action and, where necessary, suspending or ending a relationship and reporting the matter to the appropriate authority.

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5. Risk Assessment and Management

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The company recognises that modern-slavery risk may be higher in international recruitment, including recruitment under its Sponsorship Licence; agency and temporary labour; labour-intensive outsourced services; low-cost or overseas-manufactured uniforms, PPE, electronics and consumables; complex subcontracting arrangements; and situations in which an adult receiving care is controlled, financially exploited, criminally exploited or trafficked by another person.

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Risks will be considered when workers and suppliers are appointed, when contracts are reviewed, following concerns or changes in circumstances, and as part of the annual policy review. The Registered Manager or delegated lead will record significant risks and actions, obtain further assurance where needed, monitor corrective actions and escalate unresolved or serious concerns to senior management, commissioners, safeguarding authorities or the police.

6. Service Users

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RHS will seek to ensure that no adult receiving care or support is subjected to modern slavery, exploitation or forced labour. Staff will remain alert to indicators such as fearfulness, restricted movement, control of money or documents, unexplained injuries, another person speaking on the individual's behalf, poor living conditions or signs of criminal or sexual exploitation.

Where there is suspicion, information or evidence that a person is a victim of, or at risk of, modern slavery, the service will take immediate protective action, follow safeguarding procedures and contact the appropriate local authority or police. Immediate danger or a crime in progress must be reported through 999.

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7. Staff

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RHS will not employ staff under conditions that amount to modern slavery or exploitation. Recruitment procedures will comply with employment law, right-to-work requirements and regulatory expectations, and pay and conditions will meet statutory requirements.

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RHS's workforce is built primarily on local recruitment, supplemented where necessary by staff recruited under the company's Home Office Sponsorship Licence. Sponsored workers are subject to the same right-to-work, contractual and welfare safeguards as all other staff, and are never charged recruitment fees or required to surrender identity documents.

If there is evidence that an employee is being exploited or subjected to forced labour by a third party, the company will exercise its duty of care, support the employee and report the concern where appropriate. The employee will not be penalised for disclosing exploitation where they have been recruited lawfully and are meeting their employment obligations.

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8. Contractors and Suppliers

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RHS expects contractors and suppliers to maintain a zero-tolerance and due-diligence approach to modern slavery and human trafficking. Suppliers must take reasonable steps to prevent forced labour and exploitation within their own operations and supply chains and must cooperate with proportionate information requests or investigations.

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Staff responsible for procurement must report any concern at the earliest opportunity. Serious non-compliance may result in corrective-action requirements, suspension, termination of the relationship or referral to the relevant authority.

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9. Effectiveness and Performance Indicators

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RHS will assess the effectiveness of this policy through management review and the following proportionate performance indicators:

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• percentage of employees completing modern-slavery and safeguarding awareness training at induction and refresher intervals;

• percentage of recruitment files containing completed identity, right-to-work, reference, contract and pay checks;

• percentage of new higher-risk agencies and suppliers completing proportionate modern-slavery due diligence before appointment;

• number of concerns, disclosures, safeguarding referrals, supplier issues and corrective actions recorded, with actions tracked to closure;

• completion of an annual review of modern-slavery risks, suppliers and this statement; and

• evidence that no worker recruitment fees, unlawful deductions or retention of identity documents have been identified or tolerated, including in respect of staff recruited under the company's Sponsorship Licence.
   

The Registered Manager will review the results at least annually. Identified gaps will lead to additional checks, training, supplier engagement or changes to recruitment and procurement controls.

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10. Training and Capacity Building

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All staff will be introduced to this policy and trained to recognise and report signs of modern slavery affecting people who use the service or members of the workforce. Refresher information will be provided periodically and when risks, legislation or guidance change.

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Managers and staff responsible for recruitment, rostering, safeguarding or procurement will receive additional guidance on ethical recruitment, recruitment-fee risks, document retention, coercion, supplier due diligence, responding to disclosures and referral to safeguarding or law-enforcement bodies.

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11. Review, Approval and Publication

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This statement and policy will be reviewed annually, or sooner following a serious concern or material change in legislation, guidance, commissioning requirements, business activities or supply-chain risk. The approved version may be made available to staff, commissioners, contracting authorities, service users, representatives, suppliers and other interested parties.

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