Modern Slavery Policy
- Introduction
At Lily of the Valley Care, we are committed to providing high-quality, compassionate care to vulnerable individuals in a safe, supportive environment. We have a zero-tolerance approach to modern slavery and human trafficking and are dedicated to preventing these practices within our organisation and supply chains. This policy outlines our commitment to preventing modern slavery and human trafficking, ensuring compliance with the Modern Slavery Act 2015 and safeguarding the rights of those under our care and those working with and for us.
We expect everyone working for us or on our behalf in any capacity, including employees, directors, officers, agency workers, volunteers, contractors, and suppliers, to uphold this policy.
- Policy Statement
Lily of the Valley Care strictly prohibits the use of modern slavery and human trafficking in our operations and supply of care. We are committed to implementing systems and controls to ensure that modern slavery is not present within our organisation or in any part of our supply chain. We require all of our suppliers to adhere to the same high standards and expect them to ensure that their own suppliers also comply with this policy.
- Definitions of Modern Slavery and Human Trafficking
Modern slavery is a term that encompasses a range of criminal activities, including:
- Slavery: A condition where an individual has no control over their own freedom and is coerced into work or services through force, threats, or manipulation.
- Servitude: A person being forced to work under duress, often for no pay or under abusive conditions.
- Forced or Compulsory Labour: Work or services obtained by coercion or threats.
- Bonded Labour: Labour in which the worker is forced to work to repay a debt under abusive or exploitative conditions.
- Child Labour: The exploitation of children through work that deprives them of their childhood, education, and development.
- Human Trafficking: The unlawful transportation, recruitment, or exploitation of individuals through force, fraud, or deception for the purpose of exploitation, including sexual exploitation or forced labour.
Modern slavery is a crime and a violation of fundamental human rights.
- Our Commitments
We are committed to ensuring that modern slavery and human trafficking are not part of any of our operations or supply chains. This includes the following commitments:
- Zero-tolerance approach: We have a zero-tolerance approach to modern slavery within our organisation and our supply chains. All those working for or on behalf of Lily of the Valley Care are expected to support and uphold this policy and to report any concerns.
- Prevention, detection, and reporting: The prevention, detection, and reporting of modern slavery within our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in or facilitate any activity that could suggest or lead to a breach of this policy and must report any suspicions promptly.
- Engagement with stakeholders: We are committed to working closely with our stakeholders, including suppliers and contractors, to assess and address the risk of modern slavery in our operations and supply chains. This includes ongoing engagement to ensure that they uphold our high standards and comply with our expectations.
- Risk-based approach: We take a risk-based approach to our contracting processes. We assess whether specific prohibitions against modern slavery and trafficking should be included in our contracts with third parties. We will also assess whether circumstances warrant writing to suppliers to require them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and human trafficking.
- Third-party compliance: We may require employment and recruitment agencies and other third parties supplying workers to confirm their compliance with our Code of Conduct. In addition, we may require suppliers engaging workers through a third party to obtain that third party’s agreement to adhere to the Code.
- Audits and due diligence: As part of our ongoing risk assessment and due diligence processes, we will consider whether circumstances warrant us carrying out audits of suppliers to ensure their compliance with our Code of Conduct.
- Appropriate action for breaches: If we discover that any individuals or organisations working on our behalf have breached this policy, we will take appropriate action. This may range from remediation efforts for those impacted by the breach to terminating our relationships with any parties involved.
- Recruitment and Employment Practices
Lily of the Valley Care is committed to ensuring that all workers are employed legally, fairly, and without the use of modern slavery practices:
- We will ensure that all employees have the legal right to work in the UK and will not employ anyone who is coerced or exploited.
- We will carry out appropriate background checks to prevent the employment of individuals involved in modern slavery or human trafficking.
- We expect all agencies and third parties that provide workers to us to comply with our anti-slavery and human trafficking policy.
- Reporting and Whistleblowing Procedures
The directors of Lily of the Valley Care Ltd have the overall responsibility for ensuring that this policy adheres to the company’s legal and ethical obligations.
Leena Ghoorah, the Care Manager, is tasked with the daily implementation of this policy, overseeing its usage and effectiveness, and conducting audits of internal controls, policies, and procedures to prevent the risk of modern slavery
We encourage employees, contractors, and anyone working with us to report any concerns regarding modern slavery or human trafficking. All concerns will be treated seriously, confidentially, and investigated thoroughly. Employees can report concerns through the following channels:
- Directly to their line manager or senior staff member.
- By using the confidential whistleblowing procedure leena.ghoorah@lilyofthevalleycare.co.uk
We guarantee that there will be no retaliation against anyone who reports a concern in good faith.
- Support for Victims
If modern slavery or human trafficking is suspected or identified, Lily of the Valley Care will take immediate steps to ensure the safety and well-being of the victims. This may include:
- Contacting the relevant authorities, such as the police or the National Crime Agency.
- Providing support and assistance to the victims, including working with social services and other support agencies to ensure that victims are protected.
- Supply Chain Management
We expect all our suppliers, contractors, and partners to comply with our anti-slavery policy. We will:
- Conduct due diligence to assess the risks of modern slavery in our supply chain.
- Require suppliers to comply with our Code of Conduct, which sets out the standards expected to combat modern slavery and trafficking.
- Regularly review and audit our suppliers to ensure compliance with our policies.
- Monitoring and Review
This policy will be reviewed annually to ensure it remains effective and up to date. The review will include:
- Assessing the effectiveness of training and awareness programmes.
- Reviewing reports of suspected modern slavery or human trafficking.
- Ensuring that the policy is compliant with current laws and best practices.
We are committed to continuously improving our approach to preventing modern slavery and human trafficking.
- Consequences of Non-Compliance
Any employee, contractor, or supplier found to be involved in modern slavery or human trafficking will face disciplinary action. This may include dismissal or termination of contracts, and legal action where appropriate. We are committed to working with law enforcement to ensure that those involved are held accountable.
- Conclusion
Lily of the Valley Care is dedicated to preventing modern slavery and human trafficking within its operations and supply chains. We are committed to upholding the highest standards of care and ethics, guaranteeing that all individuals in our care, as well as our employees, are free from exploitation.