Modern Slavery & Human Trafficking Policy

What does a modern slavery policy do in care?

A modern slavery policy sets out how a care service prevents, spots and reports modern slavery and human trafficking. It reaches the people you support, your staff and your suppliers. The statutory safeguarding guidance lists modern slavery as a type of abuse, and the Modern Slavery Act 2015 makes slavery, servitude, forced labour and human trafficking crimes.

The template is written for care homes, home care and supported living. Care homes watch contracted services such as cleaning, laundry and catering. Home care staff may see who lives or works in a person's home. In supported living, exploiters may target a tenant at home.

Signs staff look for

Victims may stay silent. Some do not come forward, and some do not see themselves as victims at all, so the template lists the general signs from the Home Office statutory guidance, including people who:

• cannot leave their work or home, or seem to have their movements controlled

• do not hold their own passport or identity documents

• let others speak for them

• get little or no pay, or work very long hours with no days off

• believe they are bound by a debt

Not all of these will be present in each case. Signs of domestic servitude include living with a family but not eating with them, having no private space and rarely leaving the house.

How a concern is reported

If anyone is in immediate danger, staff call 999. Otherwise they tell the manager or modern slavery lead straight away and never alert the suspected exploiter or try to investigate themselves. The manager makes a safeguarding referral if the person has care and support needs, reports to the police, and tells CQC where the notification rules apply.

The National Referral Mechanism is the process for finding and supporting possible victims. Staff who are not First Responders, the organisations that can refer someone into it, work with one to make a referral.

Recruitment matters too. Right to work checks happen before anyone starts, and staff keep their own identity documents.

Before you issue it

Add your local police and safeguarding contacts, plus the national reporting contacts checked on GOV.UK. List the agencies and suppliers you use. Then check whether your organisation must publish an annual modern slavery statement. That depends on turnover, and the threshold sits in regulations, outside the Act itself.

Concerns about a person you support go through the Safeguarding Policy & Procedure. Log each check on the Right to Work Verification Record. Staff worried about a colleague can use the Whistleblowing & Speak Up Policy.