Modern Slavery and Human Trafficking Policy and Procedure

Modern Slavery and Human Trafficking Policy and Procedure

Procedure

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. LIFELINE CARERS PVT 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 or client who requires additional help with day to day general routine activities, as a victim or perpetrator, or a Service User or client who requires additional help with day to day general routine activities, 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 Miss Lynn Barlow immediately.
4. Miss Lynn Barlow contacts and escalates the concern immediately to Preston City 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 LIFELINE CARERS PVT 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. LIFELINE CARERS PVT LTD will follow PR16 - Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times.

LIFELINE CARERS PVT 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:

1. Individuals not being paid for the work they undertake
2. Individuals being held in debt-bondage (being told they “still” owe money after having paid off a previous debt).
3. An individual’s passport being held by their “employer” in order to keep the individual at work.
4. Multiple benefit claimants having their benefits being paid into the same account.
5. An individual not having the freedom of movement (i.e. passport being taken).
6. Clear exploitation of an individual by another for financial or sexual gain.
7. Shows signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated injuries.
8. 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.
9. Relationships which do not seem right - for example, a young teenager appearing to be the boyfriend/girlfriend of a much older adult.
10. Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address.
11. 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.
12. Have little opportunity to move freely and may have had their travel documents retained, e.g. passports
13. Be dropped off/collected for work on a regular basis either very early or late at night
14. 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.
15. 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 LIFELINE CARERS PVT LTD or the polic

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 LIFELINE CARERS PVT 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, LIFELINE CARERS PVT LTD will consider how fluctuations in demand and changes in the operating model may lead to new or increased risks of labour exploitation.

If LIFELINE CARERS PVT LTD needs to delay the Modern Slavery statement

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

Recruitment Risks

Some suppliers may be seeking to recruit additional workers in order to meet increases in demand. LIFELINE CARERS PVT 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 LIFELINE CARERS PVT LTD.

Risk Assessment

LIFELINE CARERS PVT LTD will undertake a risk assessment of how suppliers are operating to highlight and help identify where there are risks of Modern Slavery or Human Trafficking occurring. A template available in the QCS Management system will be used where appropriate.

Review of Effectiveness

LIFELINE CARERS PVT 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:

1. 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
2. Gain assurance that all staff at LIFELINE CARERS PVT LTD have access to training on how to identify victims of modern slavery and human trafficking
3. Review the Safeguarding Adults Policy and Procedure at LIFELINE CARERS PVT 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

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

Definitions

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

Human Trafficking

1. 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
2. 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

1. Trade discounts
2. Value added tax
3. Any other taxes based on the amounts so derived (HM Government - 'Transparency in Suppy Chains')

Modern slavery

1. 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.
2. A large number of active organised crime groups are involved in modern slavery. But it is also committed by individual opportunistic perpetrators.
3. 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)

1. 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.
2. Modern Slavery – human trafficking; forced labour; domestic servitude; organ harvesting.
3. Financial Exploitation – debt bondage; finances controlled by others; financial scams; benefit fraud.
4. 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
5. Cultural Exploitation – those manipulated or coerced using religious, social or cultural beliefs e.g., FGM, radicalisation, forced marriag

Key Facts - Professionals

Professionals providing this service should be aware of the following:

1. Where applicable, an annual statement on modern slavery and human trafficking will be published by LIFELINE CARERS PVT LTD on our website and approved by the senior management team e.g. the board of Directors and signed by a Director.
2. Staff will receive training on Modern Slavery Human Trafficking, and be supported by LIFELINE CARERS PVT LTD if subject to, or reporting of, cases of slavery or human trafficking.
3. Only staff that have been through robust recruitment procedures will be employed at LIFELINE CARERS PVT LTD.
4. The Modern Slavery Act 2015 details what organisations need to do about slavery and human trafficking.
5. 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.
6. If there are cases of slavery or human trafficking then the service will share this information with Lancashire County Council Social Services, Preston PR2-1TB.

Key Facts - People affected by the service

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

1. If you are aware of or become part of any acts of modern slavery or human trafficking, this can be reported to LIFELINE CARERS PVT LTD and the necessary support will be provided.
2. You will receive Care from staff who have been through robust recruitment procedures.