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Anti-Slavery Policy

Modern Slavery Statement


Introduction

This statement sets out Service Care Solution’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 01st April 2019 to 31st March 2020.

We recognise that we are publishing this statement later than expected. This is because of reduced staff capacity/increased difficulty in gathering the required information from our suppliers during the coronavirus pandemic. As part of the Health and Social Care, Construction, Social Housing, Criminal Justice, Legal, Finance and Sales and Customer Service sectors, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously during the coronavirus pandemic.

Our organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

Organisational structure and supply chains

This statement covers the activities of Service Care Solutions Limited:

Service Care Solutions are an Employment Business, Employment Agency that has been operating since 2005. We recruit into many sectors including, Health and Social Care, Construction, Social Housing, Criminal Justice, Legal, Finance, Sales and Customer Service both the private and public sector.

We currently operate in the following countries:

United Kingdom

As part of our continuing commitment to the highest standards, Service Care Solutions are members of the following regulatory bodies:

  • Recruitment & Employment Confederation (REC) - SCS are subject to a voluntary audit from the REC on a regular basis to ensure our regulatory standards are maintained. 
  • The Association of Professional Staffing Companies (APSCO) 

Our Process for managing risk

We have appropriate Modern Slavery policies and a due diligence programme based on risk assessment and follow up. We encourage transparency throughout our supply chain and deliver appropriate training to colleagues to help raise awareness and knowledge. We continuously review and aim to improve upon our policies to ensure they are fit for purpose. These policies are agreed and signed by the Managing Director.

The manifestations of Modern Slavery are complex and hidden; therefore, Service Care Solutions engage a risk assessment which includes the following: detailed mapping of supply chains, desk based research, supplier surveys, supplier engagement, and discussions with expert stakeholders.

When engaging with suppliers we seek evidence, via audit, that they have appropriate policies and procedures, including Modern Slavery, Human trafficking, forced labour, human rights and whistle-blowing. We do not currently engage with any international suppliers.

Once the initial audit is complete and Service Care Solutions are satisfied with the outcome, the supplier may be added to our preferred supplier list. This preferred supplier list is subject to re-audit on an annual basis or should such concerns arise and come to our attention that would warrant one.

In 2019/2020, Service Care Solutions did not identify any High Risk activities within its supply chain.

Responsibility

Responsibility for our anti-slavery initiatives is as follows:

  • Policies: Must be signed by a Director. Updated on an annual basis or subject to legislative changes to ensure policies remain current. 
  • Risk assessments: Conducted by our Finance Team and signed by a Director. 
  • Investigations/due diligence: The finance team conduct all audits of suppliers as part of our due diligence. This is then reviewed and authorised by a Director. 
  • Training: Annual Internal training takes place with colleagues to raise awareness on the potential signs of modern slavery in line with key indicators which should be escalated to senior management immediately. 
Relevant policies

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

  • Whistleblowing policy: We encourage all our workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees who have concerns can use our internal anonymous portal. Customers or others who have concerns can contact us through the usual methods or write to us if they wish to remain anonymous. 
  • Employee code of conduct: Our code makes clear to employees the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain. 
  • Agency workers policy: We use only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency. This is done in line with our process for managing risk identified above.
Due diligence

We undertake due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. Our due diligence and reviews include:
  • Mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking; 
  • Evaluating the modern slavery and human trafficking risks of each new supplier [this may be part of a more general human rights or labour rights assessment]; 
  • Reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;  conducting supplier audits or assessments through our Finance team, which have a greater degree of focus on slavery and human trafficking where general risks are identified; 
  • Taking steps to improve substandard suppliers' practices, including providing advice to suppliers through our Finance team, and requiring them to implement action plans. 
  • Using lists of suppliers approved by appropriate governing bodies, where suppliers can be checked for their labour standards, compliance in general, and modern slavery and human trafficking in particular; and 
  • Invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.
Performance indicators

We have reviewed our key performance indicators (KPIs). As a result, we are: requiring all staff to have renewed training on modern slavery by 31/03/2021 and ontinuing to develop a robust process for due diligence checks whereby we evaluate potential suppliers before they enter the supply chain by 31/03/2021; and reviewing its existing supply chains whereby we evaluate all existing suppliers by 31/03/2021.

Training

We require all staff within our organisation to complete training on modern slavery as a module within our wider human rights/ethics/ethical trade training programme. We require all staff to sign up to one of a number of training sessions that are being run and complete an online training course by 31/03/2021.

Our modern slavery training covers:
  • our business's purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country's national minimum wage, or the provision of products by an unrealistic deadline; 
  • how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available; • how to identify the signs of slavery and human trafficking; 
  • what initial steps should be taken if slavery or human trafficking is suspected; 
  • how to escalate potential slavery or human trafficking issues to the relevant parties within our organisation; 
  • what external help is available, for example through the Modern Slavery Helpline, Gangmasters and Labour Abuse Authority and "Stronger together" initiative; 
  • what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and 
  • what steps our organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from our supply chains. 
Awareness-raising programme

As well as training staff, we have raised awareness of modern slavery issues by posting our modern slavery statement on our website and having modern slavery awareness posters on the notice board in the office.

The posters explain to staff:
  • the basic principles of the Modern Slavery Act 2015; 
  • how employers can identify and prevent slavery and human trafficking; 
  • what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within our organisation; and 
  • what external help is available, for example through the Modern Slavery Helpline. 
Board approval

This statement was approved on 26th February 2021 by our Managing Director who review and update it annually.
Director's signature:
Richard Freye
Date: 26th February 2021