Modern Slavery Act
Last updated: March 2023
We are committed to working practices that maintain high standards throughout our dealings with employees, customers, and suppliers, conducting every aspect of our business with inclusivity, honesty, integrity and openness. Our Modern Slavery Act details how we are committed to these values and the general abolishment of modern slavery.
- Risk Assessment
- Due Diligence
- Contractors and Suppliers
- Training and Communication
- Compliance with this policy
- Breaches of this policy
- Policy Administration
1.1. The Board of Directors of Trinity Homecare and its subsidiary companies (collectively referred to as “Trinity Homecare Group”) are committed to ensuring that an effective anti-slavery and anti-human trafficking policy and related procedures operate throughout the Trinity Homecare Group to ensure compliance with the Modern Slavery Act 2015.
1.2 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced and compulsory labour and human trafficking all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. Trinity Homecare Group is committed to carrying on its business operations responsibly with a zero-tolerance approach to any of the forms of modern slavery which are proven to have taken place. Trinity Homecare Group is committed to acting ethically and with integrity in all business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure modern slavery does not take place in its own business or in any of its supply chains.
1.3 Trinity Homecare Group is also committed to ensuring transparency in its business and in its approach to tackling .Modern Slavery throughout its supply chains, consistent with the disclosure obligations under the Modern Slavery Act 2015. Trinity Homecare Group expect the same high standards from all contractors, suppliers and other business partners and, as part of its contracting processes, we include specific .prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and Trinity Homecare Group expect its suppliers to hold their own suppliers to the same high standards.
2.1 The purpose of this policy is to:-
(a) Set out our responsibilities, and of those working for and on our behalf in observing and upholding our position on modern slavery and human trafficking; and
(b) Provide information to those working for and on our behalf on how to identify and report concerns regarding modern slavery and human trafficking.
2.2 This Policy applies to all persons working for or on the behalf of Trinity Homecare Group including employers at all levels, directors, non-executive directors, officers, employees, contractors, temporary employees, workers, agency workers, seconded workers, interns, volunteers, agents, external consultants, and any third-party suppliers and business partners working for or engaged by Trinity Homecare Group.
2.3 Trinity Homecare Group is committed to upholding the law of the UK and in particular for this Policy, the Modern Slavery Act 2015, which came into force on 29 October 2015. Slavery and human trafficking are a crime and a violation of fundamental human rights. The Modern Slavery Act creates various offences, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain.
2.4 Importantly, these offences have extra territorial application as they apply to acts done anywhere in the world and not just the UK.
2.5 The maximum penalty for individuals who commit slavery and human trafficking offences is life imprisonment.
2.6 This policy does not form part of any employee’s contract of employment, and we may amend it at any time.
3.1 Assessing the potential for slavery and human trafficking in each operating company is key. Whilst each business must assess the risk in the context of its own activities, particular focus will be given to destination markets where perceived levels of slavery and human trafficking are high with an absence of effective anti-slavery legislation.
3.2 Legal, Internal Audit and Risk are available to help assess the risk and will, as part of the internal audit programme, be charged with checking each business’ degree of compliance with this Policy.
3.3 Following an initial risk assessment, further risk assessments will be carried out on existing suppliers every three years to assess the potential for any residing risk.
3.4 It is important to ensure that the Whistleblowing policy is read and understood in the context of this Policy.
4.1 Each operating company within Trinity Homecare Group shall conduct effective due diligence on high-risk suppliers, as identified by Trinity Homecare Group’s slavery and human trafficking risk assessment.
4.2 Where a Trinity Homecare Group company controls a joint venture or consortium, this Policy shall apply to the affairs of that entity. Where a Trinity Homecare Group company does not have effective control, then this Policy will be made known to the controlling party which will be encouraged to adopt a consistent policy.
4.3 In respect of potential acquisitions, thorough due diligence should be undertaken on the target’s shareholders, directors, officers, and senior management and its business practices to ensure no slavery and human trafficking practices exist.
4.4 Additional rigour will be applied when the target company is located in, or closely associated with a country where slavery or human trafficking is generally regarded as common place.
5.1 Each Trinity Homecare Group company shall conduct its procurement processes in a fair, honest, and transparent manner.
5.2 No Trinity Homecare Group company will knowingly deal with contractors and suppliers who have been convicted of slavery or human trafficking offences.
5.3 All new agreements with contractors and suppliers must be in writing and will contractually oblige the contractor and supplier to comply with the Modern Slavery Act. Where possible, each agreement shall give the relevant Trinity Homecare Group company concerned a right of termination, If the contractor or supplier is proven to have committed slavery or human trafficking offences or to have acted in a manner inconsistent with the Modern Slavery Act.
6.1 . Training on this policy and on the risk our business faces from modern slavery in its supply chains forms part of the induction process for all individuals who work for us, and regular training will be provided, as necessary.
6.2 Trinity Homecare Group’s zero-tolerance approach to slavery and human trafficking must be communicated to all suppliers, contractors, and business partners at the outset of the business relationship with them and reinforced as appropriate on an ongoing basis.
7.1 You must ensure that you read, understand, and comply with this policy
7.2 The prevention, detection and reporting of modern slavery in any part of Trinity Homecare Group’s business or supply chains is the responsibility of all those working for Trinity Homecare Group or under Trinity Homecare Group’s control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this Policy.
7.3 The success of this Policy is dependent upon employees and others raising concerns and reporting breaches or suspected breaches of this policy, or if they think a breach may occur in the future, to their manager as soon as possible . Accordingly, all employees are encouraged to make use of the confidential and anonymous “Whistleblowing” telephone facility which can be used to report concerns or violations.
7.4 You are encouraged to raise concerns about any issues or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or through the Whistleblowing telephone facility.
7.5 All incidents of modern slavery discovered or reported will be investigated in a prompt, consistent and appropriate manner. Trinity Homecare Group will always endeavour to maintain confidentiality as far as is reasonably practicable but once an investigation commences it may be possible for others to guess the identity of the person who has raised the issue. Any anonymous disclosures will not be ignored.
7.6 The results of all such investigations will be reported to the Board of the relevant Trinity Homecare Group company. Compliance & Quality will periodically report to the Risk Committee on the application of this Policy and continually seek to improve its effectiveness.
7.7 Where appropriate, and with the welfare and safety of local workers as a priority, Trinity Homecare Group will give support and guidance to its suppliers to help them address coercive abusive and exploitative work practices in their own business and supply chains.
7.8 Trinity Homecare Group aims to encourage openness and will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. Trinity Homecare Group is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of Trinity Homecare Group’s own business or in any of its supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe you have suffered such treatment, you should inform HR immediately. If the matter is not remedied, and you are an employee you should raise it formally using our Grievance Policy.
8.1 Any employee who breaches this Policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
8.2 Trinity Homecare Group may terminate its relationship with other individuals and organisations working on its behalf if they breach this Policy.
9.1 The board of directors have overall responsibility for ensuring this policy complies with our legal and ethical obligations , and that all those under our control comply with it.
9.2 The Group Compliance Manager has primary day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. .
9.3 This Policy will be reviewed annually and revised as necessary.
9.4 You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Group Compliance Manager.
9.5 Any exceptions and/or variations to this Policy must be approved in writing by the Trinity Homecare Group Risk Committee. Material changes must be approved by the Board of Trinity Homecare.