Modern Slavery Statement

This policy will support staff’s understanding of modern slavery and human trafficking. It has been reviewed with minor updates made to sections 5.7, 5.8 and 5.9 only.

  1. Purpose
  • The Purpose is to ensure that everyone at Hire Stone Recruitment Ltd is aware of Modern Slavery and Human Trafficking Policy and Procedure and the procedures in place to identify, respond appropriately and report in line with local and the national guidance. This policy refers to adults who may be at risk, the procedure for children is detailed in the Safeguarding Children and Child Protection Policy and Procedure.
  • This policy works together with the Safeguarding Adults Policy and Procedure. Hire Stone Recruitment Ltd will ensure that staff understand the safeguarding reporting procedures and that these procedures are communicated to all staff. Other policies that relate to Modern Slavery and Human Trafficking include but are not limited to Raising concerns, Freedom to Speak Up and Whistleblowing Policy and Procedure, Safeguarding Children and Child Protection Policy and Procedure, the Recruitment Policy and Procedure, the Right to Work Checks Policy and Procedure and the Agency Staff Policy and Procedure.
  • To support Hire Stone Recruitment in meeting the following Key Lines of Enquiry/Quality Statements: SAFE ( how do systems, processes and practices keep people safe and safeguarded from abuse), WELL-LED (is there a clear vision and credible strategy to deliver high-quality care and support, and promote a positive culture that is person-centred, open, inclusive and empowering which achieves good outcomes for porple), WELL-LED (does the governance framework ensure that responsibilities are clear and that quality performance, risks and regulatory requirements are understood and managed).
  • To meet the legal requirements of the regulated activities that Hire Stone Recruitment Ltd complies with The Modern Slavery Act 2015, Health and Safety at Work etc. Act 1974, Human Rights Act 1998, The Health and Social Care Act 2008.
  1. Scope
  • The following roles may be affected by this policy: all staff, Registered Manager and other management.
  • The following Service Users may be affected by this policy: Service Users.
  • The following stakeholders may be affected by this policy: Commissioners, Local Authority.
  1. Objectives
  • To promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of Hire Stone Recruitment Ltd in addressing slavery and human trafficking in all its forms. An annual statement will be produced, where applicable.
  • To ensure that identification, protection, care and support for victims of modern slavery and human trafficking is at the heart of our safeguarding procedures at Hire Stone Recruitment Ltd.
  1. Policy
  • 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 include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.
  • Hire Stone Recruitment Ltd has a zero-tolerance approach to modern slavery within the business and supply chains and we are committed to acting ethically and with integrity in all our dealings and relationships. We will implement and enforce effective systems and controls to ensure that modern slavery is not taking place anywhere in Hire Stone Recruitment Ltd or within any third parties that we are associated with.
  • All staff will be made aware of the issues surrounding slavery and human trafficking, whilst being encouraged and supported to report any concerns to Hire Stone Recruitment Ltd management. Hire Stone Recruitment Ltd will also support any staff that may be subject to slavery or human trafficking.
  • Where modern slavery or human trafficking is identified, hire Stone Recruitment Ltd will share information with the relevant local safeguarding team to safeguard the individual from harm and with the objective of preventing future situations arising, to promote the elimination of routes and sources of slavery or human trafficking.
  • All line managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the day-to-day performance of their roles.
  • All employees who suspect any members of the workplace of being victim of modern slavery must notify their line manager.
  • Hire Stone Recruitment Ltd will take steps to ensure that sufficient communication and employee awareness training is undertaken with regards to Modern Slavery.
  • All employees will be made aware of Whistleblowing Policy and Procedure at Hire Stone Recruitment Ltd. The purpose of this policy and associated procedure is to enable Hire Stone Recruitment Ltd to thoroughly investigate allegations of any wrongdoing raised by employees within Hire Stone Recruitment Ltd without fear of reprisal.
  • Hire Stone Recruitment will use this policy to underpin and inform any statement on slavery and human trafficking that we may be required to produce meet the requirements of Section 54 of the Modern Slavery Act 2015 (MSA).
  1. 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. Hire Stone Recruitment Ltd must ensure that the staff are aware that victims of modern slavery or trafficking will often not self-identify. Many will present with a different issue.

  • A concern is identified – This could be a service user as a victim or perpetrator, or a Service User informs us of a concern they have.
  • If an individual is, or group of people are, in immediate risk of danger or harm, the police must be immediately notified on 999.
  • The staff member must discuss this with their line manager (where appropriate) immediately.
  • The manager contacts and escalates the concern immediately to the local Safeguarding Adults Team.
    • Safer Recruitment

All staff engaged with providing services at Hire Stone Recruitment 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. Hire Stone Recruitment Ltd will follow Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times.

  • Hire Stone Recruitment Ltd will only use staff that are registered with a regulator and can make proof of their right to work in the UK and meet all the requirements for the role being provided for.
  • 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:
  • Individuals not being paid for the work they undertake
  • Individuals being held in debt-bondage (being told they still owe money after they have paid off a debt)
  • An individual’s passport being held by their “employer” in order to keep the individual at work
  • Multiple benefit claimants having their benefits being paid into the same account
  • An individual not having freedom of movement (i.e. passport being taken)
  • Clear exploitation of an individual by another for financial or sexual gain
  • Shows signs of physical or psychological abuse, look malnourished or unkept, anxious/agitated or appear withdrawn and neglected; they might have untreated injuries
  • 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
  • Relationships which do not seem right – for example, a young teenager appearing to be the boyfriend/girlfriend of a much older adult
  • Be living in dirty, cramped or overcrowded accommodation, and/or living and working at the same address
  • Have no identification documents, have few personal possessions and always wear the same clothes day in and day out. The clothes they wear may not be suitable for their work
  • Have little opportunity to move freely and may have had their travel documents retained, e.g. passports
  • Be dropped off/collected for work on a regular basis either very early or late at night
  • 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
  • Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforces 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 Director of Hire Stone Recruitment Ltd or the police.
    • Recruitment risk. Hire Stone Recruitment Ltd may need to recruit additional workers in order to meet increase in demand. Hire Stone Recruitment Ltd will ensure that rigorous recruitment checks are maintained to ensure that vulnerable workers are not being exploited by third parties seeking to profit from heightened demand.
    • The Health and Safety Workers. As a responsible organisation, it is important that the relevant local or national government policies are implemented throughout Hire Stone Recruitment Ltd.
    • Risk Assessment. Hire Stone Recruitment Ltd will undertake a risk assessment of how contractors are operating to highlight and help identify where there are risks of Modern Slavery or Human Trafficking occurring.
    • Review of Effectiveness. Hire Stone Recruitment Ltd intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking. We will continue to:
  • Support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working with us can have in keeping present and potential future victims of modern slavery and human trafficking safe
  • Gain assurance that all staff at Hire Stone Recruitment Ltd have access to training on how to identify victims of modern slavery and human trafficking
  • Review the Safeguarding Adults Policy and Procedures at Hire Stone Recruitment 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
  • Individuals may show signs of psychological or physical abuse. They might appear frightened, withdrawn or confused
  • Workers may not have free movement and they may always be accompanied
  • Individuals often lack protective equipment or suitable clothing and have not been trained to safely fulfil the requirements of the role
  • The person may not have access to their own documents, such as ID or their passport, with the employer having confiscated them
  • Individuals may not have a contract and may not be paid National Minimum Wage or not paid at all
  • Workers are forced to stay in accommodation provided by the employer. This accommodation could be overcrowded.
  • Individuals could live on site.
  • Workers could be transported to and from work, potentially with multiple people in one vehicle.
  • The person might not accept money or be afraid to accept payment.
  • Workers may work particularly long hours.
  1. 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.
  • Human trafficking is defined as recruiting, transportation, transfer, harbouring of receipt of persons, by means of the threat or use of force or other form 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
  • 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 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 means the amount derived from the provision of goods and services falling withing the ordinary activities of the commercial organisation or subsidiary undertaking, after deduction of trade discounts, VAT, any other taxes based on the amounts derived (HM Government – Transparency in Supply Chains)
    • Modern slavery. 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. A large number of active organised crime groups are involved in modern slavery. But it is also committed by individual opportunistic perpetrators. 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). 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. Modern slavery – human trafficking; forced labour; domestic servitude; organ harvesting. Financial exploitation – debt bondage; finances controlled by others; financial scams; benefit fraud. Criminal exploitation – those manipulated or coerced or trafficked for the purpose of any illegal activity i.e.. County Lines/ drug trafficking; cuckooing (taking over a person’s property); forced street crime (shoplifting, begging etc.); cannabis cultivation. Cultural exploitation – those manipulated or coerced using religious, social or cultural beliefs e.g., FGM, radicalisation, forced marriage.

 

  1. REVIEW OF POLICY

 

7.1       This policy was reviewed by: Cosmos Omeniho

 

Designation: Director Date: January 2023.

 

7.2       This policy will be reviewed in Jan 2024 by:

 

Name and designation: Cosmos Omeniho (Director)