1. Introduction / Purpose

At Sacred HomeCare, Suite 12, Business Development Centre, Eanam Wharf, Lancashire, BB1 5BL, we are committed to conducting our business ethically, with respect for human rights, and in full compliance with the Modern Slavery Act 2015. Modern slavery includes slavery, servitude, human trafficking, forced or compulsory labour, and other related exploitation.
We have zero tolerance for any form of modern slavery in our business or our supply chains. This policy outlines our approach to identifying, preventing, and addressing the risk of modern slavery.

2. Our Commitment

  • We will not knowingly engage with any individual, supplier, subcontractor, or partner that practices or supports modern slavery.

  • We commit to fair, ethical, and legal treatment of all workers, ensuring that no one is forced, coerced, or exploited.

  • We will build transparency, integrity, and accountability into our recruitment, contracting, and procurement processes.

  • We will continuously assess and mitigate the risks of modern slavery in our operations and supply chains.

3. Organisation Structure and Supply Chains

  • Sacred HomeCare is a domiciliary care provider, delivering services in clients’ homes in the United Kingdom.

  • Our supply chains include (but are not limited to): care staff recruitment (directly or via agencies), recruitment of subcontractors, procurement of care equipment, cleaning supplies, uniforms, and third-party service providers.

  • Although we operate on a local / regional scale, we recognise that risks can still exist, especially in recruitment, subcontracting, and vendor relationships.

4. Policies in Relation to Modern Slavery

To support this policy, we have established and maintain:

  • A Modern Slavery & Human Trafficking Policy (this document)

  • A Recruitment Policy that ensures right-to-work checks, references, and fair hiring practices

  • A Whistleblowing Policy so employees, contractors, or third parties can confidentially report concerns without fear of retaliation

  • A Code of Conduct / Ethical Business Policy that sets out clear behavioural expectations regarding labour practices

  • Relevant HR policies, disciplinary procedures, and grievance mechanisms to safeguard workers’ rights

5. Due Diligence Processes

To manage and minimise the risk of modern slavery, we take the following steps:

  1. Pre-engagement screening

    • Before engaging with suppliers or subcontractors, we assess their policies, reputation, and ethical practices.

    • We include contractual clauses that require suppliers to confirm that they comply with anti-slavery standards.

  2. Right-to-work and employment checks

    • For staff recruitment (direct or through agencies), we verify right-to-work, identity, references, and employment history.

    • For overseas or migrant workers (if applicable), we ensure compliance with immigration legislation and fair recruitment standards.

  3. Contractual controls

    • Our contracts with suppliers and subcontractors include anti-slavery provisions.

    • We require suppliers to declare they do not engage in forced labour or human trafficking.

  4. Ongoing Monitoring

    • We regularly review our supplier relationships.

    • We use risk-based assessment: prioritising higher-risk suppliers (e.g., those in sectors or regions more exposed to modern slavery).

    • We encourage open communication: suppliers are expected to notify us if they identify potential slavery risks in their own operations.

6. Risk Assessment and Management

  • We regularly assess which parts of our business and supply chain pose higher modern slavery risk (e.g., labour agencies, subcontractors, low-cost procurement).

  • We maintain a risk register which is reviewed periodically by senior management.

  • Where risks are identified, we implement proportionate mitigation measures — such as enhanced due diligence, more rigorous contract terms, or supplier exit if compliance cannot be assured.

7. Performance Indicators (KPIs)

We monitor the effectiveness of our modern slavery measures by tracking:

Key Indicator Measurement & Target
Number of supplier assessments completed Yearly target: 100% of active suppliers evaluated for slavery risk
Incidents / reports Zero confirmed cases of modern slavery; all reported concerns are investigated and resolved
Recruitment compliance 100% of new hires undergo right-to-work checks, references, and safe recruitment checks
Training coverage All employees and relevant contractors trained in modern slavery awareness

8. Training and Awareness

  • All our staff (employees, contractors, and subcontractors) receive training on modern slavery, how to recognise signs, and how to report concerns.

  • Modern slavery awareness is part of our induction programme for new joiners.

  • We provide refreshers / updates as necessary, especially when we identify new risks, or when legislation or guidance changes.

9. Reporting & Whistleblowing

  • If any employee, contractor, or third party suspects that modern slavery or human trafficking is occurring in any part of our business or supply chain, they must report this via our Whistleblowing Policy.

  • Reports can be made confidentially, and we guarantee non-retaliation for those raising genuine concerns in good faith.

  • All reports will be taken seriously, investigated, and escalated to senior management as needed.

  • Where necessary, we will work with law enforcement, regulatory authorities, or specialist organisations to ensure proper handling and remediation.

10. Accountability & Governance

  • The Board / Senior Management of Sacred HomeCare is ultimately responsible for this policy and its implementation.

  • Responsibility for day-to-day operational compliance lies with [insert role, e.g., Compliance Manager / HR Manager].

  • This policy will be reviewed at least annually (or more frequently if required) to ensure it remains up to date and effective.

  • Any significant issues, incidents or risk assessments will be escalated to senior leadership for discussion and action.

11. Communication & Transparency

  • This policy will be published on the Sacred HomeCare website (e.g., in the footer under “Modern Slavery / Ethical Policy”), making it accessible to clients, suppliers, staff, and the public.

  • We will ensure that our suppliers and business partners are aware of this policy and understand our expectations regarding modern slavery.

  • Where possible, we will encourage suppliers to adopt similar anti-slavery standards and practices.

12. Consequences of Non-Compliance

  • Any employee found to be in breach of this policy may face disciplinary action, up to and including termination.

  • We reserve the right to terminate contracts with suppliers or partners who fail to comply with our policy or who are unwilling to remediate identified risks.

  • We may also report any suspected criminal activity relating to modern slavery to the proper authorities.

Contact:
If you have questions or concerns about this policy, or if you suspect modern slavery in our operations or supply chain, please contact:

  • Safeguarding Lead / Compliance Officer – Sacred HomeCare

  • Address: Suite 12, Business Development Centre, Eanam Wharf, Lancashire, BB1 5BL

  • Phone: 01254 449262

  • Email: admin@sacredhomecare.co.uk