Modern Slavery & Human Trafficking Policy

In line with our Values, and to comply with current legislation, we have the following policy with regard to Modern Slavery and Human Trafficking

Introduction from the Chief Executive

This statement has been prepared in accordance with section 54 of the Modern Slavery Act 2015. It sets out The Orders of St John Care Trust’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.

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. As part of the care sector, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and have referenced our responsibilities on Slavery and Human Trafficking in our Values of Respecting Each Other and Building Communities. We continue to take our responsibility very seriously during the coronavirus pandemic.

Organisation’s Structure, Our Business

We are a not-for-profit charitable Trust providing care services for the aged, the infirm and the sick. We operate across a number of regions in the UK providing care in 65 care homes as well as a domiciliary care service in 14 extra care housing schemes. We have over 4,500 employees along with 600 volunteers.

The majority of our employees work within our care homes and extra care housing schemes. Supporting these operations are small functional teams including HR, Finance, Procurement, Marketing, IT and Care Quality. The Trust has its registered office at: Eyre Court, Whisby Way, Lincoln, LN6 3LQ

Our Supply Chains

Supply Chain
In delivery of our services, we utilise over 1,000 UK suppliers, including some who manufacture or source overseas. Through ongoing reviews of our supply chain, the areas we have identified as being at risk include: 
• Goods contracts where manufacturing is undertaken in countries with less vigilant standards for health and welfare, for example uniform supply from China, and some food products sourced in Asia and the far east.
• Temporary staff agency services.
How we mitigate these risks is evidenced in the rest of the policy.

2. Policies in relation to slavery and human trafficking

We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.

We have revised relevant policies to reflect our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in our supply chains.

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 employees 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 speak to a Senior Manager, Director or use our confidential helpline to raise them accordingly.

  • 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. Supplier code of conduct We are committed to ensuring that our suppliers adhere to the highest standards of ethics.

Suppliers are required to demonstrate that they provide safe working conditions, treat workers with  dignity and respect, and act ethically and within the law in their use of labour. Serious violations of our supplier code of conduct will lead to the termination of the business relationship. Whilst a formal Supplier Code of Conduct is being developed, our tender and due diligence processes comprehensively address the Trust’s requirements in this area, to ensure that we only engage suppliers that meet the high ethical standards aligned to our values. To date we have not identified any instances of modern slavery or human trafficking in our supply chains.

  • Modern Slavery Questionnaire

We issue a modern slavery questionnaire to our top 50 suppliers in terms of risk and spend. Responses to the questionnaire are reviewed and we work with our suppliers to address any areas of concern.

3. Due diligence

Our procurement processes, documentation and standard contracts are all designed to identify and mitigate the risks of modern slavery throughout the end-to-end supply chain process and provide the Trust with the ability to address any instances identified.

We undertake due diligence when considering taking on new suppliers, and regularly review 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. 
  • conducting supplier audits or assessments where slavery and human trafficking risks are identified.
  • creating an annual risk profile for each supplier.
  • the right to invoke 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.

The Trust, in its obligations to eradicate slavery and human trafficking, incorporates contractual requirements for its suppliers to confirm on an annual basis the steps it has taken to ensure the supplier and its supply chain comply with the law. The Trust’s prequalification questionnaire and tenders impose similar obligations.

4.Supplier adherence to our Values and Ethics

We have zero tolerance to slavery and human trafficking. To ensure all those in our supply chain and contractors comply with our values and ethics, we have put in place a rigorous supply chain compliance programme. This consists of:

  • A clear statement in our Tender Document about our attitude to modern slavery and human trafficking and our requirements of our suppliers which ensures any new suppliers meet our criteria.
  • A programme to ensure we have documented compliance statements from all our current suppliers confirming they meet our criteria.
  • A clause in our recruitment agency contracts regarding the obligation of our agencies and ourselves under the Modern Slavery Act 2015.

Internal communication to ensure all our managers and procurers are aware of and commit to delivering our policy and approach concerning modern slavery and human trafficking

5. Performance indicators/effectiveness in ensuring that slavery and human trafficking is not taking place in our business or supply chain

We use the following key performance indicator (KPI) to measure how effective we have been to ensure that slavery and human trafficking is not taking place in any part of our business or supply chains:

  • Initial questionnaire responses via the tender and due diligence processes confirming a supplier’s modern slavery position, prior to a new supplier being engaged.
  • An annual review by our suppliers to confirm there is no slavery in their supply chain.
  • Suppliers to submit in writing a confirmation that the review has been completed and that no slavery or human trafficking has been identified in their supply chain.

Additionally, we are developing further supply chain KPIs, which will be implemented over the next 12 months and subsequently reported upon to our Executive.

These KPIs are anticipated to include:

  • Percentage of spend or number of suppliers in high-risk areas.
  • Percentage of annual modern slavery questionnaires returned from high-risk suppliers.
  • Percentage of high-risk suppliers with an acceptable modern slavery clause in their contract terms.
  • Percentage of employees who have completed modern slavery training.
  • Number of modern slavery cases uncovered through our supply chain (measured through the modern slavery questionnaire.

6. Training

We require all employees within our organisation to complete training on modern slavery. This is completed as part of our induction process and employees are required to refresh this training every three years.

Along with raising general awareness to this area, our modern slavery training covers:

  • Identifying what modern slavery is and who it can affect
  • Highlighting some of the warning signs to look out for
  • Identifying the role of technology with modern slavery and how it can also be used to help combat it
  • Identifying the business’s responsibilities under the Modern Slavery Act 2015
  • Reporting methods that are available to refer potential victims
  • We also require our business partners to provide training to their staff and suppliers and providers.

7. Continuous Improvement

We are committed to continuously working to strengthen our approach to tackling the threat of modern slavery and human trafficking in our business and supply chain. Our journey continues in 2021/22 and our priorities for this period are as follows:
• Audit the top 50 suppliers by risk and spend currently engaged with The Orders of St John Care Trust
• Increased engagement to support our suppliers in identifying and mitigating risk
• Ensure that 100% of all new starters complete the Modern Slavery and Human Trafficking training module
• Review the content of the training to ensure it remains current and relevant
• Review the content of the policies named above to ensure they remain current and relevant

Board Approval

This statement was approved on 28 September 2021 by our Board of Trustees.

A signed copy of this policy can be provided upon request.

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