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
The Orders of St John Care Trust is committed to improving practices to combat slavery and human trafficking. Since the introduction of the Modern Slavery Act 2015, we have reviewed our supply chain policies and updating our managers to ensure we all understand and are delivering on our responsibilities in this regard.
We are a not for profit charitable Trust providing care services for the aged, the infirm and the sick. The Trust has its registered office at 1 Des Roches Square, Witney, OX28 4BE, Oxfordshire.
We have an annual turnover of over £137,000,000 and spend approximately over £40m on bought in goods and services from our extensive range of supply chains.
We operate across a number of regions providing care in 66 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.
Our Supply Chains
Our supply chains include over 1,000 UK suppliers, some of whom manufacture overseas.
Our Policy on Modern 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 have also referenced our responsibilities on Slavery and Human Trafficking in our Values of Respecting Each Other and Building Communities.
Due Diligence Processes for Slavery and Human Trafficking
As part of our initiative to identify and mitigate risk we have updated our Procurement documentation to reference the Modern Slavery Act 2015 and contacted all our suppliers to ensure there is no modern slavery or human trafficking in our supply chains or in any part of our business. We have in place systems to:
- Identify and assess potential risk areas in our supply chains
- Mitigate the risk of slavery and human trafficking occurring in our supply chains
- Monitor potential risk areas in our supply chains
- Protect whistle blowers
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.
The Trust considers that the following supply chains could be at risk of slavery and human trafficking:
- Temporary staff agency services
- Goods contracts where manufacturing is undertaken in countries with less vigilant standards for health and welfare
For both the above areas the Trust is ensuring that all its supply chains complete their annual declaration confirming the steps they have taken to comply with the law. In particular for temporary agency workers the Trust operates a whistle blowing policy if staff should have concern for the welfare of their colleagues whether permanent or temporary. To date the Trust has not received any issues of concern.
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
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide training to our employees. We also require our business partners to provide training to their staff and suppliers and providers.
Our Effectiveness in Combating Slavery and Human Trafficking
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:
• 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.
With regard to partners, we have also requested that they confirm in writing on an annual basis that no slavery or human trafficking has been identified in their supply chain.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2019/20.
Approved by the Board of Trustees on 19 January 2021.
A signed copy of this policy can be provided upon request.