1.1 To ensure that PW & EJ Thompson trading as Gabriels Care is aware of the issues surrounding slavery and human trafficking and has a policy and process in place to identify, and if applicable report on, issues surrounding slavery and human
1.2 To support PW & EJ Thompson trading as Gabriels Care in meeting the following Key Lines of Enquiry:
1.3 To meet the legal requirements of the regulated activities that PW & EJ Thompson trading as Gabriels Care is registered to provide:
- The Modern Slavery Act 2015
- The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2015
- Human Rights Act 1998
2.1 The following roles may be affected by this policy:
- All staff
- Registered Manager
- Owner, Proprietor or Responsible Individual
3.1 To promote awareness of concerns surrounding slavery and human
3.2 To publicly state PW & EJ Thompson trading as Gabriels Care’s commitment to addressing slavery and human trafficking in all its#
3.3 To define PW & EJ Thompson trading as Gabriels Care’s response to any incidence of slavery or human trafficking.
3.4 If applicable to publish an annual statement on slavery and human
4.1 In essence, compliance is necessary from 29th October However, if PW & EJ Thompson trading as Gabriels Care’s year end falls between 29th March 2015 and 30th March 2016, PW & EJ Thompson trading as Gabriels Care will not be required to publish a statement for the 2015/2016 financial year.
4.2 Guidance suggests that statements should be published within six months of the financial year end. Therefore, those with a financial year end of 31st March 2016 will be the first required to publish a statement by 30th September
4.3 It is unlikely that PW & EJ Thompson trading as Gabriels Care will experience cases of slavery or human trafficking, but this policy details the commitment to raise awareness and defines a process to address issues if they do
4.4 The Modern Slavery Act 2015 states that every organisation providing goods and services in the UK with a total global annual turnover of £36m or more will be required to produce a slavery and human trafficking statement for each financial
4.5 This figure of £36 million is the total turnover of the organisation or its group not the individual As such the publication of an annual statement (if applicable) will primarily be the responsibility of the senior management of the organisation, but individual services will contribute to the content of the statement and have an awareness of the issues of slavery and human trafficking.
4.6 All staff will be made aware of the issues surrounding slavery and human trafficking and encouraged and supported to report any concerns to the management of PW & EJ Thompson trading as Gabriels
4.7 PW & EJ Thompson trading as Gabriels Care will ensure that staff are only employed whose credentials can be
4.8 PW & EJ Thompson trading as Gabriels Care will be open and transparent with all staff and encourage discussion about slavery and human The service will also support any staff that may be subject to slavery or human trafficking.
4.9 Slavery and human trafficking is classed as abuse and indicators could be:
- Signs of physical or emotional abuse
- Appearing to be malnourished, unkempt or withdrawn
- Isolation from the community, seeming under the control or influence of others
- Living in dirty, cramped or overcrowded accommodation and/or living and working at the same address
- Lack of personal effects or identification documents
- Always wearing the same clothes
- Avoidance of eye contact, appearing frightened or hesitant to talk to strangers
- Fear of law enforcers
4.10 In situations of slavery or human trafficking being identified, PW & EJ Thompson trading as Gabriels
Care will share this information with the appropriate authorities with the objective of preventing future situations arising, and to promote the elimination of routes and sources of slavery or human trafficking.
5.1 If PW & EJ Thompson trading as Gabriels Care has a turnover of more than £36m then the annual statement will be published and will include detail on:
- Its structure, business and supply chains
- Its policies in relation to slavery and human trafficking
- Its due diligence processes in relation to slavery and human trafficking in its business and supply chains
- The parts of its business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps that it has taken to assess and manage that risk
- Its effectiveness in ensuring that slavery and human trafficking is not taking place in its business or supply chains, measured against such performance indicators as it considers appropriateThe training about slavery and human trafficking available to its staff
5.2 The statement should be:
- Written in simple language
- Succinct, but cover all relevant points and link to relevant documents
- In English, but may be provided in other languages that are relevant to the supply chain
- The statement must include either a statement: of the steps PW & EJ Thompson trading as Gabriels Care has taken during the financial year to ensure that slavery and human trafficking is not taking place in any of its supply chains and in any of its own business, or that PW & EJ Thompson trading as Gabriels Care has taken no such steps
5.3 The statement needs to be published and any director signing the statement needs to be satisfied that the statement is This might include carrying out full investigations.
5.4 Charities and educational institutions are captured by the obligation. If the turnover is £36 million, goods or services are supplied, and it carries on business within the UK, it is irrelevant the purpose for which its profits are made. Both franchisors and franchisees may be captured if they meet the turnover
5.5 The statement should be published on PW & EJ Thompson trading as Gabriels Care’s website and, where appropriate, linked through to any other relevant websites of PW & EJ Thompson trading as Gabriels
5.6 It must be obvious on the home page or clearly accessible by a drop down
5.7 If a parent company meets the requirements, it must include in its statement the steps taken in relation to each of its subsidiaries if they form part of the parent’s supply chain or business (even if the subsidiaries themselves do not meet all the requirements).
5.8 A subsidiary organisation that meets the thresholds in its own right must produce its own slavery and human trafficking However, a parent company may produce one statement that the subsidiaries also use.
5.9 All staff engaged with providing services at PW & EJ Thompson trading as Gabriels Care 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 This should minimise the chance of employing a person that has been / is subject to slavery or human trafficking.
5.10 PW & EJ Thompson trading as Gabriels Care will only use staff provided by third party organisations (such as agencies) that are registered with the regulator and who can confirm that the staff being supplied are free to work in the UK and meet all the requirements for the role being provided
5.11 All staff will receive information about slavery and human
5.12 Staff will be advised that if they are subject to slavery or human trafficking, or 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 should inform the Registered Manager of PW & EJ Thompson trading as Gabriels Care or the
- Slavery, in accordance with the 1926 Slavery Convention, is the status or condition of a person over whom all or any of the powers attaching to the right of ownership are exercised. Since legal ‘ownership’ of a person is not possible, the key element of slavery is the behaviour on the part of the offender as if he/ she did own the person, which deprives the victim of their freedom
6.2 Human trafficking
- An offence of human trafficking requires that a person arranges or facilitates the travel of another person with a view to that person being The offence can be committed even where the victim consents to the travel. This reflects the fact that a victim may be deceived by the promise of a better life or job or may be a child who is influenced to travel by an adult. In addition, the exploitation of the potential victim does not need to have taken place for the offence to be committed. It means that the arranging or facilitating of the movement of the individual was with a view to exploiting them for sexual exploitation or non-sexual exploitation
Key Facts – Professionals
Professionals providing this service should be aware of the following:
- The Modern Slavery Act 2015 details what organisations need to do about slavery and human trafficking
- Staff will receive information about slavery and human trafficking, and be supported by the organisation if subject to, or reporting of, cases of slavery or human trafficking
- Only staff that have been through robust recruitment procedures will be employed at PW & EJ Thompson trading as Gabriels Care
- If there are cases of slavery or human trafficking then the service will share this information with the appropriate authorities
- If slavery or human trafficking is disclosed to you then this must be shared with the Registered Manager, or the police