Kashfam Limited fully supports the Government’s objectives to eradicate modern slavery and human trafficking and recognises the significant role we can play in both combatting it and supporting victims. In particular, we are strongly committed to ensuring our supply chains and business activities are free from ethical and labour standards abuses.
Section 1- Policy
1.1 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.
1.2 KASHFAM CARE 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 KASHFAM CARE or within any third parties (agencies) that we are associated with.
1.3 All staff will be made aware of the issues surrounding slavery and human trafficking, whilst being encouraged and supported to report any concerns to KASHFAM CARE management. KASHFAM CARE will also support any staff that may be subject to slavery or human trafficking.
1.4 Where modern slavery or human trafficking is identified, KASHFAM CARE will share information with the specific to geographical area where client lives 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.
1.5 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.
1.6 All employees who suspect any members of the workplace being victim of modern slavery must notify their line manager.
1.7 KASHFAM CARE will take steps to ensure that sufficient communication and employee awareness training is undertaken with regards to Modern Slavery.
1.8 All employees will be made aware of PM11 – Whistleblowing Policy and Procedure at Bespoke Health & Social Care. The purpose of this policy and associated procedure is to enable Bespoke Health & Social Care to thoroughly investigate allegations of any wrong doing raised by employees within KASHFAM CARE without fear of reprisal.
1.9 KASHFAM CARE will use this policy to underpin and inform any statement on slavery and human trafficking that we may be required to produce to meet the requirements of Section 54 of the Modern Slavery Act 2015 (MSA).
2.1 Reporting Modern Slavery and Human TraffickingConcerns
The following procedure must take place where there are any concerns that someone is a victim of modern slavery or human trafficking. KASHFAM CARE must ensure that staff are aware that victims of modern slavery or trafficking will often not self-identify. Many will present with a different issue.
All staff engaged with providing services at Bespoke Health & Social 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 references. This will minimise the chance of employing a person that has been, or is subject to, slavery or human trafficking. Bespoke Health & Social Care will follow PR16 – Right to Work Checks Policy and Procedure to ensure that a robust and fair process is followed at all times.
KASHFAM CARE will only use staff provided by third-party organisations (such as agencies) that are either registered with the regulator or 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 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:
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 Registered Manager of Bespoke Health & Social Care or the police.
The Government guidance states that under section 54 of the Modern Slavery Act2015, certain businesses are required to publish an annual modern slavery statement setting out the steps they have taken to identify and address their modern slavery risks. During the coronavirus pandemic, it is essential that KASHFAM CARE continues to identify and address the risks of modern slavery in operations and supply chains. As well as focusing on the health and safety of workers, KASHFAM CARE will consider how fluctuations in demand and changes in the operating model may lead to new or increased risks of labour exploitation. If KASHFAM CARE needs to delay the Modern Slavery statement The challenges presented by the coronavirus pandemic may mean that KASHFAM CARE will not be able to publish the statement within the usual timeframe. Where KASHFAM CARE needs to delay the publication of the modern slavery statement by up to 6 months due to coronavirus- related pressures, KASHFAM CARE understands that we will not be penalised. In the statement, KASHFAM CARE will state the reason for any delay.
Some suppliers may be seeking to recruit additional workers in order to meet increases in demand. Bespoke Health & Social Care will ensure that rigorous recruitment checks are maintained and that suppliers adhere to the same robust processes to ensure that vulnerable workers are not being exploited by third parties seeking to profit from heightened demand.
As a responsible organisation, it is important that the relevant local or national government policies are implemented throughout the supply chain at Bespoke Health & Social Care. Bespoke Health & Social Care will ensure that suppliers adopt social distancing measures and pay statutory sick pay in order to prevent the spread of coronavirus as part of due diligence processes.
KASHFAM CARE intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers. We will also continue to:
Support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working in care can have in keeping present and potential future victims of modern slavery and human trafficking safe.
Gain assurance that all staff at KASHFAM CARE have access to training on how to identify victims of modern slavery and human trafficking. Review the Safeguarding Policy and Procedure at Bespoke Health & Social Care to ensure that Modern Slavery and Human Trafficking are integral within the content and staff are directed to support and advice as needed.
We recognise that being in the healthcare industry, we are exposed to risks relating to the potential violation of human rights in areas including modern slavery and human trafficking. We are conscious that such risks can arise in certain areas of the sector, in particular nursing, aged care provision, as well as in the manufacturing of healthcare equipment. We are committed to monitoring such risks in our business and in our wider supply chain and to mitigating them.
This statement is published in accordance with Section 54 of the Modern Slavery Act 2015 Act and the Modern Slavery Act 2015 (Transparency in Supply Chains) Regulation 2015 (the “Act”). It sets out the steps taken by Kashfam Limited, to prevent modern slavery and human trafficking in its business and supply chain.
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