Modern slavery statement

1. Introduction

This document sets out the policy of Leonard Cheshire with the aim of the prevention of opportunities for modern slavery to occur within the organisation or supply chain. This policy’s use of the term “modern slavery” has the meaning given in the Act. 

Modern slavery is a criminal offence under the Modern Slavery Act 2015 (the “Act”). The Act is designed to tackle slavery in the UK and consolidates previous offences relating to trafficking and slavery. Modern slavery can occur in various forms, including servitude, forced or compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.  

From 29 October 2015, the Transparency in Supply Chain Provisions (source: Modern Slavery Act, 2015, Section 54(1), requires businesses to ‘publish an annual statement if they have an annual turnover above a threshold of £36 million’.   

Leonard Cheshire statement https://accordgroup.org.uk/about/about-us/mission-and-valuesis made in relation to this legislative requirement and confirms the steps taken to ensure that slavery and human trafficking are not taking place in the organisation (or in any supply chain). https://www.leonardcheshire.org/modern-slavery-statement 

We operate a number of policies which reflect our commitment to acting properly in all of our organisational relationships and to implementing and enforcing effective systems and controls. Our policies which contribute to minimising the risk of modern slavery and human trafficking in our organisation and our supply chain include our: 

• Recruitment & Selection policy
• Whistleblowing policy
• Safeguarding Children and Adults at Risk policy
• Confidentiality policy  

We will continue to review our policies to ensure that they are effective and appropriate. Subject to changes in legislation, this Policy will be reviewed and updated accordingly. 

Slavery can take many forms. These include: 

• Child trafficking
• Forced labour
• Forced marriage
• Sexual exploitation
• Criminal exploitation
• Domestic servitude
• Labour exploitation
• Organ harvesting  

Leonard Cheshire will not tolerate slavery in any aspect of our organisation. We hold our supply chains and ourselves accountable and we will ensure compliance with the provisions of the Modern Slavery Act 2015 in relevant aspects of our work. 

2. Policy outline

This policy document provides an overview of our zero-tolerance approach to modern slavery. We assess risks across supply chains and have amended our procedures to ensure that our contractors, consultants, suppliers and downstream partners (who directly implement our projects), in areas where a potential risk may occur, actively work towards eradicating modern slavery. We have determined that the main areas of risk for the organisation are: 

• Workforce sourcing for delivering Care and Support Services (both in the UK and Internationally)
• Construction contractors and sub-contractors
• Food sourcing 

We will provide guidance to colleagues on modern slavery by: 

• Providing training through the company Learning management system (refer to section 7)
• Running Modern Slavery awareness using our internal communication channels (including Workplace and Intranet) to mark Anti-Slavery Day 18th October (created by Act of Parliament to raise awareness of modern slavery)
• Updating the Procurement Intranet page with Modern Slavery information and links to useful websites, organisations and materials, including Anti-slavery International; Unseen UK and the UK government. 

3. Our Employees And Volunteers

We employee around 4000 staff, most of whom are based in the United Kingdom. Our staff are largely directly employed and are generally not in any category which is seen to be vulnerable to modern slavery in this country. 

Through our policies and procedures, we ensure fair and transparent recruitment processes.  We follow safe recruitment practices, ensuring that everyone who is offered employment with us, whether permanent or temporary has appropriate pre-employment checks. This includes appropriate references, right to work and disclosure checks where appropriate.  

We also encourage employees and volunteers to ‘speak up’ about any concerns. We have a number of ways for employees to raise whistleblowing concerns, including our external and confidential speak up service. We also have an employee assistance programme, which is available to all our employees, and offers confidential counselling support. 

Where we engage an agency worker we will ensure we use only agencies on our preferred supplier list. Each agency on the list has been carefully selected and complies with our terms and conditions and is required to conduct a thorough recruitment process to minimise safeguarding risks. 

4. Our Supply Chains 

Our annual third-party expenditure is circa £47m.  Due to the nature and geographical reach of our organisation, procurement across the organisation is a hybrid structure of central and decentralised procurement activity.   

The Procurement strategy and high value and high-risk opportunities are facilitated centrally by Procurement, with the remainder carried out by operational colleagues.   

5. Our Approach 

To mitigate risk within our supply chains, we have implemented and communicated the following systems and controls:  

5.1 Operations will: 

• Identify and assess potential risk areas in our UK supply chains by conducting an organisation wide spend and risk analysis
• Mitigate the risk of slavery in our supply chains by being open with suppliers on how we work together
• Ask third party providers for a copy of their Modern Slavery policy or statement.  Where this is not available, we will ask third party providers to read and comply with the Leonard Cheshire Modern Slavery policy. This is carried out at the onboarding stage of all new suppliers.

• Include Leonard Cheshire Modern Slavery clause in all Contracts.

  6. Risk Management

  As Leonard Cheshire operates in the UK and internationally, we have identified that we do have a potential exposure to risk.  However, our Modern Slavery Policy and policies around recruitment, safeguarding and procurement ensures that we have effective controls in place.  Staff are encouraged to ‘speak up’ through our whistleblowing and confidentiality policies.

  To manage this risk, we will work with suppliers and contractors to acknowledge our commitment to combat slavery by inserting relevant clauses into our contracts and agreements.  

  7. Training and Awareness Raising 

  To ensure a high level of understanding of the risks of modern slavery. Leonard Cheshire’s Safeguarding Training includes the modern slavery policy and is available through the company Learning management system.  The training is available to all staff.  This is aimed at helping colleagues to better understand the risks and how we as an organisation are working to manage this and mitigate Modern Slavery. 

  8. How to Report Modern Slavery Concerns 

  Colleagues who suspect incidents or signs of modern slavery in the UK should:   

• In the first instance, all modern slavery crimes should be reported to the local police by dialling 999.
• If colleagues hold information that could lead to the identification, discovery and recovery of victims in the UK, they should contact the Modern Slavery Helpline 0800 0121 700.

For more information, colleagues are advised to visit: www.unseenuk.org

• Alternatively, colleagues can make calls anonymously to Crimestoppers on 0800 555 111. 

9. Monitoring, Review and Performance Information 

The monitoring and effectiveness of this policy will be managed jointly by People and Procurement which includes: 

• Recording and monitoring any incidents or reports made to us which conflict with our values.
• Treating all reports and incidents in line with our confidentiality policy.
• Reviewing and strengthening our centralised procurement processes and policy, taking into account a range of risks, including slavery and human trafficking.