Modern Slavery Policy

Policy Statement

365 Care Services is committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chain.
The aim of this policy is to help our staff to understand what constitutes Modern Slavery, what the various responsibilities within the company are, and how we plan to tackle the issue of Modern Slavery within our workplace.

What is Modern Slavery?

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 have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or our supply chain.

EXAMPLES OF MODERN SLAVERY

An example of Modern Slavery would be if somebody is being paid below the National Minimum Wage, forced into working more than 48 hours a week, or being denied the required amount of break time and rest between shifts, which goes against the Working Time Derivative

Working Time Derivative:

The 48-hour week is defined as an average over a 17-week period. So, a 50-hour week followed by a 5-hour week would not be in breach of legislation.

Care workers are also able to opt-out of the working time derivative and, if doing so, a copy must be kept in their personnel file.

Due Diligence Processes

365 Care Services undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. 365 Care Services’s due diligence process includes building long-standing relationships with suppliers, making clear our expectations of business partners, evaluating the modern slavery and human trafficking risks of each new supplier and invoking sanctions against suppliers that fail to improve their performance.

To ensure all those in our supply chain and contractors comply with our values, we have in place a standard clause in all our new agreements with suppliers and contractors which informs them of our commitment to combatting slavery and human trafficking and requires them to agree to this commitment when working with us.

We are committed as a company to tackling modern slavery and human trafficking and want to work with suppliers who share this commitment.

Compliance with the Policy

You must ensure that you read, understand, and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chain is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

You must notify your manager as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future.

You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or the supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur, you must notify your manager or report it in accordance with our Whistleblowing Policy as soon as possible.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any part of our supply chain. If you believe that you have suffered any such treatment, you should inform your manager immediately.

Breaches of this Policy

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Further Steps

Following a review of the effectiveness of the steps we have taken to ensure that there is no slavery or human trafficking in our supply chains we intend to take the following further steps to combat slavery and human trafficking:

 

  • continuous monitoring of our business and its supply chains to ensure we are free from slavery and human trafficking.
  • continuing to require our contractors and supply chains to act in accordance with our Anti-Slavery policy when dealing with us; and
  • ongoing education and promotion of our Anti-Slavery Policy along with a training program to ensure our staff understand and adopt our values.

This policy is made pursuant to section 54(1) of the Modern Slavery Act 2015

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