MODERN SLAVERY POLICY
1. Carehome Interiors Ltd is a specialist interior design and installation service supplying the UK Care Home Industry.
2. Carehome Interiors Ltd is committed to the highest level of ethical standards and good governance arrangements and sets high standards of integrity and objectivity in relation to its business activities.
3. Carehome Interiors Ltd adopts a zero tolerance to modern slavery and human trafficking.
4. We fully support HM Government’s objectives to eradicate modern slavery and human trafficking.
5. Our Statement will provide information annually to supplement this policy, including details of our activities and supply chains and actions we are taking to comply with the provisions of the Modern Slavery Act 2015.
6. The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all our employees and our suppliers. Employees must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
7. It is a fundamental requirement of any procurement or supply contract with this company that suppliers will be required to comply with this company’s policy on Modern Slavery.
STATEMENT INTRODUCTION
1. This statement is made pursuant to s54 of the Modern Slavery Act 2015 (the Act) and sets out the steps that Carehome Interiors Ltd (the Company) has taken, and is continuing to take, to ensure that modern slavery or human trafficking is not taking place within our business or supply chain during the course of the financial year.
2. Modern slavery encompasses slavery, servitude, human trafficking and forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.
3. The Company is a small to medium sized enterprise (SME) and for the purposes of the Act it is not a commercial organisation. However, following published Home Office Guidance the Company has decided to comply with the spirit of the Act and publish both its own policy and its own statement.
ABOUT OUR BUSINESS
4. The Company carries out interior designs for new build care homes and care home refurbishments for various care home providers. The service offered by the Company typically includes the on-site manufacture of furnishings and the procurement of any other furnishings, fixtures and fittings not manufactured on Company premises. The Company regularly employs 10 people. However, during any installation process, this number can increase to 20. The Company is solely UK based and its supply chain is also predominantly UK based.
SUPPLY CHAIN AND DUE DILIGENCE
Scope of Procurement Activity
5. The Company procurement activities take place in England, and our suppliers and contractors are predominantly UK and EU based. For any one design and installation project, we typically engage up to 38 suppliers annually. Based on spend, the average value of supply contracts in any one year is £265,000.00.
Supply Chain Transparency
6. Regular mapping of our supply chain enables us to ensure that we are in a position to continually risk-assess for manufacture in areas deemed ‘at risk’ of Modern Slavery and we regularly use risk templates specifically designed for that purpose.
7. We expect that all our supply partners and other companies we engage with ensure that their goods, materials and labour-related supply chains:
a. Fully comply with our Policy and the provisions of the Act;
b. Are transparent, accountable and auditable; and
c. Are free from ethical ambiguities.
Risk Control Measures
8. In addition to the above the Company operates a number of internal policies to ensure we are conducting our business in an ethical manner. These policies include:
a. Recruitment. We operate a robust recruitment policy, including conducting UK eligibility checks for all directly employed staff, and agencies on an approved list which are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will.
b. Equal Opportunities. We have a range of controls to protect our staff from poor treatment and/or exploitation, and which comply with all relevant laws and regulations. These include provision of fair rates of pay, fair terms and conditions of employment and access to training and development opportunities.
c. Whistleblowing. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people employed or contracted by our Company are being treated, or about practices within our business or supply chain, without fear of reprisal.
d. Training. Advice and training about modern slavery and human trafficking is available to employees and also through our staff induction day for new employees. We continue to look at ways to continuously increase awareness across the Company to ensure a high level of understanding about the risks involved with modern slavery and human trafficking in our supply chain.
STATEMENT APPROVAL
9. This statement is approved for publication.