This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that Stow Healthcare Group Ltd has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our company or supply chain during the year ending 31 March 2022.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour.
Stow Healthcare has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all company dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the company or our supply chain. 

Our Policy on Slavery and Human Trafficking 

Stow Healthcare is aware of our responsibilities towards residents, employees, families connected to our homes and the local community and expects all suppliers to the company to adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our company. Our internal policies replicate our commitment to acting ethically and with integrity in all our company relationships.

We operate a number of internal policies which ensure that we are conducting company in an ethical and transparent manner. These include: 

Recruitment – We operate a robust recruitment policy, including conducting eligibility to work in the United Kingdom checks for all directly employed staff. Agencies supplying staff are required 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.

Equal Opportunities – We have a range of controls to protect staff from poor treatment and/or exploitation, which complies with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and fair access to training and development opportunities

Safeguarding – We adhere to the principles inherent within our Safeguarding policy.  This provides clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving care in our homes are being treated, or about practices within our company or supply chain

Whistleblowing – We operate a whistleblowing/raising concerns policy so that everyone in our employment knows that they can raise concerns about how colleagues or people receiving care in our homes are being treated, or about practices within our company or supply chain, without fear of reprisals, and the various ways in which they can raise their concerns

Employees Handbook – Our handbook explains the manner in which we behave as an organisation and how we expect our employees to act

Our approach to procurement and our supply chain includes:

• Ensuring that our suppliers are carefully selected
• Requiring that the main contractor provides details of any sub-contractor(s) to enable the company to check their credentials
• Ability to request that the main contractor provide details of its supply chain
• Supplier adherence to our values. We are zero tolerant to slavery and human trafficking and thereby expect all our direct and indirect suppliers/contractors to follow suit
• Where it is verified that a subcontractor has breached the child labour laws or human trafficking, then this subcontractor will be excluded from further work with Stow Healthcare.

Training

Advice and training about modern slavery and human trafficking is available to staff through our mandatory safeguarding training programmes, our safeguarding policy and procedures, and our safeguarding leads. It is also discussed at our company safeguarding induction training which is mandatory for all our new starters. We are looking at ways to continuously increase awareness within our organisation, and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our company.

Our Performance Indicators

We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our company or supply chain if there are no reports received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.

This policy will be accessible on our website and reviewed annually.