Modern Slavery Statement and Policy
This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
This procedure forms part of the Community Quality Management System in line with ISO-9001:2015 standards and applies to all community companies unless stated otherwise.
Next review date:
Anti-Slavery and Human Trafficking Policy v01
Modern Slavery Statement 2020
All companies within the community are detailed in the current legal structure
Modern Slavery Policy Statement
This is the modern slavery statement of Polaris community of companies and all its subsidiaries and UK companies. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). Although FCA is the only one of the companies within the community that meets the financial criteria for producing a modern slavery statement, this statement has been adopted by all companies in the community of organisations as their respective modern slavery statement for the financial year ending 31 December 2020.
This statement sets out the steps taken by Polaris community of companies to prevent modern slavery in its business and supply chains.
Our organisation continues to have a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of our business dealings and relationships. We have continued to implement and enforce effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either our own business or in any of our supply chains. We are committed to improving our practices to combat modern slavery and human trafficking.
Our Structure and Business
The agency’s parent company, whose registered office is situated in England, encompasses a community of companies which provide high-quality foster care, including specialist placements, throughout the UK, alongside supported and semi-independent accommodation for care leavers, family support, adoption, edge-of-care services and overseas Statutory Social Work services, as well as related services throughout the continuum of care.
Our Supply Chain
Throughout our supply chain, we are committed to high ethical standards, promoting safe and fair working conditions and responsible management of social issues. We believe we have a responsibility and opportunity to encourage sustainable business practices as well as inclusion and diversity amongst our suppliers. Our supply chains include contractors and consultants, primarily based in the UK, who provide various products and services such as:
- Social work services.
- Information technology suppliers providing equipment such as computers, laptops and mobile phones as well as software.
- Facilities management such as cleaning and security services.
- Company vehicles.
- Marketing services.
- Suppliers of materials such as stationery and office equipment.
For the minority of our suppliers that are outside of the UK, if modern slavery is identified or suspected, then the response will be tailored to the local circumstances, including engaging with local government, law enforcement, non-governmental organisations, industry bodies or trade unions.
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking is not taking place anywhere in our supply chains. In addition to this, we have a number of appropriate policies such as:
- Human Resources related documentation including Recruitment, Whistle-blowing and Grievance Policies.
- Risk Management Policy to clarify the process for identifying, analysing and evaluating a risk.
- Safeguarding Policy to ensure that vulnerable people are not at risk.
- Health and Safety Policy to demonstrate acceptable working conditions.
These policies encourage staff to report any wrongdoing, which extends to human rights violations such as modern slavery. All reports will be fully investigated and appropriate remedial actions shall be taken. Our modern slavery policies meet the following good practices:
- Policies are approved by senior management
- Policies are available to all staff in the organisation and communicated to them
- Relevant staff are trained in these policies
- High-risk suppliers are required to adhere to our modern slavery policies
Due diligence process
Within our organisation, we have robust recruitment processes, which include undertaking document checks on candidates prior to employment to evidence they are allowed to work in the UK, performing appropriate reference checks and ensuring that staff are paid directly into a suitable personal bank account. In relation to our supply chains, we have reviewed our contractual arrangements with current and prospective suppliers to ensure they comply with the Act. This involves placing obligations upon suppliers to conduct regular modern slavery risk assessments within their own supply chains, implement appropriate controls to prevent modern slavery, and notify our organisation immediately if any supplier becomes aware of any modern slavery within their supply chains.
Risk assessment and management
Our strategy for managing risks in relation to modern slavery and human trafficking are achieved through:
- A review of Incident and Supplier Management activities carried out by the Operational Leadership Team at their monthly meeting
- A central live portal for all staff to record specific incidents with reporting of extreme/high-risk situations being escalated to senior leadership meetings
- Quarterly reviews of the incidents to inform our Strategic and Business Continuity Risk Registers and enable the prioritisation of improvement projects
- Ongoing audit and assessment against the ISO 9001:2015 standards to identify compliance issues and identify improvement projects
Responsibilities for compliance
The Managing Directors of each business area are responsible for compliance in their respective departments and for their supplier relationships. Given the complexity and changing nature of this issue, we have formalised internal governance of modern slavery and human trafficking at both operational and senior leadership levels. To demonstrate the organisation's commitment to combat modern slavery and human trafficking in its business and supply chains, we monitor and enforce compliance with our Modern Slavery Policy.
We have a dedicated compliance team, which consists of involvement from the following departments:
- Human Resources;
- Finance; and
We recognise that overall accountability for risk management and internal controls are the responsibility of the Board. All risks that are identified as extreme or high risk are escalated to the leadership meeting, with exceptions subsequently reported to the Board.
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have appropriate staff training. This provides our employees with knowledge on how to identify exploitation and modern slavery as well as the process for reporting suspected cases. During the induction process and throughout employment, training is provided to staff on topics relating to business ethics. In addition to this, we have specific modern slavery training available for our staff. We also encourage our business partners to arrange training for their staff, suppliers and providers.
Our effectiveness in combating modern slavery and human trafficking
We understand that modern slavery is not static, and will ensure that our organisation continues its leading approach to mitigating this risk in the year ahead. In order to assess the effectiveness of the measures taken by our organisation, we will continue to review the following key performance indicators:
- Staff training levels, particularly in connection with specific modern slavery training;
- Actions taken to strengthen supply chain auditing and verification;
- Steps taken to raise awareness of modern slavery and human trafficking throughout supply chains; and
- Investigations undertaken into reports of modern slavery and remedial actions taken in response.
Following a review of the effectiveness of the measures we have adopted this year to ensure that there is no modern slavery or human trafficking in our supply chains, we intend to take the following further steps:
- Develop and report on key performance indicators; and
- Investigate modern slavery risks as identified and implement corrective actions in response to such risks within the business or supply chain as appropriate.
We are committed to continual improvement and will take active measures to combat modern slavery and human trafficking in our business and supply chains. This statement is made pursuant to section 54(1) of the Act and constitutes our community of companies modern slavery statement for the financial year ending 31 December 2020. This statement was approved by the Board.
Modern Slavery Policy
Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking.
The Company has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships. The Company is also committed to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015. The Company also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will, in turn, hold their own suppliers to the same standards.
Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, the Company accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications.
The Company encourages openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Company is committed to ensuring no one suffers any detrimental treatment or victimisation as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of its business or in any of its supply chains.
The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains, whether in the UK or abroad, is the responsibility of all those working for the Company or under the Company’s control. All staff are required to avoid any activity that might lead to a breach of this policy.
If any staff member believes or suspects a breach of or conflict with this policy has occurred or may occur, they must notify their line manager or report it in accordance with the Company’s Disclosures in the Public Interest Policy. Staff are encouraged to raise concerns about any issue or suspicion of modern slavery in any part of the Company’s business or supply chains as soon as possible. If there is any uncertainty about whether a particular act, the treatment of workers or their working conditions within any of the Company’s supply chains constitutes any of the various forms of modern slavery, it should be raised with a line manager. The government’s Modern Anti-Slavery and Human Trafficking Slavery Helpline can also be contacted on 0800 0121 700 for further information and guidance on modern slavery.
If a specific case of modern slavery is identified here in the UK, it should be reported to the police immediately on 101. If potential victims are in immediate danger the standard 999 emergency number should be used. In the UK, mechanisms are in place to assist victims of slavery and human trafficking. If staff identify a potential victim they can be referred (with consent) to the National Referral Mechanism to be formally identified as a victim of modern slavery and offered Government-funded support.
Training and Communication
Regular training on this policy, and on the risk that the business faces from modern slavery in its supply chains, is available to staff so that they know how to identify exploitation and modern slavery and how to report suspected cases. The Company’s zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and other business partners when entering into new or renewed contracts with them.
Breach of Policy
Any employee who breaches this policy will face disciplinary action, up to and including summary dismissal for gross misconduct. The Company may terminate its commercial relationship with suppliers, contractors and other business partners if they breach this policy and/or are found to have been involved in modern slavery.
UK Modern Slavery Adult Victim support providers
England and Wales
The Salvation Army 0300 303 8151
Trafficking Awareness Raising Alliance (TARA) 0141 276 7724
Migrant Helpline 07837 937737 or 07789 791 110
Migrant Help 013 0420 3977 or 07766 668 781 (for male potential victims of human trafficking)
Women’s Aid 028 9024 9041 (for female potential victims of human trafficking)
Modern Slavery Helpline
The NGO Unseen operates a UK-wide 24/7 Modern Slavery Helpline that victims, employers and members of the public who may encounter modern slavery can call for expert support and advice on 08000 121 700.
UK Government Modern Slavery Webpage
Modern Slavery Act 2015
The Modern Slavery Act 2015 (Transparency in Supply Chains) Regulations 2015 www.legislation.gov.uk/ukdsi/2015/9780111138847
Transparency in Supply Chains Consultation Document and Government Response www.gov.uk/government/consultations/modern-slavery-and-supply-chains