Anti-Slavery & Trafficking Policy

Anti-Slavery and Trafficking Policy

This policy is made by the board of NYS Nursing with regards to the Modern Slavery Act 2015 which requires large employers to be transparent about their efforts to eradicate Slavery and Human Trafficking in their supply chain. It requires all staff of NYS Nursing to comply with the Modern Slavery Act 2015 and act accordingly if they are ever exposed to details listed in the Modern Slavery Act 2015.

Here at NYS Nursing, we are committed to ensuring that there is no modern slavery or human trafficking taking place in our supply chains or in any part of our business. We do not believe there to be any high-risk operations within the work of NYS Nursing and its supply chains with regards to modern slavery and human trafficking. The potential for medium risk is also low as we undertake most of our own building and maintenance work. There is a potential for low risk in the supply chains in the provision of agency staff. Our Anti-slavery Statement 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 slavery and human trafficking is not taking place anywhere in our supply chains.

There are several forms of Modern Slavery that deprive the victims of their liberty and often leads to financial exploitation. Some forms of Modern Slavery are forced labour or servitude, child labour, human-trafficking, and any form of slavery both in our business and in our supply chains. Any form of Modern Slavery will not be tolerated at NYS Nursing and suitable action will be taken.

In relation to this policy, rigorous checks of the employees and the care homes they are sent to are taken regularly to ensure there is no exploitation in the business or supply chain.

We have in place systems to:

Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.
Protect whistle blowers

Whistleblowing: Aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery.

Complaints: Whilst aimed at receiving complaints or concerns about our care provision or conduct, all complaints received will be fully investigated and appropriate remedial actions taken, and we will work closely with our social care and health partners ensuring our safeguarding policies and procedures dovetail with local procedures and best practice.

Robust recruitment procedures: This includes conducting eligibility to work in the UK checks for all employees to safeguard.

Agency employment procedures: At NYS, we ensure that all our staff are screened and vetted in line with best practice and relevant legislation to ensure: Authentic and legal documentation, right to work in the UK and identity, as well as assessing for any concerning behaviours/fears/pay or banking irregularities or health issues that may require further review in line with combating Modern Slavery.

Anti-Fraud, Bribery and Corruption: It is part of our policy to conduct all business in an honest and ethical manner. We are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

The Company confirms that prior to any supplier being included on our supply chain, they have policies and procedures that are congruent with our intention to combat slavery and human trafficking. If Service Users do not have their own Modern Slavery statement/policy, we will make our statement available and obtain assurances of their commitment to follow prior to supply commencing. If, after supply commences, we believe there is an actual breach or risk of breach, we will investigate this following our Complaints and/or Serious Untoward Incident Policy. To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, our employees are encouraged to identify and report any potential breaches of our anti-slavery policy and we have in place protection for whistle blowers. Direct Communication the Company encourages members of the public or people not employed by us to write, in confidence, to the Company’s Director of Compliance and Regulation to raise any concern, issue or suspicion of modern slavery in any part of our business. We will know the effectiveness of the steps that we are taking to ensure that slavery is not taking place within our business or supply chain if: No reports are received from employees, the public, or law enforcement agencies or local safeguarding teams to indicate that modern slavery practices have been identified. Safeguards 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 because of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our business. Detrimental treatment includes dismissal, disciplinary action, threats, or other unfavourable treatment connected with raising a concern.

Whistleblowing is constantly encouraged to ensure a fair and healthy working environment and help improve the running and reputation of the business. Any whistle-blowers can approach any member of senior staff without the fear of reprisals. Any information that they have given is kept confidential and can only be shared to the relevant authority. Their identity is kept confidential. The Company will accept and take seriously concerns communicated anonymously. However, retention of anonymity does render investigations and validation more difficult and can make the process less effective. Individuals are therefore encouraged to put their names to allegations. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary action being taken against the individual. Staff are hereby informed of the Modern Slavery Helpline o 0800 0121 700 or visit website https://www.modernslaveryhelpline.org in accordance with the training recommendations of “Transparency in Supply Chains etc. A practical guide” (Guidance issued under section 54(9) of the Modern Slavery Act 2015).

Modern Slavery And Human Trafficking Policy

NYS Nursing Agency is committed to driving out acts of modern-day slavery and human trafficking within its business and that from within its supply chains, including sub-contractors, and partners. The Company acknowledges responsibility to the Modern Slavery Act 2015 and will ensure transparency within the organisation and with suppliers of goods and services to the organisation. These as well as the suppliers of services make up the supply chain within the Agency.

As part of the company’s due diligence processes into slavery and human trafficking the supplier approval process will incorporate a review of the controls undertaken by the supplier. Imported goods from sources from outside the UK and EU are potentially more at risk for slavery/human trafficking issues. The level of management control required for these sources will be continually monitored.

The company will not support or deal with any business knowingly involved in slavery or human trafficking.

The company Director and senior management shall take responsibility for implementing this policy statement and its objectives and shall provide adequate resources (training, etc.) and investment to ensure that slavery and human trafficking is not taking place within the organisation and within its supply chains.

A copy of this policy and a copy of the Modern Slavery Act 2015 will be accessible to all employees electronically and can be obtained from the HR department upon request.

This policy statement will be reviewed annually and published. This Policy considers, and supports, the policies, procedures and requirements documented in our Integrated Management System, compliant with the requirements of ISO 9001:2008, ISO 14001:2004 and OHSAS 18001:2007.

The implementation and operation of this management system underlines our commitment to this policy. Formal procedures concerning slavery and human trafficking have been established, including disciplinary procedures where they are breached.

Additional procedures ensure that this policy is understood and communicated to all levels of the company, and that it is regularly reviewed by the Director to ensure its continuing suitability and relevance to the company activities.

Modern Slavery

Modern Slavery involves recruiting and moving people using threats, deception, and coercion to exploit them.

It takes many forms but the most common are sexual exploitation, forced labour and domestic servitude. Victims are forced to work in various settings such as brothels, cannabis farms, nail bars, car washes, agriculture, and even within people’s homes.

Slavery isn’t confined to history or other countries. It is a myth that slavery and forced labour was stopped in the 19th century with the introduction of The Slavery Abolition Act 1833. It’s a global problem and is happening right now, here in United Kingdom.

Human trafficking can also be a part of Modern Slavery as a person is moved from one place to another. This could be country to country, town to town, or even as simple as one room in a building to another. Even if a victim agrees to be moved, trafficking could still be taking place.

Unfortunately, few people understand modern slavery, and many confuse it with ‘migrant working’ or ‘illegal immigration’.

It’s a problem that affects all ages, genders, and ethnicities, and affects people from Britain and abroad.

Victims are generally living in fear. They don’t fully understand what’s happening to them and comply with their abusers in hiding the reality. They aren’t speaking up because their traffickers threaten them and their families with violence.

This area of policing is complex and spotting Modern Slavery can be hard. In many cases organised crime groups are responsible for trafficking people into the UK. However, sometimes victims will travel into the UK by their own means (sometimes they’re asked to by their families), expecting to start legal employment, unaware of the situation that awaits them.