Anti-Slavery Policy

1. Introduction

Birmingham Carers Support ("the Organisation") is committed to acting with integrity and transparency in all of its business activities, and to taking a zero-tolerance approach to modern slavery in all its forms, including forced labour, human trafficking, and child labour. The Organisation is committed to ensuring that modern slavery does not occur within its operations or supply chains.

This Anti-Slavery Policy ("the Policy") outlines the Organisation’s commitment to preventing slavery and human trafficking, and sets out the steps that will be taken to ensure compliance with relevant legislation.

2. Purpose

The purpose of this Policy is to:

• Clearly state the Organisation’s stance on modern slavery.

• Define modern slavery and explain its forms.

• Detail the steps the Organisation will take to identify and mitigate the risks of modern slavery.

• Set out the responsibilities of the Organisation, its employees, contractors, suppliers, and other stakeholders in preventing modern slavery.

3. Legal Framework

This Policy is guided by and complies with the following laws, regulations, and international frameworks:

• The Modern Slavery Act 2015 (UK)

• The Trafficking Victims Protection Act 2000 (USA)

• International Labour Organisation (ILO) Convention No. 29 on Forced Labor and Convention No. 105 on Abolition of Forced Labour

• The Universal Declaration of Human Rights

• Other applicable national and international laws and regulations relating to slavery and human trafficking

4. Definition of Modern Slavery

For the purposes of this Policy, modern slavery refers to situations in which individuals are forced, coerced, or deceived into work or service under threat or duress, without the freedom to leave or control their work conditions. Modern slavery includes, but is not limited to:

• Slavery: The condition in which individuals are owned or controlled by others, without personal freedom, and are forced to work.

• Servitude: A condition of compulsory labor or service, typically for little or no pay, and with limited or no ability to leave.

• Forced Labor: Any work or service that is extracted from a person under the threat of a penalty or harm, and where the person has not freely consented to work.

• Human Trafficking: The recruitment, transportation, transfer, harboring, or receipt of persons for the purposes of exploitation through force, fraud, or coercion.

• Child Labor: The employment of children under the legal minimum age for work, in violation of national laws or international standards.

5. Our Commitment

The Organisation is committed to:

• Zero Tolerance: Adopting a zero-tolerance approach towards slavery and human trafficking. Any instance of modern slavery discovered within the Organisation’s operations or supply chains will be taken seriously and dealt with accordingly.

• Transparency: Promoting transparency in the Organisation's supply chains and business operations, ensuring that suppliers and business partners share this commitment to eliminating modern slavery.

• Human Rights: Upholding human rights and ensuring that all individuals involved in the Organisation’s activities are treated with dignity and respect.

6. Recruitment and Employment Practices

The Organisation will ensure that its recruitment processes adhere to the highest standards of ethical practice, and that no individuals are coerced, threatened, or forced into employment. The Organisation will:

• Carry out appropriate checks to ensure that all employees have the right to work in the relevant jurisdiction, and that they have voluntarily entered into their employment relationship.

• Provide clear terms and conditions of employment to all employees, including written contracts, outlining their rights, hours of work, remuneration, and benefits.

• Pay employees at least the national minimum wage or higher and ensure all workers have access to freely chosen employment, without undue constraints or exploitation.

7. Supply Chain Due Diligence

The Organisation will take appropriate steps to assess and address the risk of modern slavery within its supply chains. These steps include:

• Supplier Assessment: Conducting due diligence checks on suppliers to identify and assess the risk of modern slavery in their operations, ensuring that they comply with the Organisation’s standards regarding ethical labor practices.

• Contracts: Ensuring that all contracts with suppliers and third parties include clear anti-slavery provisions, including the requirement for compliance with this Policy, and empowering the Organisation to take action in case of non-compliance.

• Monitoring and Auditing: Regularly monitoring and auditing suppliers to ensure adherence to anti-slavery practices. Where issues are identified, corrective action plans will be developed in collaboration with suppliers.

8. Reporting Concerns and Whistleblowing

The Organisation encourages all employees, contractors, and business partners to report any concerns they have regarding modern slavery, whether related to the Organisation’s operations or supply chains. All reports will be treated confidentially, and individuals will not face retaliation for raising concerns.

• Reporting Mechanisms: The Organisation will provide a confidential reporting mechanism to allow individuals to report any instances of modern slavery without fear of retribution. This may include a helpline, email address, or dedicated point of contact within the Organisation.

• Whistleblower Protection: The Organisation will ensure that whistleblowers are protected and that no individual suffers any form of discrimination or disadvantage as a result of making a report in good faith.

9. Training and Awareness

The Organisation will provide training on modern slavery and human trafficking to all employees, particularly those in roles involving procurement, recruitment, and supply chain management. This training will help employees to recognize the signs of modern slavery and understand how to report concerns effectively.

• Induction Training: All new employees will receive training on the Organisation’s anti-slavery stance as part of their induction process.

• Ongoing Training: Refresher training and awareness programs will be provided regularly to ensure that all employees remain informed of the latest developments in anti-slavery laws and best practices.

10. Monitoring and Enforcement

The Organisation will establish mechanisms to regularly monitor compliance with this Policy. The effectiveness of the Policy will be reviewed annually, and the Organisation will ensure that adequate resources are in place to implement its anti-slavery initiatives.

In cases of non-compliance, appropriate corrective actions will be taken, which may include:

• Termination of contracts with suppliers or contractors who fail to meet the Organisation’s anti-slavery requirements.

• Disciplinary action against employees found to be in breach of this Policy, up to and including termination of employment.

11. Review and Update of the Policy

This Anti-Slavery Policy will be reviewed annually to ensure its effectiveness and compliance with applicable laws and best practices. Any updates or changes to this Policy will be communicated to all employees and stakeholders.

The Organisation is fully committed to the elimination of modern slavery and human trafficking from its operations and supply chains. This Policy reflects the Organisation’s dedication to maintaining high ethical standards and ensuring the welfare and dignity of all individuals involved in its activities.