Modern Slavery and Human Trafficking Statement 2019/20

 

Ingeus are fully committed to the requirements of the Modern Slavery Act 2015 and appreciates the significance of continually developing and improving our practices under these requirements. We have, and will, take a proactive approach to preventing modern slavery or human trafficking, and be strong in our reactions if any concerns are identified.
 
This statement outlines the steps Ingeus will continue to take to prevent modern slavery or human trafficking from occurring within our direct business delivery, or with our supply chain partners. These include:

  • Safeguarding Policy: sets out the legislative requirements regarding our duty of care towards staff and participants and provides a clear reporting process for any identified safeguarding concerns. This includes any issues related to modern slavery or human trafficking.
  • Modern Slavery Prevention and Reporting procedure: includes how to escalate any identified concerns relating to our supply chain.
  • Mandatory training programmes:  all staff complete mandatory training on safeguarding and Modern Slavery during induction and undertake annual refreshers. Our training is reviewed annually, which allows for changes in legislation and practice to be reflected in the content.
  • Staff Code of Conduct: embedded throughout our organisation, ensuring employees are aware of responsibilities and ethical behaviours, required for the effective and appropriate delivery of services. It refers to our company values, human rights and duty of care.
  • Equality and Diversity Policy: ensures we treat all people fairly, with dignity and respect, both staff and participants, and know how to take appropriate action if this is not occurring.  
  • Staff Recruitment Processes: ensure we employ people who can demonstrate personal values that complement our company values and are the most appropriate people for the role applied for. Right to Work in the UK documentation is checked for every staff member.
  • Participant ID checks: all participants accessing our services must provide appropriate identification documentation at the start of their programme and any concerns are reported through the Modern Slavery Prevention and Reporting procedure.
  • Supply Chain Due Diligence: Appropriate checks for ensuring Modern Slavery or human trafficking are not occurring in our supply chain are included in the due diligence process and are part of annual audits of delivery partners. We issue mandatory evaluation questionnaires to understand partners’ controls and processes ensuring Modern Slavery is not occurring within their own business. We also have facilitated training to supply chain partners on Modern Slavery and issued them with training materials that can be utilised within their organisation.
  • Global commitment: We have communicated our commitment to eradicate modern slavery across our global network and have issued mandatory evaluation questionnaires to understand and assess their current controls, as well as a compliance review with senior leaders focusing on policies and practices that are in place to prevent Modern Slavery and harm to individuals.

We will continue to review our policies and procedures in light of legislative changes and publications of best practice. We will provide training and bulletin updates to our teams and supply chain.
 
Our organisational lead on Modern Slavery and Human Trafficking is the Safeguarding Assurance Manager who will attend forums with the Human Trafficking Foundation and undertake training to disseminate across the organisation.
 

Fiona Monahan
CEO, Ingeus UK