Modern Slavery and Human Trafficking Policy
Policy Number: DOC – 074
Date Implemented / Last Reviewed: July 24, 2025
Next Review Date: July 24, 2026
Policy Statement
This policy outlines the principles, values, and procedures that underpin Tomaaron Care Services LTD’s approach to identifying and responding to any situations in which modern slavery, human trafficking, or forced labour may be present—whether directly or indirectly.
It applies to our organisation and to all individuals and organisations we engage with in the course of our operations.
This policy is aligned with the safeguarding responsibilities of local authorities under the Care Act 2014 (and equivalent legislation in devolved nations), which include protecting adults at risk from abuse, including exploitation through modern slavery, human trafficking, or coercion such as “county lines” involvement.
It also reflects the aims and obligations set out in the Modern Slavery Act 2015, which outlines the responsibilities of companies and charities to avoid any links to modern slavery and to report suspected incidents to the relevant authorities.
We understand that as our organisation does not meet the £36 million annual turnover threshold, we are not legally required to produce an annual modern slavery statement. However, we voluntarily commit to adopting the highest ethical standards in line with the Act.
Modern slavery includes, but is not limited to, forced or compulsory labour, trafficking of adults and children, and exploitation where individuals are coerced into work or services for the financial gain of others without their free consent.
Service Users
As a provider of social care, we are committed to ensuring that no service user in our care is subjected to any condition that may constitute modern slavery, exploitation, or forced labour, as defined in the Care Act and related legislation.
If we have concerns, suspicions, or evidence that a service user may be at risk of, or a victim of, modern slavery or trafficking, we will take immediate safeguarding action by alerting the local safeguarding authority and/or the police. Our full safeguarding procedures will then be applied.
Staff
We do not employ staff under any circumstances that could give rise to accusations of exploitation, forced labour, or modern slavery.
All staff are recruited in compliance with employment law and relevant sector registration requirements. Pay, working conditions, and rights comply fully with statutory obligations.
Should we become aware that any member of our staff is being exploited by a third party or subject to forced labour outside our organisation, we will uphold our duty of care by reporting our concerns to the police or the local modern slavery unit.
We will not penalise or discriminate against an affected employee, provided they meet the terms of their employment and were recruited following our lawful recruitment processes.
Contractors and Suppliers
We work with a range of external organisations and suppliers. We recognise that some may form part of complex supply chains. Tomaaron Care Services LTD takes all reasonable steps to ensure that our suppliers do not use forced labour or engage in human trafficking.
We expect all contractors and suppliers to adopt a zero-tolerance approach to modern slavery and to demonstrate robust due diligence in their own supply chains. We will only work with organisations that operate in compliance with the Modern Slavery Act 2015 and can provide evidence of their own anti-slavery commitments.
When tendering for goods or services, we inform potential suppliers that we expect full transparency regarding their employment practices and those of their suppliers. We require evidence of anti-slavery measures and reserve the right to terminate any contracts where credible concerns arise.
All staff, especially those involved in procurement or contracting, are expected to report any concerns or suspicions relating to modern slavery at the earliest opportunity.
Employees who raise concerns in good faith will be protected in accordance with our Whistleblowing Policy.
Training
All staff are informed about this policy and trained on their responsibilities regarding safeguarding and recognising the signs of modern slavery, particularly as it pertains to vulnerable adults.
Staff involved in the procurement of goods and services receive additional training to ensure the organisation remains compliant and is not inadvertently implicated in unlawful or unethical practices.
They are also trained in how to respond to concerns or evidence of breaches of anti-slavery laws.
Summary
Tomaaron Care Services LTD has a zero-tolerance approach to modern slavery and human trafficking. We are committed to acting ethically, with integrity and transparency in all aspects of our operations and supply chain, and to implementing and enforcing effective systems and controls to prevent slavery and human trafficking from taking place.