Modern Slavery and Human Trafficking Policy
Better Days UK is committed to conducting all business with integrity, transparency, and respect for human rights. We have zero tolerance for modern slavery, forced labour, or human trafficking in any form.
We recognise our responsibility to prevent exploitation and uphold the highest standards of ethical conduct in all aspects of our operations and supply chains.
No individual will ever be disadvantaged for raising concerns they reasonably believe to be genuine. Better Days UK strongly encourages the reporting of suspected modern slavery or human trafficking. We provide clear reporting channels, confidentiality safeguards, and protection from retaliation.
Purpose
The purpose of this policy is to:
- Prevent modern slavery and human trafficking in our operations and supply chains.
- Ensure compliance with the UK Modern Slavery Act 2015 and relevant international human rights standards.
- Set out the responsibilities of employees, managers, and contractors in identifying and preventing modern slavery.
- Provide procedures for reporting, investigating, and addressing concerns.
- Safeguard individuals who raise concerns in good faith.
Scope
This policy applies across all jurisdictions where Better Days UK operates. It applies to all employees, contractors, volunteers, and agents across all business functions.
This policy extends to all third parties that we are involved with, inclusive of business partners, who are expected to uphold the same standards.
Definitions
For the purposes of this policy:
- Modern Slavery: The severe exploitation of people for personal or commercial gain, including forced labour, debt bondage, and child labour.
- Human Trafficking: The recruitment, transportation, transfer, harbouring, or receipt of persons by means of coercion, abduction, fraud, or abuse of power for the purpose of exploitation.
- Exploitation: Includes sexual exploitation, forced labour, domestic servitude, organ harvesting, and other forms of abuse.
Roles and Responsibilities
Role | Responsibilities |
All employees | Are to remain vigilant to signs of modern slavery, report concerns to their supervisors or managers, and comply with this policy. |
Supervisors and Managers | Are to lead by example, address concerns raised, and support employees in understanding and applying this policy. |
Human Resource Manager | Maintain the policy, provide training, investigate concerns, and ensure HR practices are free from exploitation. |
Executive Team and Senior Managers | Are to oversee compliance, ensure due diligence in supply chains, and review risk management processes. |
Prohibited conduct
Employees and associated persons must not:
- Engage in or facilitate modern slavery, human trafficking, or exploitation.
- Enter into business relationships with suppliers or contractors who fail to comply with modern slavery standards.
- Ignore or conceal knowledge of potential exploitation.
- Retaliate against anyone who raises a concern in good faith.
Procedure
Reporting Modern Slavery and Human Trafficking Concerns
Victims of modern slavery or trafficking will often not self-identify, and many may present with unrelated issues. Employees must remain alert to potential signs of exploitation.
Where there are concerns that someone is a victim of modern slavery or human trafficking, the following procedure must be followed:
- Concern identified – This could involve a client as a victim or perpetrator, or a client raising concern about someone else.
- Immediate risk – If an individual or group is in immediate danger, the police must be called on 999.
- Escalation – The staff member must discuss the concern with their line manager (where appropriate) and notify the Designated Safeguarding Lead (DSL) immediately.
- Safeguarding referral – The DSL must escalate the concern to the Safeguarding Adults Team in the geographical area where the client lives.
Regulatory notification – A notification must be made to the Care Quality Commission (CQC) via the Provider Portal.
Recruitment Procedures
All staff engaged in providing services at Better Days UK will be subject to thorough and rigorous recruitment checks, including:
- DBS check
- Identity verification
- Confirmation of right to work in the UK
- Verification of full employment history
- Assessment of suitability for the role
- Professional references
These steps minimise the risk of employing someone who has been, or is, subject to slavery or human trafficking.
Better Days UK internal talent team follow PR16 – Right to Work Checks Policy and Procedure to ensure that recruitment is robust, compliant, and fair.
Use of Agency and Third-Party Staff
Better Days UK will only use staff provided by third-party organisations (such as recruitment agencies that):
- Are registered with the appropriate regulator, or
- Can confirm that staff being supplied are legally free to work in the UK and meet all requirements for the role.
This ensures that individuals providing services through third-party organisations are subject to the same safeguarding standards.
Reporting Concerns (“Whistle Blowing”)
Any employee who suspects modern slavery or human trafficking must report it immediately to their line manager or HR.
Reports may be made confidentially and will always be taken seriously. Concerns involving suppliers or contractors will also be investigated.
Better Days UK will protect whistleblowers from retaliation, disadvantage, or victimisation. All employees will be made aware of Better Days UK’s Whistleblowing Policy and Procedure, which provides a secure process for reporting concerns without fear or reprisal.
Record-Keeping
Better Days UK will maintain accurate records to demonstrate compliance with this policy, including:
- Risk assessments and supplier due diligence checks.
- Records of training and awareness sessions.
- Documentation of reports, investigations, and actions taken.
Records will be retained for a minimum of six years.
Training & Awareness
Better Days UK will take steps to ensure sufficient communication and employee awareness training is provided on modern slavery and human trafficking.
Employees must:
- Complete induction and refresher training on modern slavery awareness.
- Understand what constitutes exploitation and how to spot warning signs.
- Know how to report concerns through appropriate channels.
Additional training will be provided for employees in procurement, recruitment, and high-risk roles.
Breach of Policy
Failure to comply with this policy may result in disciplinary action, up to and including dismissal for gross misconduct. Where appropriate, Better Days UK will refer matters to external authorities.
Review
This policy will be reviewed annually, or sooner if required, by the Risk and Quality Committee. Updates will be communicated to staff, contractors, and partners as needed.
Legislation
Better Days UK is committed to full compliance with:
- Modern Slavery Act 2015
- Human Rights Act 1998
- Employment Rights Act 1996
- Equality Act 2010
- International Labour Organization (ILO) conventions on forced labour and child labour