Modern Slavery & Human Trafficking Policy

Policy Statement

This policy describes the values, principles and procedures that underpin Magnus Care’s approach to any situation where it becomes aware of, or has evidence of, involvement or the
risk of involvement, direct or indirect, in enterprises that subject people to conditions that meet
current definitions of modern slavery, human trafficking and forced labour. It applies to Magnus
Care and all other organisations with which it has dealings.

It is written in line with the safeguarding duties of local authorities under the Care Act 2014 (and equivalent applicable devolved government laws) to ensure any vulnerable adult is not subject to abuse by being a victim of modern slavery or forced labour, nor to any form of human trafficking or, for example, being coerced into such as “county line” drug trafficking.

It is also written to reflect the aims of the Modern Slavery Act 2015 that sets out the responsibilities and duties of corporate businesses and charities to prevent and avoid any dealings with any network or organisation implicated in modern slavery or human trafficking and to alert the police and other responsible authorities if they come across it. Magnus Care understands that unless its total annual turnover is over £36 million it will not be subject to the
Act’s annual reporting requirements.

Modern slavery includes, under its definition, forced and compulsory labour, human trafficking of
children and adults and organised activities that involve people being coerced, controlled and
exploited to carry out work to which they do not freely consent for the financial gain of their controllers.

Service Users

As a care service, we ensure no vulnerable young person or adult in our care is subject to any conditions that meet the Care Act (and similar) definitions of modern slavery. If Magnus Care
has any suspicions, information or evidence that any of its service users are victims of, or at risk
of, becoming victims of modern slavery, exploitation or forced labour, it will take immediate protective action by alerting the appropriate safeguarding authority or police and apply all
safeguarding procedures that then follow. (See also Magnus Care’s safeguarding policies.)
Staff.

We also do not employ staff under any conditions that might make us vulnerable to accusations or suspicions that we are employing people under conditions that would amount to modern
slavery and exploitation as defined. All staff are subject to recruitment procedures that comply
with both employment law and registration requirements with pay and conditions of employment
that meet all statutory requirements.

If we have evidence that any of our employees are subject to exploitation and forced labour by third parties, we will exercise our duty of care to our employees by reporting our concerns as whistleblowers to the police or local unit responsible for investigating modern slavery to decide
on further investigation or action. We will not act or discriminate against the employee if they are
meeting all the required employment conditions and had been recruited in line with Magnus Care’s recruitment procedures.

Contractors and Suppliers
At Magnus Care, we inevitably deal with several external organisations as suppliers of goods and services. We know that these organisations might form part of a longer supply chain. We make all reasonable efforts to ensure that no link in the supply chain is producing goods and services made under conditions of modern slavery or which might involve human trafficking.

We expect all our contractors and suppliers to have a similar zero tolerance and due diligence
approach to modern slavery and human trafficking and only work with organisations that have
robust anti-modern slavery policies that operate in other parts of their supply chain and who
comply with the Modern Slavery Act 2015.

We explain in our replies to businesses who respond to tenders and adverts for goods and services that we will check if they employ people under conditions of modern slavery and if they do similar checks with other businesses in their supply chain. In doing so, we expect those businesses to have taken all reasonable efforts to exclude their suppliers from colluding with modern slavery practices.

All staff members, particularly those responsible for procuring goods and services, are expected to report any concerns about any issue or suspicion of modern slavery in any parts of their
dealings at the earliest possible stage.
Anyone raising concerns about slavery or human trafficking that affects the care service will be
protected by Magnus Care’s whistleblowing policy.

Training

All staff are made familiar with the anti-slavery policy particularly in respect of the safeguarding
of vulnerable people and they are expected to report any concerns in line with Magnus Care’s safeguarding policies and procedures.

Staff responsible for the procurement of goods and services will receive training so that they can ensure that Magnus Care is never implicated in any dealings that would render it vulnerable to accusations or charges that it might have breached modern anti-slavery law and how to respond to any suspicions or evidence of breaches in the law.