HALCYON CARE (GLOUCESTERSHIRE) LTD

Company No. 13145833

HALCYON CARE (CUMBRIA) LTD

Company No. 15099759

Modern Slavery and Human Trafficking Policy – UPDATED OCTOBER 2026

For the purposes of this policy, HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD are collectively referred to as “Halcyon Care” or “the organisations”.

1. Policy Statement

HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD are committed to preventing modern slavery, servitude, forced labour, compulsory labour, debt bondage, child labour and human trafficking in all aspects of their operations and supply chains.

We recognise our responsibilities under the Modern Slavery Act 2015 and are committed to conducting business ethically, transparently and with integrity. We maintain a zero-tolerance approach towards modern slavery and human trafficking and expect the same standards from all employees, workers, contractors, suppliers, recruitment agencies and business partners.

As care providers, HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD are committed to safeguarding vulnerable individuals and ensuring that all workers are treated fairly, with dignity and respect, and are free from exploitation.

2. Purpose

The purpose of this policy is to:

• Prevent modern slavery and human trafficking within the organisations.
• Protect employees, service users, contractors, agency workers and stakeholders from exploitation.
• Ensure compliance with applicable legislation and regulatory requirements.
• Establish procedures for identifying, reporting and responding to concerns regarding modern slavery.
• Promote awareness and understanding of modern slavery risks and indicators.

3. Scope

This policy applies to:

• Directors and senior management.
• Permanent and temporary employees.
• Agency workers.
• Volunteers and apprentices.
• Contractors and consultants.
• Suppliers and service providers.
• Recruitment agencies and employment businesses.

The policy applies to all activities undertaken by HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD.

4. Definition of Modern Slavery

Modern slavery is a serious crime and a violation of fundamental human rights. It includes:

Human Trafficking

The recruitment, transportation, transfer, harbouring or receipt of individuals through force, coercion, deception or abuse for the purpose of exploitation.

Forced or Compulsory Labour

Work or services extracted from individuals under threat, coercion, intimidation or punishment.

Servitude

A situation in which a person is forced to live and work for another person and is unable to leave.

Debt Bondage

A person being forced to work to repay a debt under unfair or exploitative conditions.

Child Labour

The exploitation of children through work that interferes with their education, health, development or wellbeing.

5. Organisational Commitment

Halcyon Care will:

• Operate in compliance with all relevant legislation and regulations.
• Promote ethical business practices throughout both organisations.
• Ensure fair treatment of all employees and workers.
• Maintain transparent recruitment and employment procedures.
• Carry out appropriate right-to-work and identity checks.
• Prohibit the withholding of personal identification documents.
• Encourage the reporting of concerns without fear of retaliation.
• Investigate all allegations promptly and appropriately.
• Provide training and awareness to employees and managers.

6. Recruitment and Employment Practices

To reduce the risk of modern slavery and exploitation, Halcyon Care will:

Recruitment

• Conduct fair and lawful recruitment processes.
• Verify the identity of all employees and workers.
• Conduct right-to-work checks in accordance with legal requirements.
• Ensure all workers understand the terms of their employment.

Employment Contracts

All employees and workers will receive:

• A written contract or statement of employment.
• Clear information regarding pay, working hours and responsibilities.
• Information regarding grievance and whistleblowing procedures.
• Access to organisational policies and procedures.

Pay and Working Conditions

Halcyon Care will:

• Pay employees in accordance with applicable wage legislation.
• Ensure workers receive fair pay for work undertaken.
• Provide safe and healthy working conditions.
• Ensure working hours comply with legal requirements.
• Prohibit unlawful deductions from wages.

7. Supply Chain Responsibility

HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD expect suppliers, contractors and business partners to operate ethically and responsibly.

The organisations will:

• Work with reputable suppliers and service providers.
• Seek assurances that suppliers comply with applicable employment laws.
• Encourage suppliers to implement measures to prevent modern slavery.
• Review supplier relationships where concerns arise.
• Take appropriate action if evidence of exploitation is identified.

Business relationships may be terminated where serious breaches of ethical standards are discovered.

8. Identifying Signs of Modern Slavery

Employees should remain alert to potential indicators of exploitation, including:

Employment Indicators

• Workers appearing fearful, anxious, withdrawn or intimidated.
• Individuals who seem controlled by another person.
• Workers lacking access to personal identification documents.
• Excessive working hours without adequate rest.
• Signs of physical abuse, neglect or poor living conditions.
• Employees who are reluctant to speak openly about their circumstances.

Service User Indicators

• Unexplained restrictions on freedom of movement.
• Signs of coercion, intimidation or control by another individual.
• Concerns regarding financial exploitation.
• Evidence suggesting abuse, neglect or trafficking.

No single indicator confirms modern slavery; however, all concerns should be reported and investigated appropriately.

9. Reporting Concerns

All employees, workers and representatives of HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD have a responsibility to report concerns regarding modern slavery or human trafficking.

Concerns should be reported to:

• A Line Manager.
• The Registered Manager.
• A Director.
• The Safeguarding Lead.

Where there is an immediate risk to safety, emergency services should be contacted without delay.

All reports will be treated seriously, investigated appropriately and handled confidentially wherever possible.

10. Investigation and Response

Upon receiving a report or concern, Halcyon Care will:

• Assess any immediate risks to individuals.
• Take appropriate safeguarding action where required.
• Conduct a proportionate investigation.
• Cooperate with relevant authorities and agencies.
• Maintain accurate records of concerns and actions taken.
• Implement corrective measures to prevent recurrence.

The welfare and safety of potential victims will remain a priority throughout the process.

11. Protection for Individuals Raising Concerns

HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD encourage employees and stakeholders to raise concerns in good faith.

No individual will be subjected to:

• Victimisation.
• Harassment.
• Discrimination.
• Unfair treatment.

for reporting genuine concerns relating to modern slavery or human trafficking.

Any retaliation against an individual who raises a concern will be treated as a serious disciplinary matter.

12. Training and Awareness

Halcyon Care will provide appropriate training and awareness programmes to help employees:

• Understand modern slavery and human trafficking.
• Recognise warning signs and indicators.
• Understand safeguarding responsibilities.
• Know how to report concerns effectively.
• Comply with legal and regulatory requirements.

Training may be refreshed periodically to ensure continued awareness and compliance.

13. Roles and Responsibilities

Directors and Senior Management

Responsible for:

• Promoting ethical business practices.
• Ensuring compliance with this policy.
• Supporting effective implementation throughout both organisations.

Managers

Responsible for:

• Monitoring compliance within their areas of responsibility.
• Responding appropriately to concerns.
• Supporting employees who raise concerns.

Employees and Workers

Responsible for:

• Complying with this policy.
• Remaining vigilant to signs of exploitation.
• Reporting concerns promptly.
• Participating in relevant training.

14. Monitoring and Review

HALCYON CARE (GLOUCESTERSHIRE) LTD and HALCYON CARE (CUMBRIA) LTD will regularly monitor the effectiveness of this policy and associated procedures.

The organisations will:

• Review recruitment and employment practices.
• Monitor reported concerns and outcomes.
• Evaluate training and awareness initiatives.
• Update procedures where necessary to maintain compliance and best practice.

This policy will be reviewed periodically and updated where necessary to reflect changes in legislation, regulatory guidance or organisational practices.

15. Related Policies

This policy should be read in conjunction with:

• Safeguarding Adults Policy.
• Safeguarding Children Policy.
• Whistleblowing Policy.
• Recruitment and Selection Policy.
• Equality and Diversity Policy.
• Grievance Policy.
• Disciplinary Policy.
• Complaints Policy.

16. Conclusion

HALCYON CARE (GLOUCESTERSHIRE) LTD (Company No. 13145833) and HALCYON CARE (CUMBRIA) LTD (Company No. 15099759) are committed to maintaining the highest standards of ethical conduct and ensuring that modern slavery and human trafficking have no place within their operations, workforce or supply chains.

All employees, workers and business partners share responsibility for upholding these principles and helping to protect vulnerable individuals from exploitation.