Slavery & human trafficking statement
Healthcare Homes (Genesis) Limited and two of its subsidiaries – Healthcare Homes (Holdings) Limited and Healthcare Homes Group Limited – are commercial organisations that fall within the scope of Section 54 of the Modern Slavery Act 2015. These organisations must, therefore, publish an annual statement setting out the steps taken to prevent modern slavery in their business and their supply chains.
This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and relates to Healthcare Homes (Genesis) Limited (for the financial year ended 31st August 2020), Healthcare Homes Holdings Limited and Healthcare Homes Group Limited (for the financial year ended 30th September 2020). Its purpose is to confirm the arrangements we already have in place and also the steps we are taking to ensure the continued prevention of modern slavery and human trafficking across all of our operations and our supply chains.
Organisation Structure and Supply Chains
The Healthcare Homes Group operational services that fall under the Healthcare Homes (Genesis) Limited (as the ultimate parent company) company structure includes:
- Nursing and residential care homes. There are currently 39 care homes that operate under Healthcare Homes Group Limited, or its subsidiary Healthcare Homes (LSC) Limited. Healthcare Homes (LSC) Limited does not presently fall within scope of Section 54 of the Modern Slavery Act 2015, but its operations are managed in the same way as those of Healthcare Homes Group Limited in terms prevention of modern slavery and human trafficking.
- Homecare services, which trade as Manorcourt Homecare. Each week our teams currently deliver over 20,000 hours of care to people in their own homes.
Within the above nursing and residential homes and homecare services we employ c.3,650 staff. We also have an external UK-based supply chain, supplying us with a range of goods and services, including:
- IT support services
- Agency/temporary staffing
- Various equipment and consumables
- Food and beverages
- Waste disposal and shredding
If a current or potential supplier is required to publish a Modern Slavery Statement, we undertake checks in order to assess that supplier’s commitment and actions taken to prevent modern slavery within their own organisation and supply chains.
Each of our care homes and domiciliary care services is registered with our Regulator, the Care Quality Commission (CQC). The CQC places a number of stringent obligations on us in relation to deployment of workers, all of which we comply with in full.
Policies in relation to slavery and human trafficking and due diligence processes
Our policies and procedures are developed centrally and mandated for use within our operational services. Each policy is authored and owned by a director or senior manager, who is responsible for keeping it up to date with all applicable legislation, as well as for making sure changes are made to policies and procedures in order to respond to any risks or issues that are identified. Policies relevant to modern slavery and human trafficking are:
- Safeguarding Adults. This policy is owned by our Group Clinical Governance Director. It identifies and defines Modern Slavery and confirms how the Healthcare Homes Group will react to and manage any safeguarding concern raised, including a concern related to modern slavery or human trafficking.
- Recruitment and Selection. Owned by our Group HR Director, this policy mandates that pre-employment checks in accordance with CQC requirements and Safer Recruitment Guidance are undertaken for each applicant, which includes a check of formal photographic identification to assure that the applicant is of legal working age and has Right to Work in the UK. A DBS check is also undertaken before employees work unsupervised, which would identify any previous convictions that may present a risk to our staff teams, or those using or visiting our services.
- Speak Up protocol and Raising a Concern Policy, owned by our Group Clinical Governance Director.
‘Raising a Concern’ posters are displayed prominently at each of our sites, providing details of contacts within the organisation (outside the immediate line management structure) that workers can contact to report instances of concern, as well as external bodies such as the CQC. The posters confirm that anyone raising a genuine concern under this policy will not be at risk of losing their job or suffering any form of reprisal as a result. The Healthcare Homes Group does not tolerate the harassment or victimisation of anyone raising a concern. Nor will we tolerate any attempt to bully anyone into not raising any such concern. Any such behaviour is a breach of our values as an organisation.
Our operational services are required to engage agency/temporary workers via our preferred supplier list. Due diligence has been undertaken on these preferred agencies, including in relation to ensuring that employees have all required pre-employment checks undertaken, that working hours are not in excess of legal requirements and that they are paid at least National Living/Minimum Wage.
Risk Assessment and Management
Our Group Director of Property and Estates holds responsibility for ensuring that risk assessments are undertaken at all of our sites and for implementing necessary actions to ensure that our staff teams (as well as those who live within or visit our services) are able to work in a safe environment.
The Healthcare Homes Group has a well-established risk assessment programme in place. Not only do we respond to risks highlighted in our robust audit programme used to evidence compliance with the Health And Safety At Work Act 1974, this audit programme ensures we are also able to adapt and change our risk assessment process to any new risks emerging. We are then able to prioritise our responses to risk assessment.
The Healthcare Homes Group has a zero tolerance towards modern slavery and human trafficking. Any identified concern regarding modern slavery and human trafficking will be escalated as part of our safeguarding policies and procedures, and reported to appropriate external bodies such as the police, the Care Quality Commission, or the relevant local authority.
Key performance indicators (KPIs) to measure effectiveness of steps taken
The Healthcare Homes Group has not received any disclosures or identified any instances of modern slavery or human trafficking within the organisation or our external suppliers.
Training on modern slavery and human trafficking
- All staff are made aware from induction on how to raise a concern (whistleblowing) during their mandatory induction programme training.
- Safeguarding training is provided to all staff.
- Our Group Clinical Governance Director has undertaken Level 5 Safeguarding training and acts as our Safeguarding Lead.
During the financial period or year beginning 1st September 2020 (Healthcare Homes (Genesis) Limited) or 1st October 2020 (Healthcare Homes Holdings Limited and Healthcare Homes Group Limited) we will continue to monitor and assess risk through audit, review and due diligence.
This statement has been formally approved by the Board of Directors of Healthcare Homes (Genesis) Limited and signed on their behalf.