Modern Slavery Act 2015

STATEMENT AND POLICY

Business and supply chain

Porthaven is an independent provider of elderly care. Porthaven currently manages 15 care homes in England and delivers, with integrity, high standards of care to its Residents within high quality facilities.

Porthaven builds its own homes and purchases a range of goods and services including clinical equipment, food and drink, waste disposal services and office supplies. These products are used in the provision of care to its Residents.

Porthaven has a large number of suppliers and supply chains which makes the supply chain complex. Porthaven prioritises attention on the companies that supply the largest amount of products and services, particularly those critical to the business.

Outlined below is Porthaven’s position on slavery and human trafficking which is reviewed annually to monitor risk assessments, supplier engagement and staff training.

Statement

Porthaven is committed to acting ethically and with integrity in all its business dealings, and to enforce systems that are in place to prevent modern slavery. Porthaven is transparent in its approach and expects the same level of transparency from suppliers to the business. Porthaven’s suppliers are required to comply with the law and their policy to combat the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. Porthaven expects its suppliers to hold their suppliers to the same standards.

Checking compliance

Porthaven is reviewing its supplier’s compliance statements, with priority being given to the larger suppliers. There will be follow up if there is insufficient or unsatisfactory compliance. All new suppliers will have to confirm explicitly that they comply with the Modern Slavery Act 2015.

Where a supplier does not comply, Porthaven will initially try to work with that supplier to assist them in improving their practice. If the supplier is unwilling to amend their practice Porthaven will review the use of that supplier.

Recruitment

Porthaven operates a robust recruitment policy, including conducting checks to establish eligibility to work in the UK for all directly-employed staff. Agencies, approved by Porthaven, are audited to provide assurance that pre-employment clearance has been obtained for agency staff, to safeguard against human trafficking or individuals being forced to work against their will.

Equal opportunities

Porthaven has a range of controls to protect staff from poor treatment and or exploitation, which comply with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities.

Safeguarding policies

Porthaven adheres to the principles inherent within both safeguarding children and adults policies. These are compliant with the multiagency agreements of the Clinical Commissioning Groups that Porthaven works with. They provide clear guidance so that employees are clear on how to raise safeguarding concerns about how colleagues or people receiving the care services are being treated, and about practices within the business or supply chain.

Whistleblowing policy

Porthaven operates a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving care are being treated, and about practices within the business or supply chain, without fear of reprisals.

Training

Porthaven’s staff handbook sets out the behaviours expected from its staff which include respect and acting fairly.

Porthaven provides mandatory training for safeguarding of children and adults where advice is given regarding modern slavery and human trafficking. This training is part of the staff induction and is updated annually. In addition there are safeguarding policies and procedures. All Porthaven staff who work face to face with suppliers will receive training to raise awareness on the requirements of the Modern Slavery Act 2015 and will be required to support the continuous risk assessment related to this.

Porthaven is looking at ways to continuously increase awareness within its organisation, and to facilitate a high level of understanding of the risks involved with modern slavery and human trafficking in its supply chains and in the business.

Reporting of incidents

Staff who suspect that modern slavery may be taking place within Porthaven must report this to their line manager or use the Porthaven whistleblowing policy. Any concerns raised will be taken seriously, investigated and responded to appropriately. Any request for confidentiality will be respected to the extent possible under the applicable law and regulation.