Purpose

This statement applies to U in Mind Care Limited management, all employees, and suppliers.
It is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out U in Mind Care Limited approach to dealing with the potential risk of human slavery and trafficking (as defined in the Act) occurring in any parts of its business.
U in Mind Care Limited is strongly opposed to slavery and human trafficking, and we will not knowingly support or do business with any organisation that is involved in either of these activities. This commitment is underpinned by our approach to procurement and supplier management activities generally, which require our businesses to undertake due diligence upon the suppliers whom we engage. This approach is complemented by our other corporate policies such as the Whistleblowing Policy, Recruitment Policy, Anti Bribery and Corruption Policy and Conflicts of Interest Policy among many others.

What is Slavery?

The Modern Slavery Act (MSA) 2015 covers four activities:

• Slavery – Exercising powers of ownership over a person
• Servitude – The obligation to provide services is imposed using coercion
• Forced or compulsory labour – Work or services are exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily
• Human trafficking – Arranging or facilitating the travel of another person with a view to their exploitation

Identifying Slavery

There is no typical victim and some victims do not understand they have been exploited and are entitled to help and support. However, the following key signs could indicate that someone may be a slavery or trafficking victim:

• The person is not in possession of their own passport, identification, or travel documents.
• The person is acting as though they are being instructed or coached by someone else.
• They allow others to speak for them when spoken to directly.
• They are dropped off and collected from work.
• The person is withdrawn, or they appear frightened.
• The person does not seem to be able to contact friends or family freely.
• The person has limited social interaction or contact with people outside their immediate environment.

This list is not exhaustive.
Remember, a person may display several of the trafficking indicators set out above, but they may not necessarily be a victim of slavery or trafficking. Often you will build up a picture of the person’s circumstances which may indicate something is not quite right. If you have a suspicion, report it to the HR Department who will follow our reporting procedures.

How Is It Relevant to U in Mind Care Limited?

• Modern slavery is a complex and multi-faceted crime and tackling it requires many organisations and individuals to play a part. The MSA 2015 recognises the important part businesses can and should play in tackling slavery and encourages them to do more.
• At a very basic level, preventing exploitation and human trafficking, and protecting our workforce and reputation makes good business sense.
• With this in mind, we pay close attention to our supply chain, especially those areas which have historically proven to be at risk such as outsourced activities like cleaning, waste management and hiring of staff including carers and support workers
  etc.

U in Mind Care Limited Responsibilities:

• Maintain clear policies and procedures preventing exploitation and human trafficking and protecting our workforce and reputation.
• Be clear about our recruitment policy
• Examine our supply chains and be clear with key suppliers our expectations regarding the Act
• Completing appropriate checks on all employees, recruitment agencies, suppliers, etc to ensure we know who is working for us
• Ensure we have in place an open and transparent grievance process for all staff
• Seek to raise awareness so that our colleagues know what we are doing to promote their welfare
• Make a clear statement that we take our responsibilities to our employees and our clients seriously.
• Raise the awareness and ensure all employees are provided a copy of this policy and be aware of their responsibilities.

Recruitment Processes:

U in Mind Care Limited will always ensure staff are able to legally work in the UK and all staff have a written contract of employment. U in Mind Care Limited Recruitment Policy will be followed, completing DBS checks, reference checks and providing information to all new recruits on their statutory rights including sick pay, holiday pay and any other benefits they may be entitled to. If, through our recruitment process, we suspect someone is being exploited, HR will be informed, and U in Mind Care Limited reporting procedures will be followed accordingly.

Recruitment Using Agencies:

The Company follows a clear recruitment policy and only uses reputable recruitment agencies. U in Mind Care Limited expects all recruitment agencies we engage to fully comply with the Modern Anti-Slavery Act 2015.

• Are free from ethical ambiguities
• Are transparent, accountable, and auditable.
• If the Company has reason to believe that any recruitment agency has failed to meet these standards, HR should be informed and any contracts with them would be terminated.
• We keep the agencies we use under regular reviews.

Supply Chains:

U in Mind Care Limited will uphold all laws relevant to countering bribery and corruption in all the jurisdictions it conducts business, including, in the UK and abroad.
Our standard terms and conditions include reference to compliance with the Modern Slavery Act and an obligation on suppliers to sign up to our Supplier Code of Conduct. This code includes statements that we will respect human rights, that we won’t engage in or support child labour, and that we will employ only workers who are legally allowed to work in the UK.

Monitoring Our Procedures:

We will review our Anti-slavery policy regularly, at least annually. We will provide information and/or training on any changes we make.