Modern Slavery Policy

1. Statement

ExcelCare Agency does not tolerate modern slavery or human trafficking in any part of our business or supply chain. Modern slavery includes forced labour, debt bondage, human trafficking, domestic servitude and forced criminality. It is a crime, a serious safeguarding matter and a breach of human rights.

This statement is made under section 54 of the Modern Slavery Act 2015 and is reviewed and signed annually by the Board. Although the agency may fall below the statutory turnover threshold, we publish it voluntarily because our sector carries a real risk.

2. Risk in social care

Domiciliary care carries specific risks:

• a large, dispersed, low-paid workforce with high turnover
• recruitment through informal networks and social media
• overseas recruitment and sponsorship, where workers may be tied to one employer
• contracted cleaning, laundry and transport services
• people we support who are themselves vulnerable to exploitation by family members, "friends" or organised groups

3. Our workforce commitments

• We never charge a worker a fee for recruitment, training, uniform, DBS checks or sponsorship.
• We never retain a worker's passport, visa or other identity documents. Originals are verified and returned immediately, and only copies are retained.
• Every worker has a written contract, in a language they understand, setting out pay, hours, holiday and the right to leave.
• Wages are paid directly into the worker's own bank account, at or above the National Living Wage, with itemised payslips.
• Workers are told, in writing, that they can leave at any time and can raise a concern without fear — through our Whistleblowing Policy or to an external body such as the Modern Slavery Helpline, the Gangmasters and Labour Abuse Authority, or the police.
• We verify right to work in person, and never accept documents that appear to belong to someone else.
• No worker is required to live in accommodation tied to their employment, or to repay accommodation costs from wages without a written agreement.

4. Recruitment and sponsorship checks

For every appointment we verify identity, right to work, qualifications and references, and we interview in person or by video so the applicant can be seen and spoken to directly. Where we sponsor overseas workers, we:

• use a licensed sponsor process and pay all associated costs as required by the Home Office
• ensure the worker understands their rights, their rate of pay and their right to change employer
• never ask a worker to repay sponsorship costs
• monitor for signs of coercion in the first twelve months of employment

5. Supply chain due diligence

• All suppliers complete a labour standards questionnaire before appointment and annually thereafter.
• Contracts require compliance with the Modern Slavery Act, payment of at least the National Living Wage, and the right to audit.
• High-risk categories — cleaning, laundry, transport, IT equipment and uniforms — are reviewed annually with a documented risk rating.
• Any supplier unable or unwilling to evidence compliance is not appointed, or is removed from our list.

6. Recognising exploitation in the people we support

Signs may include:

• another person speaking for them, holding their documents or controlling their money
• unexplained injuries, fear, or reluctance to be alone with staff
• poor living conditions, malnutrition, or being denied access to healthcare
• unpaid work, or being made to care for others in the household
• a "friend" or relative who is unusually present, and who resists private conversation
• signs of debt, threats, or threats against family abroad

Staff never confront a suspected exploiter. They record what they observe and report it to the Registered Manager immediately.

7. Responding to a concern

1. Make the person safe and, where there is an immediate danger, call 999.
2. Report to the Registered Manager the same day, who applies our Adult Safeguarding Policy.
3. Refer the person to the National Referral Mechanism through the Single Competent Authority, with their consent where they have capacity to give it.
4. Notify the local authority safeguarding adults team, and CQC under Regulation 18 where required.
5. Consider immediate protection: a change of care arrangements, an advocate, and support to access healthcare and legal advice.
6. Record all actions, including the referral reference.

Modern Slavery Helpline: 08000 121 700 · Police: 999 (emergency) or 101

8. Training and reporting

All staff, managers and Board members complete modern slavery awareness training at induction and every two years, including how to spot the signs and how to refer. Recruitment and procurement staff receive additional training.

The Board reviews this statement and our supply chain assessment annually, and receives a report on any concerns raised, referrals made and actions taken.