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Anti-Modern Slavery Policy


1.1. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.


1.2. CareCo (UK) Limited has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery and human trafficking is not taking place anywhere in our own business or in any of our supply chains.


1.3. CareCo (UK) Limited is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery and human trafficking throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners and to ensure they comply with our values we have in place a supply chain compliance programme. We also have in place systems to: identify and assess potential risk areas in our supply chains; mitigate the risk of slavery and human trafficking occurring in our supply chains; monitor potential risk areas in our supply chains; and protect whistleblowers. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.



2.1. This policy applies to all persons working for CareCo (UK) Limited or on our behalf in any capacity, including employees at all levels, Directors, Officers, Agency Workers, Seconded Workers, Volunteers, Interns, Agents, Contractors, External Consultants, Third-party Representatives and Business Partners.


2.2. This policy does not form part of any employee’s contract of employment and CareCo (UK) Limited may amend it at any time.



3.1. Employees must ensure that they have read, understand, and comply with this policy.


3.2. The prevention, detection and reporting of modern slavery and human trafficking in any part of our business or supply chains is the responsibility of all those working for us or under our control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.


3.3. Employees are encouraged to raise concerns about any issue or suspicion of modern slavery and human trafficking in any parts of our business or supply chains of any supplier tier at the earliest possible stage.


3.4. Employees must notify their line manager or Head of Quality & Compliance as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future.


3.5. If an Employee believes or suspects a breach of this policy has occurred or that it may occur, they must notify their manager or Quality & Compliance department, or they can report it in accordance with internal processes as soon as possible.


3.6. If an Employee is unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of CareCo (UK) Limited’s supply chains constitutes any of the various forms of modern slavery or human trafficking, they are aware that they can raise it with their manager or the Quality & Compliance Department.


3.7. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. CareCo (UK) Limited is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery and human trafficking of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern.



4.1. Training on this policy, and on the risk our business faces from modern slavery and human trafficking in its supply chains for our staff, will be provided as necessary.


4.2. Our zero-tolerance approach to modern slavery and human trafficking must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.



5.1. Any person working for CareCo (UK) Limited who breaches this policy will face disciplinary action in line with internal processes, which could result in dismissal for misconduct or gross misconduct.


5.2. CareCo (UK) Limited may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.