Modern slavery
Modern Slavery and Human Trafficking Policy – SD Care Agency Group

Modern Slavery and Human Trafficking Policy and Procedure

1. Purpose

1.1 To ensure that everyone at San Damiano Corporation Ltd is aware of the Modern Slavery and Human Trafficking Policy and Procedure and the procedures in place to identify, respond appropriately and report in line with local and the national guidance. This policy refers to adults who may be at risk; the procedure for children is detailed in the Safeguarding Children and Child Protection Policy and Procedure.

1.2 This policy must be read alongside the Safeguarding Adults Policy and Procedure. San Damiano Corporation Ltd will ensure that staff understand Guildford Locality Team Adult Social Care and Waverley Borough Council safeguarding reporting procedures. Other related policies include Raising Concerns, Whistleblowing, Recruitment, Right to Work Checks, and Agency Staff policies.

1.3 Relevant Legislation

  • Health and Safety at Work etc. Act 1974
  • Human Rights Act 1998
  • The Health and Social Care Act 2008 (Regulated Activities) (Amendment) Regulations 2012
  • The Modern Slavery Act 2015

2. Scope

2.1 Roles Affected: All Staff, Registered Manager, and other management.

2.2 People Affected: Service Users.

2.3 Stakeholders Affected: Commissioners and Local Authority.

3. Objectives

3.1 To promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of San Damiano Corporation Ltd in addressing these issues in all forms. An annual statement will be produced, where applicable.

3.2 To ensure that identification, protection, care, and support for victims is at the heart of our safeguarding procedures.

4. Policy

4.1 Modern slavery is a crime and a violation of fundamental human rights, encompassing slavery, servitude, forced labour, and human trafficking.

4.2 San Damiano Corporation Ltd has a zero-tolerance approach. We will implement and enforce effective systems to ensure modern slavery is not taking place within our business or associated third-party agencies.

4.3 All staff are encouraged and supported to report any concerns to management. We will also support any staff member who may be a victim of such practices.

4.4 Where identified, we will share information with the Guildford Locality Team Adult Social Care and Waverley Borough Council Safeguarding Team to safeguard individuals and prevent future occurrences.

5. Procedure

5.1 Reporting Concerns

  1. Identification: A concern is identified regarding a Service User (as a victim or perpetrator) or via information provided by a Service User.
  2. Immediate Danger: If there is an immediate risk of harm, the police must be notified immediately on 999.
  3. Internal Reporting: Staff must discuss concerns with their line manager and Aleah Molejon (Deputy Manager) immediately.
  4. Escalation: The Deputy Manager will escalate the concern to Guildford Locality Team Adult Social Care and Waverley Borough Council Safeguarding Adults Team.
  5. Notification: A notification is made to the CQC via the provider portal.

5.2 Safer Recruitment

All staff are subject to rigorous recruitment procedures, including DBS checks, identity checks, confirmation of validity to work in the UK, employment history, and references. We only use third-party agencies that are registered or can confirm their staff meet all UK legal requirements.

5.3 Indicators of Modern Slavery (Training)

Staff are trained to recognize indicators, including but not limited to:

  • Individuals not being paid or being held in debt-bondage.
  • Passports or ID documents being held by an “employer.”
  • Signs of physical/psychological abuse, malnutrition, or untreated injuries.
  • Rarely being allowed to travel alone or appearing under the control of others.
  • Living in dirty, cramped, or overcrowded accommodation.
  • Avoiding eye contact and appearing frightened of law enforcers.

6. Definitions

6.1 Human Trafficking: The recruitment or receipt of persons by threat, force, or coercion for the purpose of exploitation.

6.2 Exploitation: Includes sexual exploitation, forced labour, domestic servitude, financial exploitation (debt bondage/scams), and criminal exploitation (County Lines).

7. Key Facts – Professionals

  • Annual statements will be published and signed by a Director where applicable.
  • Cases will be shared with the Multi Agency Safeguarding Hub (MASH): 0300 470 9100 / ascmash@surreycc.gov.uk.
  • Only staff through robust recruitment procedures will be employed.

8. Contact Information

If you have any questions or wish to report a suspicion, contact the Registered Manager or:

Email: info@sdcare.co.uk