Modern Slavery Policy

Last updated: February 15, 2026

  • Description and Definitions
  • Scope of Policy
  • Policy Principles
  • Related Policies
  • Responsibility
  • Policy Review
  • Company Details

1. Description and Definitions

1.1 Slavery, Servitude and Forced or Compulsory Labour

A person commits an offence if:

(a) they hold another person in slavery or servitude and the circumstances are such that they know or ought to know that the other person is held in slavery or servitude; or

(b) they require another person to perform forced or compulsory labour and the circumstances are such that they know or ought to know that the person is being required to perform such labour.

These provisions shall be interpreted in accordance with Article 4 of the European Convention on Human Rights and the Modern Slavery Act 2015.

In determining whether a person is being held in slavery or required to perform forced labour, all relevant circumstances will be considered, including:

  • Personal circumstances such as age, vulnerability, illness, disability, or family situation

  • The nature of the work or services provided

  • Any evidence of exploitation or coercion

Consent of a person does not preclude a finding of slavery or forced labour.

1.2 Human Trafficking

A person commits an offence if they arrange or facilitate the travel of another person with a view to that person being exploited.

This includes:

  • Recruiting, transporting, transferring, harbouring, or receiving individuals

  • Exchanging or transferring control over individuals

It is irrelevant whether the individual consents to travel.

“Travel” includes:

  • Entering or leaving any country

  • Travelling within any country

This applies regardless of nationality where any part of the activity occurs within the United Kingdom.

1.3 Meaning of Exploitation

A person is considered exploited if any of the following apply:

  • Slavery, servitude, or forced labour

  • Sexual exploitation under applicable UK legislation

  • Removal of organs in breach of the Human Tissue Act 2004

  • Use of force, threats, or deception to obtain services or benefits

  • Exploitation of children or vulnerable individuals

2. Scope of Policy

This policy applies to:

  • All employees of A Smart Care UK LTD
  • All agency workers and contractors
  • All third parties engaged by the company, including suppliers and partners

3. Policy Principles

3.1 Commitment

A Smart Care UK LTD is committed to preventing modern slavery, human trafficking, forced labour, and all forms of exploitation within its operations and supply chains.

3.2 Ethical Recruitment and Staffing

As a healthcare staffing provider, we ensure that all staff supplied to care homes and organisations:

  • Are recruited lawfully and ethically
  • Have the right to work in the UK
  • Are not subject to coercion, exploitation, or forced labour
  • Are paid fairly and in accordance with UK employment laws

3.3 Safeguarding and Awareness

All staff receive appropriate training and awareness on:

  • Safeguarding vulnerable individuals
  • Identifying signs of exploitation or abuse
  • Reporting concerns appropriately

3.4 Reporting Concerns

All employees, workers, and third parties are encouraged to report any concerns or suspicions relating to modern slavery or exploitation.

Reports can be made to management or through internal reporting procedures.

3.5 Investigation and Action

All concerns are taken seriously and will be investigated promptly.

Where issues are identified, A Smart Care UK LTD will take appropriate action, including:

  • Working with relevant organisations to address concerns
  • Reporting matters to law enforcement or regulatory authorities where required

3.6 Compliance with UK Law

This policy is aligned with:

  • Modern Slavery Act 2015
  • UK employment legislation
  • Safeguarding and care sector regulations

4. Related Policies

This policy should be read alongside:

  • Safeguarding Policy
  • Whistleblowing Policy
  • Equality and Diversity Policy
  • Recruitment and Compliance Policy
  • Data Protection Policy

5. Responsibility

The Director of A Smart Care UK LTD is responsible for:

  • Ensuring compliance with this policy
  • Promoting ethical practices across the organisation
  • Reviewing and updating this policy as required

6. Policy Review

The Director of A Smart Care UK LTD is responsible for:

  • Ensuring compliance with this policy
  • Promoting ethical practices across the organisation
  • Reviewing and updating this policy as required

Company Details

Company Name: A Smart Care UK LTD
Policy Name: Modern Slavery Policy
Effective Date: 03/01/2026
Version: 1.0