Modern Slavery and Human Trafficking Statement 2021
Introduction
Modern slavery encompasses slavery, human trafficking, forced labour and domestic
servitude.
St Anne’s is committed to preventing modern slavery in any of its corporate activities
and supply chains. This statement is made pursuant to section 54 of the Modern
Slavery Act 2015. It sets out the actions and activities that have taken place during
the financial year 1 April 2019 to 31 March 2020 to ensure that there is no slavery or
human trafficking in our organisation and supply chains.
It covers the activities of both St Anne’s Community Services and our subsidiary St
Anne’s Trading Ltd.
Our Organisation
St Anne’s was founded in 1971 as a shelter for homeless men in Leeds and gradually
expanded over the years to become the organisation it is today, with around 1,500
staff supporting over 1,300 people across the North of England.
We support people with learning disabilities, mental health issues, substance use and
misuse and homelessness to help them achieve their aspirations and to live their best
life possible.
We provide housing and accommodation-based care and support in partnership with
other housing providers and we deliver a range of community-based services.
A Company registered by guarantee, we are regulated by the Care Quality
Commission, the Regulator of Social Housing and The Charity Commission.
St Anne’s Trading Ltd. is a subsidiary company. It is accredited by the British Institute
of Learning Disabilities to provide specialist “Positive Behaviour Support” training and
delivers training nationally throughout the United Kingdom, including Wales and
Northern Ireland.
Our staff are largely directly employed and are not in any category which is generally
seen to be vulnerable to modern slavery in this country, so our focus is to ensure there
are policies and procedures in place for our contractors and suppliers.
Our Supply Chain
St Anne’s is committed to continuously improving its practices to identify and eliminate
any slavery and human trafficking in its business and supply chains, and to acting
ethically and with integrity in all its business relationships.
Our range of suppliers is vast and having reviewed our business, those which we deem
to be most at risk from Modern Slavery are providers of building, maintenance and
cleaning contractors, and IT equipment providers and suppliers. Our staff look to
procure goods from reputable and suitable organisations.
Policies and Control
St Anne’s take a robust approach and operates the following policies to assist the
identification and support steps to be taken to prevent modern slavery and human
trafficking in our operations and procurement of services.
• Procurement Policy
We expect our suppliers to have internal policies and processes in place to meet
the Modern Slavery Act 2015. A supplier without these policies in place will not
meet our minimum requirements and will therefore not be used. A supplier with
policies in place but found not to be adhering to them may have their contract
terminated. We have several small providers who we would expect to sign up to
related polices.
• Safeguarding Policy
Our safeguarding policy provides clear guidance to staff on the different types of
exploitation covered under the Modern Slavery Act and how to report a suspicion.
• Whistle-blowing Policy
Our Whistle-blowing policy provides clear guidance on how to make a disclosure
and sets out how whistle-blowing concerns are addressed and how the whistleblower is supported.
• Recruitment and Selection Policy
As a responsible employer we have safe and robust selection and recruitment
procedures in place, including conducting UK eligibility to work checks for all
employees to safeguard against human trafficking or individuals being forced to
work against their will. We monitor this on an annual basis to assure ourselves of
its effectiveness.
Due Diligence
As part of our due diligence with any new suppliers we require them to confirm their
compliance with relevant legislation which includes Modern Slavery Act.
We use only specified, reputable employment agencies to source labour and always
verify the practices of any new agency before accepting workers from that agency.
We have a number of senior level staff who are trained and would be responsible for
carrying out Root Cause Investigations (RCI) in relation to any suspected instances of
modern slavery or human trafficking within St Anne’s.
Training
We have risk assessed our staff requirement for training. All our staff that have any
involvement in procurement are required to attend face to face training. We have also
identified some members of staff who work with client groups that may be exploited
under the Modern Slavery Act 2015 and they are also required to attend face to face
training.
Further Actions 2020/21
We plan to implement an annual review of our suppliers’ compliance with their policies
under the Modern Slavery Act and ensure they understand our requirements on an
ongoing basis.
We plan to continue to provide information, training, and support for our staff as
appropriate ensuring they understand the legislation and feel confident to report
concerns.
We plan to strengthen the number of “Speak up” Guardians and local champions.
We plan to increase the range of systems and tools to support and to increase the
confidence to people to speak up.
Board Approval
This statement has been approved by the Board of Trustees of St Anne’s Community
Services who will review and update it annually.
Please see below the link to our Modern Slavery and Human Trafficking Statement – 2021.
Modern Slavery Statement March 2021