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Modern Slavery and Human Trafficking Policy and Procedure

Implementation: 21/06/2022 Reviewed by: 21/06/2023
Scheduled review date: This policy will be reviewed annually or as per relevant legislation/guidance changes.


The purpose of this policy is to:

Ensure that everyone at Merseycare Julie Ann (MCJA) 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. Modern Slavery: Statutory Guidance for England and Wales (

Ensure that staff understand Liverpool City Council safeguarding reporting procedures and that these procedures are communicated to all staff.

This policy should be read in conjunction with other MCJA policies and procedures that relate to Modern Slavery and Human Trafficking including:

  • Whistleblowing Policy and Procedure
  • Recruitment Policy and Procedure
  • Right to Work Checks Policy and Procedure and the Agency Staff Policy and Procedure.
Key Question Key Line of Enquiry (KLOE)
SAFE S1: How do systems, processes and practices keep people safe and safeguarded from abuse?
WELL-LED W1: Is there a clear vision and credible strategy to deliver high-quality care and support, and promote a positive culture that is person-centred, open, inclusive, and empowering, which achieves good outcomes for people?
WELL-LED W2: Does the governance framework ensure that responsibilities are clear, and that quality performance, risks and regulatory requirements are understood and managed?

To meet the legal requirements of the regulated activities that MCJA is registered to provide:

  • The Modern Slavery Act 2015
  • 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 scope of this policy may affect individuals and/or stakeholders directly or indirectly, both internally and external to MCJA, and may include:

  • All staff
  • Registered Manager and/or other senior management
  • Service Users
  • Commissioners and/or Local Authority


The objectives of this policy are to:

  • Promote awareness of concerns surrounding slavery and human trafficking and promote the commitment of MCJA in addressing slavery and human trafficking in all its forms.
  • Ensure that identification, protection, care, and support for victims of modern slavery and human trafficking is at the heart of our safeguarding procedures.


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 include the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

MCJA has a zero-tolerance approach to modern slavery within the business and supply chains and we are committed to acting ethically and with integrity in all our dealings and relationships. We will implement and enforce effective systems and controls to ensure that modern slavery is not taking place anywhere within our services or within any third parties (agencies) that we are associated with.

All staff will be made aware of the issues surrounding slavery and human trafficking, whilst being encouraged and supported to report any concerns to Senior Management.

MCJA will also support any staff that may be subject to slavery or human trafficking.

Where modern slavery or human trafficking is identified, MCJA will share information with the Liverpool City Council Safeguarding Team to safeguard the individual from harm and with the objective of preventing future situations arising, to promote the elimination of routes and sources of slavery or human trafficking.

All line managers are responsible for ensuring that those reporting directly to them comply with the provisions of this policy in the daily performance of their roles. All employees who suspect any members of the workplace being victim of modern slavery must notify their line manager.

MCJA will take steps to ensure that sufficient communication and employee awareness training is undertaken with regards to Modern Slavery.

All employees will be made aware of MCJA’s Whistleblowing Policy and Procedure. The purpose of this policy and associated procedure is to enable MCJA to thoroughly investigate allegations of any wrongdoing raised by employees without fear of reprisal.

We will use this policy to underpin and inform any statement on slavery and human trafficking that we may be required to produce to meet the requirements of Section 54 of the Modern Slavery Act 2015 (MSA).


Reporting Modern Slavery and Human Trafficking Concerns

The following procedure must take place where there are any concerns that someone is a victim of modern slavery or human trafficking. MCJA will ensure that staff are aware that victims of modern slavery or trafficking will often not self-identify. Many will present with a different issue.

  1. A concern is identified -This could be a customer as a victim or perpetrator, or a customer informs us of a concern they
  2. If an individual is, or group of people are, in immediate risk of danger or harm, the police must be immediately notified on
  3. The staff member must discuss this with their line manager (where appropriate) and the Complaints Manager.
  4. The Complaints Manager will contact and escalate the concern immediately to Liverpool City Council Safeguarding Adults
  5. A notification will be made to the CQC via the provider portal.

Safer Recruitment

All staff engaged with providing services at MCJA will be subject to thorough and rigorous recruitment procedures that will include a DBS check, identity check, confirmation of validity to work in the UK, employment history, suitability for the role and references. This will minimise the chance of employing a person that has been, or is subject to, slavery or human trafficking. As part of this process MCJA’s Right to Work Checks Policy and Procedure will be adhered to ensure that a robust and fair process is followed consistently.

MCJA will only use staff provided by third-party organisations (such as agencies) that are either registered with the regulator or who can confirm that the staff being supplied are free to work in the UK and meet all the requirements for the role being provided for.


All staff will undertake training on Modern Slavery and Human Trafficking. This will ensure that they are aware of the indicators of modern slavery which include:

  • Individuals not being paid for the work they
  • Individuals being held in debt-bondage (being told they “Still” owe money after having paid off a previous debt).
  • An individual’s passport being held by their “employer” in order to keep the individual at
  • Multiple benefit claimants having their benefits being paid into the same
  • An individual not having the freedom of movement (i.e., passport being taken).
  • Clear exploitation of an individual by another for financial or sexual
  • Shows signs of physical or psychological abuse, look malnourished or unkempt, anxious/agitated or appear withdrawn and neglected. They may have untreated
  • Rarely be allowed to travel on their own, seem under the control, the influence of others, rarely interact or appear unfamiliar with their neighbourhood or where they
  • Relationships which do not seem right – for example, a young teenager appearing to be the boyfriend/girlfriend of a much older
  • Be living in dirty, cramped, or overcrowded accommodation, and/or living and working at the same address.
  • Have no identification documents, have few personal possessions, and always wear the same clothes day in and day out. What clothes they do wear may not be suitable for their
  • Have little opportunity to move freely and may have had their travel documents retained, e.g.,
  • Be dropped off/collected for work on a regular basis either very early or late at
  • Unusual travel arrangements – children being dropped off/picked up in private cars/taxis at unusual times and in places where it is not clear why they would be
  • Avoid eye contact, appear frightened or hesitant to talk to strangers and fear law enforcers for many reasons, such as not knowing who to trust or where to get help, fear of deportation, fear of violence to them or their

Staff will be advised that if they are subject to slavery or human trafficking, if they are aware of any individual that may be subject to slavery or has been trafficked, or if slavery or human trafficking is disclosed to them, they must inform the Registered Manager or the police.

Modern Slavery Annual Reporting during COVID

The Government guidance states that under section 54 of the Modern Slavery Act 2015, certain businesses are required to publish an annual modern slavery statement setting out the steps they have taken to identify and address their modern slavery risks. MCJA is currently exempt from having to produce this statement as it does not meet the turnover criteria required for reporting purposes.

During the coronavirus pandemic, it is essential that MCJA continues to identify and address the risks of modern slavery in operations and supply chains. As well as focusing on the health and safety of workers, MCJA will consider how fluctuations in demand and changes in the operating model may lead to new or increased risks of labour exploitation. Publish an annual modern slavery statement – GOV.UK (

Recruitment risks during COVID-19

We will ensure that rigorous recruitment checks are maintained and that our suppliers adhere to the same robust processes to ensure that vulnerable workers are not being exploited by third parties seeking to profit from heightened demand.

The Health and Safety of Workers

As a responsible organisation it is important that the relevant local or national government policies are implemented throughout the MCJA supply chain. As such we will ensure that suppliers adopt social distancing measures and pay statutory sick pay, to prevent the spread of coronavirus as part of due diligence processes.

Risk Assessment during COVID-19

We will undertake a risk assessment of how suppliers are operating during COVID-19 to highlight and help identify where there are risks of Modern Slavery or Human Trafficking occurring.

Review of Effectiveness

This organisation intends to take further steps to identify, assess and monitor potential risk areas in terms of modern slavery and human trafficking, particularly in the supply chains of our providers. We will also continue to:

  • Support our staff to understand and respond to modern slavery and human trafficking, and the impact that each and every individual working in care can have in keeping present and potential future victims of modern slavery and human trafficking
  • Gain assurance that all staff have access to training on how to identify victims of modern slavery and human
  • Review the Safeguarding Policy and Procedure to ensure that Modern Slavery and Human Trafficking are integral within the content and staff are directed to support and advice as needed.

Indicators of Forced Labour

Indicators of forced labour include:

  • Individuals may show signs of psychological or physical abuse. They might appear frightened, withdrawn or
  • Workers may not have free movement and may always be
  • Individuals often lack protective equipment or suitable clothing and have not been trained to safely fulfil the requirements of the
  • The person may not have access to their own documents, such as ID or their passport, with the employer having confiscated
  • Individuals may not have a contract and may not be paid National Minimum Wage or not paid at
  • Workers are forced to stay in accommodation provided by the employer. This accommodation could be overcrowded.
  • Individuals could live on site
  • Workers could be transported to and from work, potentially with multiple people in one
  • The person might not accept money or be afraid to accept
  • Workers may work particularly long hours.

Rosie Robinson
Registered Manager MCJA