Modern Slavery Statement

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Introduction

This statement sets out the Certitude Group’s actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions during the financial year 1 April 2020 to 31 March 2021 and covers the activities of the Certitude Group.

Organisational structure and supply chains

Certitude is London’s leading adult social care provider for people living with learning disabilities, autism, mental health support needs and their families and carers. We are a non-profit organisation who offer family support and advice, provide registered home support care and support people with autism to live their lives in ways that work for them. We support over 1,500 people in 16 London boroughs.

As a non-profit organisation, we recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we are absolutely committed to preventing any form of slavery in our activities.

We work and liaise with several suppliers around London making sure they respect the standard requested and the satisfaction of our people, ensuring that its supply chains are free from slavery and human trafficking.

Responsibility

Responsibility within Certitude for its anti-slavery initiatives is as follows:

Policies: The Whistelblowing Officer, in conjunction with the Leadership Team and relevant staff groups will review this policy from a legal and operational perspective annually.
Risk assessments:  Suppliers have to go through a supplier approval process (namely a risk assessment) which will be updated as and when new suppliers enter our supply chain.
Investigations/due diligence: The Whistleblowing Officer has day-to-day operational responsibility for this policy and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training and update.
Training:  We require all staff, supply chain managers within the organisation to complete the mandatory modern slavery e-training course.

Relevant policies

Certitude has in place the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

Speak Up – Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can contact the Whistleblowing Officer.
Expected Behaviour code: The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation works closely with the supply chain and liaise with them to ensure that they meet our minimum standard.
Supplier Expected Behaviour code: The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works closely with the supply chain and liaises with them to ensure they meet our minimum standard. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
Recruitment Agency policy: The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

Due diligence

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

evaluating the modern slavery and human trafficking risks of each new supplier
reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping
participating in collaborative initiatives focused on human rights
implementing sanctions against suppliers that fail to improve their performance or seriously violate our supplier code of conduct, including the termination of the business relationship.

Training awareness

As a result of the review of its KPI (key performance indicator) the organisation requires all staff, supply chain managers within the organisation to complete the e-learning course on modern slavery. This helps make people aware how to identify the signs of slavery and human trafficking, and what initial steps should be taken and how to assess the risk.

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, the organisation has raised awareness of modern slavery issues by using a range of media to promote awareness.

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