This statement is made pursuant to Section 54 of the Modern Slavery Act 2015 and sets out the steps that (CSSL) has taken, and is continuing to take, to make sure that modern slavery or human trafficking is not taking place within our business or supply chain during the year ending 31st January 2025. 

CSSL is aware of our responsibilities towards Residents, service users, employees and the local community and expects all suppliers to the company to adhere to the same ethical principles. We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our internal policies replicate our commitment to acting ethically and with integrity in all our business relationships. 

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. CSSL has a zero-tolerance approach to any form of modern slavery. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the Company or our supply chain. 

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 have in common the deprivation of one (or more) person’s liberty by another in order to exploit them for personal or commercial gain. We have a zero-tolerance approach to modern slavery. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business. 

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. 

We expect the same high standards from all of our contractors, suppliers, and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards. Wherever possible we ensure contract specifications contain a provision around Good Industry Practice to ensure each supplier’s commitment to anti-slavery and human trafficking in their supply chains; and that they conduct their businesses in a manner that is consistent with CSSL anti-slavery policy. 

In addition, an increasing number of suppliers are implementing the Labour Standards Assurance System (LSAS) as a condition of contract for tenders within high-risk sectors and product categories and indeed this has been referenced in the Government’s Modern Slavery Strategy. Many aspects of the LSAS align to the seven reporting areas that the Government has outlined and should appear within any slavery and human trafficking statement. 

This policy therefore applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners (“stakeholders”). 

TO BE EXPLICIT, THIS POLICY DOES NOT FORM PART OF ANY EMPLOYEE’S CONTRACT OF EMPLOYMENT OR AN AGREEMENT WITH ANY STAKEHOLDER, AND WE MAY AMEND IT AT ANY TIME TO ENSURE IT MEETS THE NEEDS OF THOSE AT RISK! 

RESPONSIBILITY FOR THE POLICY

• The Operations Manager has primary and day-to-day responsibilities for implementing this policy, monitoring its use and effectiveness, and dealing with any queries.
• Management, at all levels, is responsible for ensuring those reporting to them understand and comply with this policy. They are also responsible for ensuring that staff involved in buying/procurement and the recruitment and deployment of workers receive training on modern slavery and ethical employment practices. 
• Stakeholders are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries are encouraged and should be addressed to the Operations Support Manager.

 Policies and Procedures to deliver compliance with the Modern Slavery Act 2015: 

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. We operate a number of internal policies and procedures that ensure we are conducting our business in an ethical, fair, and transparent manner. 

These include:

 Safeguarding Adults Policy: This sets out the Company’s stance on safeguarding vulnerable adults. Those who are victims of Modern Slavery are themselves Vulnerable Adults. The Policy gives direction on identifying abuse and explains how employees can identify any instances of this and where they can go for help.

1. Recruitment Policy: including conducting eligibility to work in the UK checks for all employees to safeguard against human trafficking or individuals being forced to work against their will.
2. Whistle-Blowing Policy: ensures that all employees know that they can raise concerns about how colleagues are being treated, or practices within our business or supply chain, without fear of reprisals.
3. The Nominated Individual and Chief Operating Officer will provide an annual anti-slavery statement to be published on the CSSL website. The anti-slavery policy will be reviewed annually as part of the continuous improvement processes, we have in place as part of our Quality Governance Process.
4. Induction for all employees covers the review of this policy. 
5. Each manager is responsible for ensuring all new employees are educated on the policy and our procedures for handling any concerns or queries or possible cases.
6. Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. 
7. Terms of business agreed with all suppliers and contractors will include requirement for the supplier/contractor to confirm there is no slavery activity within their organisation.

TRANSPARENCY: 

Stakeholders are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business at the earliest possible stage. If you are unsure about whether a particular act constitutes any of the various forms of modern slavery, raise it with the Operations Support Manager immediately. 

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Whistle Blowing procedure.