Professional Comment

Dealing with the Modern Slavery Crisis in Care Homes

By Sejal Raja, partner in the Employment Law team at national law firm Weightmans (

The number of modern slavery cases reported within the UK care industry has more than doubled in the past year, with more than 100,000 cases estimated in the U.K, according to a recent report by the BBC. Care homes must do everything they can to ensure that modern slavery isn’t in their operations or their supply chain.

Not only is the reputational impact significant; there are also legal implications.

The Modern Slavery Act 2015 is designed specifically to ensure that businesses across all sectors are transparent in the way they tackle modern slavery and human trafficking. In light of the recent report, it is important that care homes examine their protocols and keep an open dialogue with their staff members.

Monitor and report
You can’t tackle a problem you don’t know exists, so the best way to start tackling modern slavery is increasing visibility over the issue. Many companies are legally required to do this. The Modern Slavery Act requires all commercial organisations with a global annual turnover of £36million or more to prepare a slavery and human trafficking statement each financial year which must clearly set out the ways they are tackling modern slavery. Even if your care facility isn’t legally required to produce one, it’s worth considering preparing such a statement and putting the same principles at the heart of your organisation.

These principles should include reviews of:
• your organisation’s structure and supply chains
• procurement and contract terms
• policies relating to slavery and human trafficking (for example, code of conduct, ethics, speak up policies, whistleblowing, and grievance procedures)

Think about the management implications, and training
Remember that your anti modern-slavery obligations are not over once the annual statement has been prepared and published. It is an on-going obligation and requires everyone in your organisation to be aware of best practices, be fully informed on what modern slavery is, and how to best prevent it.

Businesses should train and educate their employees on modern slavery to prevent its occurrence in the first place. Raising awareness of the issue and providing training on how to identify and report potential cases of modern slavery allows companies to take proactive steps to address the problem.

Seek outside help
In many cases, victims of modern slavery are immigrants in need of sponsorship. It can therefore be difficult for victims to report what is happening to them for fear of losing their job and right to work in the UK.

One way to overcome this is for businesses to use an outside third party to conduct independent audits and field concerns. This can provide comfort to employees to come forward and raise concerns.

Modern slavery is a prevalent issue that may occur at any point in the supply chain of a care home. Though it’s not the easiest thing to get a grip of, it is essential that care homes have a strong grasp over how modern slavery can manifest in their operations and be able to identify signs that an employee has fallen victim to it. By producing a statement, providing training for employees, and dealing with complaints and queries diligently, care homes will be able to take proactive steps to not only ensure compliance with any relevant laws, but also address and deal with the issue at hand – and avoid any reputational issues that would inevitably arise.