Modern Slavery and Human Trafficking Statement 2023

Ingeus is fully committed to the requirements of the Modern Slavery Act 2015 and appreciates the significance of continually developing and improving our practices under these requirements. We have, and will, take a proactive approach to preventing modern slavery or human trafficking, and be strong in our reactions if any concerns are identified. 

Our organisational lead on Modern Slavery and Human Trafficking is:  

• Brian Sullivan, Head of Risk and Compliance  
• Email bsullivan@ingeus.co.uk 

The below outlines the steps Ingeus has taken to prevent modern slavery or human trafficking from occurring within our direct business delivery, or with our supply chain partners: 

• Identification of Key Modern Slavery Risks
• Involving programme participants   
• Supply Chain Delivery Partner practices  
• Implementation of a Safeguarding Policy that sets out the legislative requirements regarding our duty of care towards staff and participants and provides a clear reporting process for any identified safeguarding concerns. This includes any issues related to modern slavery or human trafficking.
• Implementation of a Modern Slavery Prevention and Reporting procedure which includes how to escalate any identified concerns relating to our supply chain.
• Staff complete a mandatory Modern Slavery training during induction and as part of annual refresher programme. 
• Implementation of a Staff Code of Conduct, ensuring employees are aware of responsibilities and ethical behaviours, required for the effective and appropriate delivery of services. It refers to our company values, human rights and duty of care.
• Implementation of an Equality and Diversity Policy that ensures we treat staff and participants with dignity and respect, irrespective of their protected characteristics. It also details how to take appropriate action if this is not occurring.  
• Implementation of an Equality, Diversity and Inclusion forum, which comprises of key colleagues across the business, this group reviews all aspects of our service delivery and operations to ensure we are truly inclusive.   
• Implementation of a safeguarding forum: that shares best practice and reviews issues related to safeguarding and modern slavery. 
• We assess the right of all staff to work in the UK. 
• Undertake staff personal wellbeing reviews. Line managers undertake regular 1:1s to assess their personal wellbeing. 
• Complete participant ID checks. All participants accessing our services are required to provide appropriate identification documentation at the start of their programme. Concerns are reported through the Modern Slavery Prevention and Reporting procedure.
• Completion of Supply Chain Due Diligence to ensure that there are no inappropriate practices across our delivery partners. Checks are undertaken of Partner recruitment, payment, contracting and HR practices.  We also review their own approaches to safeguarding and modern slavery, ensuring that there are appropriate identification and reporting processes in place and that staff are trained. 
• Annual completion of the Home Office, Modern Slavery assessment: We have completed this tool to determine our position against the assessment criteria. This has identified areas for improvement that we are reviewing and seeking to develop through 2023. 

Our Key Performance Indicators:   

• All staff to be trained during induction and then annually. 
• Complete due diligence of supply chain delivery partners prior to contract and then annually.  
• Review and update policy and statement annually.