Anti-Slavery and Human Trafficking Statement

Anti-Slavery and Human Trafficking Statement
Introduction

Financial year 2020/2021

Introduction

This statement is made of behalf of the board of Salutem LD TopCo Limited with regards to the Modern Slavery Act 2015 which requires employers to be transparent about their efforts to eradicate slavery and human trafficking in their supply chain.

 

Our Structure and Business

Salutem LD Topco Limited, founded in April 2017, is the holding company of several companies operating across England and Wales in the specialist care space, including Pathways Care Group Limited, Clearwater Care (Hackney) Limited and Modus Care Limited.

The business provides specialist care and support to individuals living with complex health needs, a learning disability or mental health needs.

Each of our brands has a full infrastructure and support centre offering finance, HR, estates, legal, payroll, quality and governance services. This support function is shared with Ambito Care & Education – a sister brand to Pathways Care Group, Modus and Clearwater Care, operating under Salutem LD Topco II Limited. Ambito Care & Education provides care and support in various care settings, including educational settings, to individuals with physical and learning disabilities and complex health needs. We believe that by bringing together lots of specialist brands under one roof we can provide a better, more knowledgeable service for our clients.

Approximately 1400 staff work across all of the organisation’s brands in 75 care settings.

Our policies in relation to slavery and human trafficking

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 own business or in any of our supply chains.

To ensure our employees are not subject to undue influence and are treated with dignity and respect, we have robust HR policies and procedures in place across all our operations, including eligibility to work in the UK checks for all employees. These are regularly audited to ensure compliance with employment legislation and prevent unethical working practices. We are committed to ensuring that all staff receive fair remuneration for the job they perform and undertake regular reviews of terms and conditions across the workplace.

We have a formal anti-slavery and human trafficking policy in place and awareness of modern slavery/human trafficking responsibilities are shared with all new employees as part of their induction via inclusion in the staff handbook. Our employee app, Blink, provides direct access to this policy and the staff handbook.

Our suppliers

We procure a wide range of goods and services via a diverse supply chain, including the following:

  • Temporary/Agency staff
  • Property related services and materials (repairs and maintenance)
  • Communications and IT equipment services
  • Various professional services
  • Office equipment and supplies
  • Lease vehicles
  • Utilities and waste management

Based on published guidance from the GLAA we do not believe there to be any high risk operations within the work of Salutem and its supply chains with regards to modern slavery and human trafficking. We believe there is a potential for low risk in the supply chains in the provision of agency staff and building work.

When using agencies and other bodies associated with the employment of staff, we will ensure that steps are put in place to ensure that no modern slavery or human trafficking is taking place in these supply chains. As a matter of course we expect all agencies that supply staff to Salutem to ensure that all staff are vetted and screened in line with best practice and all applicable legislation to ensure the right to work in the UK and their identity using authentic and legal documentation, as well as assessing for any concerning behaviours that may require further review in line with combatting modern slavery.

Our whistleblowing policy encourages staff to report any bad practice, which extends to human rights violations like modern slavery, on a confidential basis and without fear of recrimination.

Our external Employee Assistance Programme provides confidential information and support by telephone on a wide range of subjects if staff have concerns they do not wish to discuss with their manager.

We are continuing to review our supply chain broadly to assess product, sector or geographical risks to help identify a clearModern Slavery Act profile of our Supply Chain. We will be ensuring that any suppliers we use either have a modern slavery statement in place or have completed our questionnaires in relation to modern slavery and human trafficking. We will evaluate the modern slavery and human trafficking risks of each new supplier as part of the procurement process. We are working to ensure that we work only with suppliers who treat their obligations towards modern slavery with the same importance that we do. This work will be monitored, and any areas of concern will be addressed; if appropriate the supplier will be suspended until we are satisfied with their commitment.

We will take appropriate action against any suppliers who have been suspended.

Since our 2020 statement no incidents of modern slavery or human trafficking have been identified or reported within our organisation and we have not had grounds to suspend any suppliers.

Specific e-learning training will be undertaken on a risk-based approach, in which those employees most likely to encounter issues are trained as priority.

This statement constitutes our Anti-Slavery and Human Trafficking Statement for the financial year ending 31 March 2021.
Date: August 2021

Signed by John Godden
Chief Executive Officer, Salutem LD Topco Limited

 

 

This statement covers Salutem LD TopCo Limited and its subsidiary companies as follows:

Salutem LD BidCo Limited
Salutem LD BidCo II Limited
Salutem LD BidCo III Limited
Salutem Shared Services Limited
Salutem Shared Services II Limited
Pathways Care Group Limited
Newlife Care Services (Holding) Limited
Newlife Care Services Limited
Modus Care Limited
Modus Care (Plymouth) Limited
Swan Village Care Services Limited
Minster Pathways (Colchester) Limited
Pathways 4 Care Limited
Pathways Daycare Limited
Hardriding House Limited
Clearwater Specialist Care Group Limited
Clearwater Specialist Care Partners Limited
Clearwater Specialist Care Enterprise Limited
Clearwater Care (Group) Limited
Clearwater Care (Hackney) Limited
Greenfield Close Residential Care
TL Care UK Limited
Amity Residential Care Limited

 

 

 

Anti-Slavery and Human Trafficking Statement
Introduction

Financial year 2020/2021

Introduction

This statement is made of behalf of the board of Salutem LD TopCo II Limited with regards to the Modern Slavery Act 2015 which requires employers to be transparent about their efforts to eradicate slavery and human trafficking in their supply chain.

 

 

Our Structure and Business

Salutem LD Topco II Limited, founded in March 2018, is the holding company for two companies operating across England and Wales in the specialist care space, Salutem LD BidCo IV Limited (trading as Ambito Care & Education) and Salutem ED BidCo Limited.

The business provides specialist care and support in various care settings, including educational settings, to individuals with physical and learning disabilities and complex health needs.

Each of our brands has a full infrastructure and support centre offering finance, HR, estates, legal, payroll, quality and governance services. This support function is shared with our sister brands Pathways Care Group, Modus and Clearwater Care, operating under Salutem LD Topco Limited. Pathways, Modus and Clearwater provide care and support to individuals with complex health needs, a learning disability or mental health needs. We believe that by bringing together lots of specialist brands under one roof we can provide a better, more knowledgeable service for our clients.

Approximately 1300 staff work across all of the organisation’s brands in 51 care settings.

Our policies in relation to slavery and human trafficking

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 own business or in any of our supply chains.

To ensure our employees are not subject to undue influence and are treated with dignity and respect, we have robust HR policies and procedures in place across all our operations, including eligibility to work in the UK checks for all employees. These are regularly audited to ensure compliance with employment legislation and prevent unethical working practices. We are committed to ensuring that all staff receive fair remuneration for the job they perform and undertake regular reviews of terms and conditions across the workplace.

We have a formal anti-slavery and human trafficking policy in place and awareness of modern slavery/human trafficking responsibilities are shared with all new employees as part of their induction via inclusion in the staff handbook. Our employee app, Blink, provides direct access to this policy and the staff handbook.

Our suppliers

We procure a wide range of goods and services via a diverse supply chain, including the following:

  • Temporary/Agency staff
  • Property related services and materials (repairs and maintenance)
  • Communications and IT equipment services
  • Various professional services
  • Office equipment and supplies
  • Lease vehicles
  • Utilities and waste management

Based on published guidance from the GLAA we do not believe there to be any high risk operations within the work of Salutem and its supply chains with regards to modern slavery and human trafficking. We believe there is a potential for low risk in the supply chains in the provision of agency staff and building work.

When using agencies and other bodies associated with the employment of staff, we will ensure that steps are put in place to ensure that no modern slavery or human trafficking is taking place in these supply chains. As a matter of course we expect all agencies that supply staff to Salutem to ensure that all staff are vetted and screened in line with best practice and all applicable legislation to ensure the right to work in the UK and their identity using authentic and legal documentation, as well as assessing for any concerning behaviours that may require further review in line with combatting modern slavery.

Our whistleblowing policy encourages staff to report any bad practice, which extends to human rights violations like modern slavery, on a confidential basis and without fear of recrimination.

Our external Employee Assistance Programme provides confidential information and support by telephone on a wide range of subjects if staff have concerns they do not wish to discuss with their manager.

We are continuing to review our supply chain broadly to assess product, sector or geographical risks to help identify a clearModern Slavery Act profile of our Supply Chain. We will be ensuring that any suppliers we use either have a modern slavery statement in place or have completed our questionnaires in relation to modern slavery and human trafficking. We will evaluate the modern slavery and human trafficking risks of each new supplier as part of the procurement process. We are working to ensure that we work only with suppliers who treat their obligations towards modern slavery with the same importance that we do. This work will be monitored, and any areas of concern will be addressed; if appropriate the supplier will be suspended until we are satisfied with their commitment.

We will take appropriate action against any suppliers who have been suspended.

Since our 2020 statement no incidents of modern slavery or human trafficking have been identified or reported within our organisation and we have not had grounds to suspend any suppliers.

Specific e-learning training will be undertaken on a risk-based approach, in which those employees most likely to encounter issues are trained as priority.

This statement constitutes our Anti-Slavery and Human Trafficking Statement for the financial year ending 31 March 2021.
Date: August 2021

Signed by John Godden
Chief Executive Officer, Salutem LD Topco II Limited

 

 

This statement covers Salutem LD TopCo II Limited and its subsidiary companies as follows:

Salutem LD BidCo IV Limited
Salutem ED BidCo Limited
Salutem Shared Services III Limited