Policy Statement

This statement sets out Regent College’s and National Care Group’s actions to understand all potential modern slavery risks related to its organisation and to ensure steps are in place 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 and activities for the financial year ending 31st March 2023.

We recognise that we have a responsibility to take a robust approach to slavery and human trafficking and we continue to take our responsibility very seriously.  National Care Group is committed to preventing slavery and human trafficking in its activities, and to ensuring that its supply chains, including sub-contractors and partners, are free from slavery and human trafficking

For the avoidance of doubt, the term NCG throughout this statement refers to National Care Group and all constituent companies managed under the NCG operational management structure, including Regent College.

Organisational structure and supply chains

This statement covers the activities of NCG.  Through its network of locally managed services, NCG supports over 1200 individuals with complex support needs including mental health, learning disabilities, and acquired brain injury in both residential care and supported living settings across England and Wales as well as providing adult learning services within our specialist further education college.

As part of the organisation’s due diligence processes into slavery and human trafficking, our supplier approval process will incorporate a review of the controls undertaken by our suppliers.  Imported goods from sources outside of the UK and EU are potentially more at risk for slavery/human trafficking issues.  The level of management control required for these sources will be regularly monitored.  We will not support or deal with any business knowingly involved in slavery or human trafficking.

Taking action 

As part of our procurement process, we will only engage with suppliers, contractors, and partners who confirm their compliance with the Act. Responsibility for our anti-slavery initiatives is as follows:

• Supply chain assessments: – We have reviewed the risks that our supply chains can present and whilst we consider our exposure to modern slavery to be limited, we expect our suppliers and contractors to demonstrate a zero-tolerance approach to exploitation. To this end, all new contracts and those renewing, now include a clause requiring our suppliers and their subcontractors, comply with the Modern Slavery Act 2015 (the Act).
• Investigations/due diligence: – As part of our procurement process, we will only engage with suppliers and contractors who confirm their compliance with the Act.
• Training: – We have re-promoted our existing Group policies to incorporate modern slavery and human trafficking issues, including in our Whistleblowing policy which allows colleagues and workers to report any concerns confidentially. Colleagues are required to complete modern slavery and human trafficking awareness training as part of their mandatory training program to increase their awareness of modern slavery and human trafficking so that they are able to understand, identify and be able to report on these risks.  Training content is reviewed regularly to ensure it is up to date and incorporates any legislative amendments.

Relevant policies/processes

We operate the following policies that describe our approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations:

• Whistleblowing policy: – We encourage all our workers, customers, and other business partners to report any concerns related to the direct activities, or the supply chains of, our organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. Our whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Colleagues, customers, or others who have concerns can use our confidential helpline.
• Colleague Code of Conduct: – Our code makes clear to colleagues the actions and behaviour expected of them when representing our organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.
• Purchasing Policy: – We are committed to ensuring that our 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. We work with suppliers to ensure that they meet the standards and improve their worker’s working conditions. However, serious violations of our policy will lead to the termination of the business relationship.
• Recruitment and Agency workers: – We use only specified, reputable employment agencies and verify the practices of any new agency before accepting workers from that agency.

Due diligence

We undertake due diligence when considering taking on new suppliers. Our commitment is to include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking.
• 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.

Awareness-raising programme

We have raised awareness of modern slavery issues by circulating our Modern Slavery Statement via our website and intranet accessible to all colleagues/workers.

This statement was approved in August 2022 by our board of directors, who review and update it annually.