1. Purpose

This policy outlines disAbility Cornwall & the Isles of Scilly’s commitment to preventing modern slavery, human trafficking, and illegal working within our operations and supply chains. It is designed to align with the Modern Slavery Act 2015 and the Immigration, Asylum & Nationality Act 2006.

2. Scope

This policy applies to all employees, volunteers, contractors, suppliers, and business partners of disAbility Cornwall & IoS.

3. Our Commitment

We are committed to acting ethically and with integrity in all our business dealings and relationships. We will not tolerate modern slavery or human trafficking in any form and we actively monitor our employment and procurement practices to prevent it. Our organisation’s turnover is under £36 million; therefore, we are not legally required to publish a Modern Slavery Statement, but we voluntarily uphold these principles as part of our ethical obligations.

4. Employment and Recruitment Practices

• All recruitment is carried out in line with our Equality, Diversity & Inclusion and Recruitment policies.
• Right to Work checks are conducted before employment begins, and temporary work rights are monitored to ensure renewals are secured in time.
• We use Home Office guidance and Identity Document Validation Technology (IDVT) where applicable.
• All documentation is retained for at least two years after employment ends.
• Staff are trained to conduct these checks consistently to avoid any discriminatory practice.

5. Supply Chain Standards

• We expect our suppliers to uphold ethical standards and we are working toward including specific anti-slavery clauses in supplier contracts.
• Contractors and suppliers must not engage in any form of forced, bonded, child or compulsory labour.
• Suppliers must ensure their own suppliers follow these same standards.

6. Reporting and Whistleblowing

• Staff, volunteers or contractors can report concerns anonymously and in good faith without fear of retaliation.
• Detrimental treatment such as dismissal, threats or discrimination for reporting concerns will not be tolerated.
• Concerns should be raised via the Whistleblowing Procedure or to the Designated Safeguarding Lead.

7. Associated Policy and Legislation

• Modern Slavery Act 2015
• Immigration, Asylum & Nationality Act 2006
• Home Office Employer Right to Work Checks Guidance
• Code of Practice on Preventing Illegal Working
• Equality, Diversity & Inclusion Policy
• Recruitment & Selection Scheme
• Whistleblowing Policy
• Safeguarding Policy

8. Breaches of This Policy

• Employees who breach this policy may face disciplinary action up to and including dismissal.
• We reserve the right to terminate contracts with suppliers, contractors or partners who are found to be in breach of this policy.

9. Monitoring and Continuous Improvement

• We conduct internal reviews of recruitment and procurement procedures to ensure compliance.
• Staff receive training on modern slavery awareness.
• We aim to evolve our due diligence practices, particularly in supplier engagement and monitoring.
• This policy is reviewed by the Governance & Compliance Officer, HR Officer, & Internal Operations Lead annually, or sooner if legislation changes and approved by the CEO.

10. Equality and Human Rights Statement

This policy has been reviewed for its impact on equality and human rights. It supports our organisational commitment to inclusion, diversity, and fairness for all employees and stakeholders.