The 不良研究所 Group is committed to preventing the existence or prospect of modern slavery and human trafficking in its corporate activity and supply chains. We are committed to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls, to ensure slavery and human trafficking is not taking place anywhere in our organisation or supply chains.
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and highlights the key activities we have taken during the financial year 1 April 2023 to 31 March 2024 to minimise the risk of modern slavery or human trafficking in our organisation or supply chains. We, 不良研究所 Ltd, are the parent company of the “不良研究所 Group” which is made up of the following group trading companies:
- 不良研究所 Ltd;
- 不良研究所 Solutions Limited; and
- Affina Organisation Development Limited.
Our organisation
不良研究所 is a private company limited by guarantee and a charity registered in England and Wales. We are the strategic workforce development and planning body for adult social care in England. We work with employers, Government, and partners to ensure social care has the right people, skills, and support required to deliver the highest quality care and support, now and in the future. Our role is to respond and adapt to the emerging trends and needs within social care, using data and evidence to drive forward widescale change. We provide best practice, tools, resources, and intelligence to support workforce recruitment, capabilities, and culture. All our work is collaborative. By working with our partners, we are able to bring together a vast array of expertise, support, and influence – which in turn increases the impact and reach of our work.
We are part of 不良研究所 and Development which is an alliance of key organisations from England, Northern Ireland, Ireland, Scotland and Wales with varied roles across social care, social work, and early years and with remits across workforce development and regulation.
Our policies on slavery and human trafficking
We have the following policies in place that reflect our commitment to acting ethically and with integrity in all our business relationships and enforcing effective systems and controls to prevent modern slavery and human trafficking. Our policies set out our approach to identifying the risks of modern slavery and human trafficking and the steps we take to prevent it in our operations.
Anti-Slavery and Human Trafficking Policy: sets out our commitment to preventing slavery and human trafficking in our corporate activity and supply chains and the steps we take to ensure any risk is mitigated. It also covers the responsibilities of the organisation and employees in realising this commitment, the risks identified and procedures in place to mitigate these risks.
Procurement Policy: we expect our suppliers to have processes in place to meet the Modern Slavery Act 2015 and we check this during our supplier due diligence checks. Smaller suppliers who are not required to meet the needs of the Modern Slavery Act 2015 need to show a commitment to the principles of this Act. Suppliers who do not meet our minimum requirements will not be contracted with.
All relevant supplier contracts contain an anti-slavery clause. This clause, which flows down through all layers of our supply chain, prohibits suppliers and their employees from engaging in slavery or human trafficking and includes an obligation to comply with all relevant legislation.
A code of conduct is contained within this policy to set out how we observe public procurement ethics.
Whistleblowing Policy: we are committed to maintaining the highest possible standards of honesty, openness and accountability and recognise that individuals have an important role to play in achieving this goal. It is important that any fraud, misconduct or wrongdoing is reported and properly dealt with, and we actively encourage employees to be empowered to report any concerns relating to the activities or supply chain of the organisation. This includes concerns around the risk of slavery and human trafficking.
Safeguarding Policy: as we work closely with adult social care employers and people who access care and support, we encourage staff to take action within the parameters of this policy if they observe something which could constitute neglect or abuse, which includes slavery and human trafficking.
Recruitment Policy: we operate a robust recruitment policy, including conducting UK eligibility to work checks for all employees.
We continuously review and update all our policies.
Due diligence processes in our supply chain
We have a broad range of suppliers, and our supply chain includes organisations within the Adult Social Care sector, for example suppliers of:
- consultancy services
- training providers
- research and evaluation
Typically, we deal with recognised suppliers that have ethical policies that meet at least our minimum expectations. Further details of the requirements for suppliers are set out above in “Our policies on slavery and human trafficking”.
We also engage with businesses to provide ordinary business support, for example suppliers of:
- temporary staff
- cleaning and maintenance services
- legal services
- audit and accountancy services
- suppliers of office stationery and equipment
- suppliers of computer peripherals and systems (both hardware and software)
These tend to be engaged locally, as the need arises. We only use reputable agencies to source any short-term staff.
We have identified the following areas as those that give rise to the highest modern slavery risks: short term agency staff, cleaning and maintenance contractors, and third-party suppliers.
As part of our initiative to identify and mitigate risk, the implementation of our policies and procedures includes due diligence on suppliers that we engage with, in accordance with our Procurement Policy. Any new suppliers are required to confirm compliance with relevant legislation including the Modern Slavery Act, and we have asked existing suppliers to confirm this too.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide annual mandatory training to our staff.
This statement has been approved on behalf of the 不良研究所 Board on 16 July 2024, and it will be reviewed and updated annually.