Modern Slavery Policy

Gardiner's Homecare Limited

Financial Year Ending: 2026

Introduction

Gardiner's Homecare Limited is dedicated to providing compassionate and professional care that enables our clients to live independently and with dignity in their own homes. We are steadfast in our commitment to upholding the highest ethical standards in all our business activities. We have a zero-tolerance approach to modern slavery and human trafficking in our organisation and our supply chains. We are committed to acting with integrity and transparency in all our business dealings and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within our own business or in any of our supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the current financial year.

Our Business, Structure, and Supply Chains

Gardiner's Homecare is a provider of domiciliary care services across Berkshire and Oxfordshire. Our dedicated team of trained care workers provides a range of services, from companionship and domestic support to complex personal care.

Our business structure is centred around our head office in Reading, Berkshire, from which we manage our care operations, recruitment, training, and administrative functions. The majority of our employees are permanent care staff, directly employed by Gardiner's Homecare.

Our supply chains are relatively short and primarily based in the UK. They include:

  • Recruitment Agencies: For the sourcing of temporary or permanent care staff, when required.
  • Personal Protective Equipment (PPE) and Uniforms: Sourcing of gloves, aprons, masks, and branded workwear from UK-based suppliers.
  • Cleaning and Sanitation Products: Procurement of supplies for use in clients' homes and for our operational needs.
  • Office Supplies and Technology: Standard equipment for our administrative functions.
  • Professional Services: Including legal, accountancy, and IT support.

We recognise that the highest risk of modern slavery within our sector lies in the recruitment and management of staff, particularly concerning the use of third-party agencies and the recruitment of workers from overseas.

Our Policies on Slavery and Human Trafficking

We are committed to ensuring there is no modern slavery or human trafficking in our business or our supply chains. Our internal policies reflect our commitment to acting ethically and with integrity. Key policies that support this commitment include:

  • Anti-Slavery and Human Trafficking Policy: This policy sets out our zero-tolerance position and the responsibilities of all employees in preventing modern slavery.
  • Recruitment and Selection Policy: This outlines our robust procedures for hiring, including mandatory 'Right to Work' checks, identity verification, and thorough referencing to ensure all employment is voluntary.
  • Whistleblowing Policy: We provide a confidential and safe mechanism for our employees and business partners to report any concerns about wrongdoing or malpractice, including any suspicions of modern slavery.
  • Safeguarding Policy: Our staff are trained to recognise, report, and respond to signs of abuse and neglect, and this includes an understanding of how modern slavery can manifest as a safeguarding concern for both our clients and our colleagues.
  • Code of Conduct: This sets out the standards of behaviour expected from all staff, reinforcing our commitment to ethical conduct.

Due Diligence and Risk Management

As part of our initiative to identify and mitigate risk, we have in place the following systems:

  • Employee Checks: We conduct enhanced Disclosure and Barring Service (DBS) checks and verify the right to work in the UK for all direct employees. We ensure that staff are paid at least the National Living Wage and that wages are paid directly into a personal bank account in the employee's name.
  • Supplier Vetting: We strive to build long-standing relationships with our suppliers and make clear our expectations of business behaviour. When onboarding new suppliers, particularly those in high-risk areas such as recruitment, we undertake due diligence to ensure they share our values and have their own robust anti-slavery policies. We require our recruitment agency partners to confirm they adhere to all relevant legislation and ethical recruitment standards.
  • Contractual Obligations: We are working towards including clauses in our contracts with suppliers that require them to comply with the Modern Slavery Act 2015.

We have identified that the principal risks are associated with recruitment agencies providing workers who may have been subjected to exploitation, such as the charging of illegal recruitment fees creating debt bondage. Our due diligence processes are designed to mitigate this risk by working only with reputable, audited agencies.

Measuring Effectiveness

We understand the importance of measuring the effectiveness of the steps we are taking. We will track the following Key Performance Indicators (KPIs):

  1. Staff Training: our office and management staff, particularly those involved in recruitment and procurement, will complete modern slavery awareness training.
  2. Supplier Compliance: We will aim to have all our key suppliers confirm their compliance with the Modern Slavery Act 2015.
  3. Reported Incidents: We will maintain a central record of any concerns raised related to modern slavery and the actions taken. The effectiveness of our policies will be measured by the absence of any identified instances of modern slavery in our operations.

Training and Awareness

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 training to our staff. Our modern slavery training covers:

  • The basic principles of the Modern Slavery Act 2015.
  • How to identify the signs of slavery and human trafficking.
  • What steps to take if slavery or human trafficking is suspected.
  • The role of our organisation and individual employees in preventing modern slavery.

This training is integrated into the induction process for all new office-based staff and is refreshed annually.

Approval

This statement has been approved by the Board of Directors of Gardiner's Homecare Limited, who will review and update it annually.