Anti-Slavery Policy 

Anti-Slavery Policy

Allegra Services Limited is a company within the Seniors Living Group Limited group of companies. This policy is  written to cover the business of Allegra Services Limited which is the oversight, management and development of  care and nursing homes acquired by investor partners. 

 

Policy Statement

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery,  servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation  of a person's liberty by another in order to exploit them for personal or commercial gain. We have a zero tolerance approach to modern slavery. 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 business. 

We are also committed to ensuring there is transparency in our own business and in our approach to tackling  modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery  Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners. As  part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or  trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our  suppliers will hold their own suppliers to the same high standards. 

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all  levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors,  external consultants, third-party representatives and business partners (“stakeholders”). 

This policy does not form part of any employee's contract of employment or an agreement with any  stakeholder, and we may amend it at anytime. 

 

Responsibility for the Policy 

  • The Operations Support Manager has primary and day-to-day responsibilities for implementing this policy,  monitoring its use and effectiveness and dealing with any queries. 
  • Management, at all levels, is responsible for ensuring those reporting to them understand and comply with  this policy. They are also responsible for ensuring that staff involved in buying/procurement and the  recruitment and deployment of workers receive training on modern slavery and ethical employment  practices.  
  • Stakeholders are invited to comment on this policy and suggest ways in which it might be improved. Comments,  suggestions and queries are encouraged and should be addressed to the Operations Support Manager. 

Policies and Procedures to deliver compliance with the Modern Slavery Act 2015

The prevention, detection and reporting ofmodern slavery inany part ofour business or supply chains is the  responsibility of all those working for us or under our control. We operate a number of internal policies and  procedures that ensure we are conducting our business in an ethical, fair and transparent manner. These include: 

  1. Anti-Slavery Policy: sets out the Company’s stance on modern slavery and explains how employees can  identify any instances of this and where they can go for help. 
  2. Recruitment Policy: including conducting eligibility to work in the UK checks for all employees to safeguard  against human trafficking or individuals being forced to work against their will. 
  3. Whistle-Blowing Policy: ensures that all employees know that they can raise concerns about how colleagues  are being treated, or practices within our business or supply chain, without fear of reprisals.
  4. The CEO will provide an annual anti-slavery statement to be published on the Allegra Services website. The  anti-slavery policy will be reviewed annually as part of the continuous improvement processes already in place (Policy Manual review). 
  5. Induction for all employees covers the review of this policy.  
  6. Each manager is responsible for ensuring all new employees are educated on the policy and our procedures  for handling any concerns or queries or possible cases. 
  7. Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this  policy has occurred or may occur in the future.  
  8. Terms of business agreed with all suppliers and contractors will include requirement for the  supplier/contractor to confirm there is no slavery activity within their organisation. 

 

Transparency

Stakeholders are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business at the earliest possible stage. If you are unsure about whether a particular act constitutes any of the  various forms of modern slavery, raise it with the Operations Support Manager immediately.  

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy,  even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your manager immediately. If the matter is not remedied, and  you are an employee, you should raise it formally using our Whistle Blowing procedure. 

 

Breaches of the policy 

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or  gross misconduct. 

We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

 

Version 1 February 2019 date reviewed September 2020 Approved H Jones