Modern slavery and human trafficking are criminal offences under the Modern Slavery Act 2015.

Our board agreed this updated modern slavery and human trafficking statement in March 2026.

Modern slavery and human trafficking are incompatible with our values. These include being caring and acting with integrity. We fully support the government’s objective to eradicate modern slavery and human trafficking.This statement clarifies our role in tackling modern slavery and human trafficking.

It covers:

• how health and social care services protect victims of modern slavery or human trafficking

• how we ensure modern slavery or human trafficking are not present in our supply chains.

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Modern slavery and human trafficking

Modern slavery and human trafficking are criminal offences under the Modern Slavery Act 2015.

 

The act includes the crimes:

• knowingly holding a person in a position of slavery, servitude, forced or compulsory labour

• facilitating their travel with the intention of exploiting them during or soon after.

 

Modern slavery and human trafficking can take place in a wide range of employment sectors, including health and social care. People using or working in a health and social care services may be victims of modern slavery or human trafficking. Health and social care organisations, such as Brown Clee Care have a role in identifying victims who come to them for care or treatment.

 

Our responsibilities

We fully align with the CQ statements and recognise our responsibility as:

 

• being regulated by health and adult social care in England

• a small to medium organisation employing more than less than 100 staff and limited procuring external services.

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As a company working in the public sector we must operate in ways that are compatible with the Human Rights Act (1998). These rights include the right for people to be free from slavery and forced labour under Article 4 Article 4 Human Rights Act 1998. We also have a duty to report criminal activity.

We have a responsibility to protect victims and a duty to report criminal activity.

Publishing this statement, and taking the actions we describe, helps us fulfil these duties.

 

Why modern slavery and human trafficking are relevant to Brown Clee Care

• All health and care services have a role to play in supporting victims of modern slavery and human trafficking. We have systems and processes to identify abuse and safeguard people from harm. People who are enslaved or trafficked should have the same high-quality care as any other person and be protected from abuse.

• We may find modern slavery happening in our service, or in associated services. These could be recruitment agencies or contractors.

 

Procurement and our supply chain

We employ under 100 staff and class as a Small to Medium Employer. However we have a responsibility to ensure our supply chains, procurement and business activities are free from ethical and labour standards abuses.Our commercial strategy includes the following steps to prevent modern slavery and human trafficking. We review this regularly.

 

• When we procure goods and services, we comply with UK legislation and government policies. We also apply our contract terms and conditions relating to modern slavery and human trafficking. These are in line with government policy thresholds and relate to the value and type of goods, services and commodities required.

• Brown Clee Care, due to less than £36 million turnover, are exempt from producing a modern slavery and human trafficking statement. But we still provide a policy statement for best practice.

• We carry out due diligence, this includes ensuring the suppliers have an up to date statement on their websites, or sign a disclosure form from Brown Clee Care. This is not a legal requirement, however it is good practice.

• Preventing modern slavery and human trafficking is included in our commercial strategy. We review this regularly.

• Procurement staff receive training to be able to apply good practice in preventing modern slavery and human trafficking and promoting social value as key tests. Social Value is constantly reviewed according to local and national frameworks.

 

Our people

We confirm the identities of all our new employees and their right to work in the UK. We also pay all our employees the National Living Wage or above.All staff hours and “second job” situation is monitoredWe support colleagues to raise concerns about poor working practices through our:

• bullying and harassment, grievance, and Speak Up policies

• staff and equality networks

• supervision processes with relevantly trained staff

• sign posting of vulnerable staff to relevant organisations