Modern Slavery Statement
This statement sets out the steps that Towerview Care has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or supply chain.
Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Towerview Care has a zero-tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically, with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains.
Towerview Care is a social care provider that offers care and support to people living with mental health and complex care needs. The 212 individuals we care for are primarily over 65 but we do also provide support to some adults of working age. We employ 497 staff members across 7 locations.
We support individuals with complex, challenging, mental, physical, and emotional needs by providing person-centered care and looking after the whole person; their emotional, social and care needs. We believe in celebrating life and focusing on what individuals can do, rather than what they cannot. Our opening hours of business are 24x7x365. Our services are regulated by the Care Quality Commission (CQC), Local Authorities (LA’s), Integrated Commissioning Boards (ICB) and Acute and Mental Health hospital settings.
Towerview Care implements their business strategy in an ethically, socially, and environmentally responsible manner. We fully acknowledge our responsibility to respect human rights as set out in the International Bill of Human Rights (IBHR). The IBHR structures all our policies related to the rights and freedoms of every individual employed, either as a direct employee or agency worker, or indirectly, through our supply chain. We are also committed to implementing the United Nations Guiding Principles on Business and Human Rights throughout our operations. Respect for the dignity of the individual and the importance of each individual’s human rights, form the basis of the behaviours we expect in every workplace nationally.
We will not accept any form of discrimination, harassment or bullying and all our managers will enforce the policies implemented by the company directorshich are designed to increase equality, opportunity and inclusion for all employees, including agency workers. We have also developed and implemented policies and processes which are intended to extend these commitments throughout our supply chains.
Policies
We have robust internal policies to ensure that we are conducting business ethically and transparently, which include:
Human Rights policy and our Ethics Policy where we confirm that we will not tolerate or condone the abuse of human rights within any part of our business or supply chains and will take seriously any allegations that human rights are not
properly respected.
Whistleblowing Policy, aimed principally at our employees but also available to others working in our supply chains which encourages staff to report any wrongdoing which extends to human rights violations like Modern Slavery. All reports will be fully investigated, and appropriate remedial actions are taken, and we will work closely with social care and health providers ensuring that our policies and procedures dovetail with local procedures and best practice
A robust recruitment policy, including compliance checks for everyone along with conducting eligibility to work in the UK to safeguard all.
Employee Code of Conduct which are guidelines we expect all employees to follow which aim to display our company values and show an expectation of how individuals should act whilst employed.
Direct Communication
The Company encourages members of the public or people not employed by us to write, in confidence, to raise any concern, issue or suspicion of modern slavery in any part of our business.
Suppliers
We conduct due diligence on all suppliers before allowing them to become a preferred supplier. Suppliers are required to confirm that no part of their business operations contradicts this policy. As part of our contract with suppliers, they are mandated to confirm that:
- They have taken steps to eradicate modern slavery within their business
- They hold their suppliers to account over modern slavery
- For UK based suppliers, they pay their employees at least the national minimum wage/national living wage (as appropriate) and to ensure that within their supply chains, where UK based suppliers have overseas supply chains, that their employees’ pay is consistent with their national minimum wage requirements, working conditions are safe and fair, there is no child labour and working hours are not excessive
- We may terminate the contract at any time should any instances of modern slavery come to light
Risk Assessments
Our supply chains include procurement of staff, consumables, facilities maintenance, utilities, equipment suppliers, premises servicing, food suppliers, waste management and professional services. We will conduct a risk assessment and will ensure that we will take further steps to ensure that we support the eradication of modern slavery, that staff understand how to recognise modern slavery and the appropriate safeguarding reporting processes are followed should there be concerns within our supply chains, with customers or suppliers.
Performance indicators
We use key performance indicators (KPI’s) to measure our effectiveness in ensuring that slavery and human trafficking is not taking place in any part of the business or supply chains. By carrying out regular quality audits along with the use of stringent staff monitoring and payroll systems we can identify and mitigate risk to all. The senior management team have complete oversight in these areas and routinely carry out audits to ensure compliance.
Safeguards
We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy. We are committed to ensuring that no one suffers any detrimental treatment because of reporting, in good faith, their suspicion that modern slavery of whatever form is or may be taking place in any part of our business. Towerview Care will accept and take seriously all concerns communicated and carry out necessary investigations to identify and resolve any such concerns. Any claims or allegations made which are found to be malicious or vexatious will result in disciplinary actions against the individual.
Identification and Management of Risk Areas
As a business we have joined the sponsorship program for employing international workers. As a risk area for potential modern slavery and human trafficking, procedures and compliance checks are in place to avoid such risks and ensure safety to all.
Key aspects that we follow to help diminish the risks to international workers are as follows:
- Before travelling to the UK, we check accommodation has been sourced
- Geographically, where applicable, employees will be in the vicinity of friends or family already resided in the UK – if they do not have any relations, we try to situate workers at branches with others of a similar cultural background/belief
- Upon arrival to the UK, the business allocates a mentor who will help in both work and adapting to the culture.
- Regular supervisions are carried out
- Opportunity for career growth is offered to all staff including international workers
- Home office regulations are followed
- We have an extensive induction program, which not only provides an understanding of the role’s requirements but provides guidance on new surroundings and offers key points of contact & areas of interest.
This combined with the continuous use of staff monitoring systems by the Employment Compliance and Payroll teams will aid control over the working environment and to ensure that slavery and human trafficking is not taking place at any stage of the sponsorship program and throughout the business.
Responsibility for this Statement
The ultimate responsibility for the prevention of modern slavery rests with the Chief Executive Officer (CEO) for ensuring that this policy and its implementation complies with our legal and ethical obligations. Managers at all levels are responsible for ensuring that those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery.
Assessment of effectiveness in preventing Modern Slavery
We understand that modern slavery risk is not static and will continue our approach to mitigating this risk. We will assess the risk via our internal auditing processes.
This statement is made according to section 54(1) of the Modern Slavery Act 2015 and constitutes the modern slavery and human trafficking statement of Towerview Care for the financial year ending 31 December 2022.
Approval for this statement
This statement was approved by Darren Stapelberg, CEO on 16th October 2023
Signed:
