Modern Slavery Statement 2021

The Board of Trustees of The Disabilities Trust believe that driving out slavery in any form is fundamental to the aims of the Trust and, accordingly, have approved this statement.

The Disabilities Trust is a national charity and provider of specialist rehabilitation, care and support for adults with acquired brain injury, complex physical or learning disabilities and for people with autism, including those in education. Placements into our services are funded by local authorities, clinical commissioning groups and other organisations in the health and social sector, as well as directly by the individuals we support themselves.

The Trust has a zero-tolerance approach to any form of modern slavery and is committed to acting ethically, and with integrity and transparency in all business dealings. We are aware of our responsibilities towards service users, employees and the local community and expect all suppliers to the Trust to adhere to the same ethical principles.

The Trust has effective systems and controls in place to safeguard against any form of modern slavery or human trafficking taking place within the business or our supply chain. Risk registers are managed locally and corporately to manage risks and internal controls effectively and the Trust’s quality team monitor compliance via internal audits.

This statement outlines the steps The Disabilities Trust has taken and continues to take to understand and minimise the potential risk of modern slavery and human trafficking in its business and supply chains. This statement is published in line with section 54(1) of the Modern Slavery Act 2015, for the financial year ending 31 May 2021 and outlines our continuing commitment to tackle modern slavery in our business and supply chains.

Recruitment & Training
Our staff and volunteers are all based in the UK and are largely directly employed and generally not in any category which is seen to be vulnerable to modern slavery in this country.

The Trust operates a robust recruitment process outlined in the Recruitment Policy, including conducting eligibility to work in the UK checks for all directly employed staff. We have an approved framework which is audited by the recruitment team to provide assurance that pre-employment clearance has been obtained for staff, to safeguard against human trafficking or individuals being forced to work against their will. Compliance documentation is further checked, prior to the commencement of employment by all managers. Spot checks are completed by the Trust’s recruitment team on a weekly basis and reports are available for audit purposes for agency staff compliance.

The Trust utilises a managed agency provider to source temporary, fixed term and permanent employees which provides greater confidence in the workers we engage through them. As part of this contract, supplying temporary work agencies are audited against legislative compliance, including compliance with the Modern Slavery Act, and any legislative non-compliance is identified to clients. All temporary workers are supplied and documented through a software system which verifies the identity of each temporary worker and the worker’s right to work in the UK before supply commences.

The Disabilities Trust educates its employees regarding the types of factors which can indicate that a temporary worker may be subject to undue influence and actively encourages employees to report any suspicious activity. Modern slavery and human trafficking are covered within the Trust’s mandatory training which is based on the latest government guidance. All staff are required to complete the training on induction which includes a practical knowledge assessment on the subject.

Safeguarding & Whistleblowing
Modern slavery training is also covered in the safeguarding children and adults elearning module. Further advice can be found in our safeguarding policies and procedures and from safeguarding leads.

We adhere to the principles inherent within our policies for safeguarding children and adults. These are compliant with the Trust’s multiagency agreements and provide clear guidance so that our employees are aware of how they can raise safeguarding concerns about colleagues or service users or about practices within our business or supply chain.

The Disabilities Trust have a whistleblowing policy and a dedicated whistleblowing helpline for employees, in case of concerns about how colleagues or people receiving our services are being treated or about practices within our business or supply chain, without fear of reprisal. Our employees are also supported by an internal Freedom to Speak Up Guardian who provides independent support and advice to staff who want to discuss their concerns whilst also respecting their confidentiality.

Suppliers and third-party partners
The Disabilities Trust places importance on working with suppliers who treat their obligations towards modern slavery with the importance that we do. Our procurement teams ensure that suppliers are carefully selected through our supplier selection criteria/processes wherever practicable and endeavour to ensure that our suppliers and any third-party partners with whom we work are compliant with the requirements of the Modern Slavery Act 2015.

Over the coming year, our Procurement and Legal teams will:

  1. Include, within the Trust’s supplier contracts, clauses relating to our mutual legal obligations to tackle modern slavery within our respective businesses and, wherever practicable, work with suppliers and third-party partners that conduct their businesses in a manner that is consistent with the Modern Slavery Act 2015.
  2. Update the Trust’s supplier selection criteria/processes to include a review of the modern slavery statements of our suppliers and third-party partners as a part of our due diligence checks.
  3. Provide information on the Modern Slavery Act 2015 to those involved in procurement activity to assist in the understanding of the Act and provide awareness of the appropriate action to be taken if a case of slavery or human trafficking is suspected.
  4. Develop documented processes to ensure all staff are aware of their responsibilities when items are sourced locally.
  5. Implement an audit process to ensure we monitor compliance with procurement processes both locally and organisationally.

Approved by the Trustee Board on 27th September 2021

Stephen Howell

Chair of the Board of Trustees

For and on behalf of The Disabilities Trust