This is the public version of this policy. Details of our contracts with commissioning local authorities and some security arrangements are left out. Commissioning local authorities can ask us for the full version.

1. Purpose

Modern slavery includes slavery, servitude, forced or compulsory labour and human trafficking. It happens in ordinary businesses and supply chains, and it happens to children, including through criminal exploitation and county lines.

This policy sets out how we make sure nobody working for us or for our suppliers is exploited, how we buy ethically and locally, and how staff recognise and report exploitation affecting the young people and families we work with.

2. Scope

This policy applies to all Care Cove Alternative Provision staff, volunteers and SWMC members; to agency and partner staff; to everything we buy; to our partners and subcontractors; and to the employers who host learners on work placements and tasters.

3. Law and contract

Modern Slavery Act 2015. Makes slavery, servitude, forced or compulsory labour (section 1) and human trafficking (section 2) criminal offences. Section 54 requires organisations with a turnover of £36 million or more to publish an annual slavery and human trafficking statement. Care Cove is below that threshold, so a published statement is not required, but we commit to the same principles.
Ethical codes for suppliers. We observe the ethical codes of conduct for suppliers of the local authorities that commission our places. The Director keeps a copy of each current code with this policy, checks our practice against it every year and briefs staff on any changes.
Employment and right to work. We are fully responsible as employer, including tax and National Insurance; every worker must have the right to work in the UK under the Immigration, Asylum and Nationality Act 2006 and Home Office guidance, with all necessary checks carried out; we must not breach the Employment Relations Act 1999 (Blacklists) Regulations 2010; and our subcontractors must comply too.
Subcontracting. Subcontracts must include 30-day payment terms and impose the same obligations we have. We may subcontract only with the commissioning local authority's express prior written consent.
Keeping Children Safe in Education 2026 and Working Together to Safeguard Children 2023, on child criminal exploitation, child sexual exploitation and trafficking.

4. Roles and responsibilities

Role	Responsibilities
Director	Owns this policy and the annual review of our workforce and supply chain. Agrees supplier and partner terms. Handles concerns about workers or suppliers and tells the commissioning local authority where its contract is affected.
Head of AP	Makes sure recruitment and right-to-work checks are completed. Checks work placement employers before any placement.
Administrator	Records right-to-work checks on the Single Central Record. Keeps supplier records and the purchase ledger analysis used to monitor local spending.
DSL	Leads the response to any sign that a learner or family member is being exploited, including referral to the Sheffield Safeguarding Hub.
SWMC	Ratifies this policy and reviews the annual statement of steps taken.
Everyone	Knows the signs of exploitation and reports concerns the same day.

5. Our commitments

Although we are not required to publish a statement, the Director prepares a short annual statement of the steps we have taken under this policy (our structure and supply chain, policies, checks, risks identified, training and any concerns raised), approved by the SWMC and available to commissioning local authorities on request.

6. Our own workforce

Safer recruitment. Every check in the Safer Recruitment policy is completed before anyone works with a learner, and recorded on the Single Central Record.
Right to work. We check every worker's right to work before they start, using original documents or the Home Office online service, and keep a copy. Where permission to work is time-limited, we diarise and repeat the check before it expires.
Fair pay and treatment. Everyone is paid at least the legal minimum wage, into a bank account in their own name, with proper deductions for tax and National Insurance. Nobody is charged a fee for a job with us.
No control of documents. We never keep anyone's passport or identity documents; we take copies and return the originals.
Warning signs. Managers watch for signs that a worker may be controlled by someone else: several workers sharing one bank account or address, someone else collecting their pay or doing the talking for them, no access to their own documents, or seeming afraid. Concerns go to the Director the same day.

7. Agency workers

Supply and cover staff come from First Class Teachers. The agency confirms its checks in writing, including right to work, before anyone starts, and every agency worker is on our Single Central Record. Our written agreement with the agency must require it to pay its workers lawfully, never to charge them fees for finding work, to follow this policy and to tell us about any concern. We will not use any other agency without the same written assurances and, where it amounts to subcontracting, the commissioning local authority's written consent.

8. Suppliers, partners and subcontractors

8.1 Knowing our risks

Most of our spending is local and low risk. Higher-risk areas for us are cleaning and facilities services, building work, transport, food, sports kit and equipment, and ICT hardware, where goods may be made overseas. Among work placement sectors, construction, hospitality, beauty and nail services, and car washing are recognised as higher risk for labour exploitation.

8.2 Due diligence

Before we use a new regular supplier, or any supplier in a higher-risk area, we check that it is a genuine business, ask how it checks right to work and pays its staff, whether it uses its own subcontractors or agencies, and whether it has a modern slavery policy or statement.
Before any work placement or taster, we visit the employer, sign a placement agreement and risk assessment, check the supervisor and verify employer's liability insurance, as the Work Experience and Vocational Placements policy requires. During the visit, staff also look for signs of labour exploitation. If there are concerns, no learner is placed and the Director decides whether to report them.

8.3 Contract terms flowed down

Written agreements with partners and subcontractors must require them to comply with the Modern Slavery Act, check right to work, follow the ethical codes of conduct for suppliers of commissioning local authorities and our anti-bribery terms, tell us about any concern, and let us check compliance. Subcontracts also carry the same obligations we have under our contracts with commissioning local authorities.

8.4 Prompt payment

We pay subcontractors no later than 30 days after we confirm that their invoice is valid and undisputed, and require them to do the same for their own subcontractors. We aim to pay all small local suppliers to the same standard, because late payment pushes risk down the supply chain.

8.5 When something is wrong

If a supplier or partner will not answer our questions or put things right, we stop using it. If we suspect exploitation, we report it (section 10).

9. Recognising exploitation of learners and families

Many of our learners are at higher risk of exploitation. Children can be trafficked within the UK, including to sell drugs through county lines, and children who are exploited are victims even when they have been made to commit offences.

Signs include unexplained money, phones or clothes; going missing or travelling to other towns; new older friends or a boyfriend or girlfriend; unexplained injuries; carrying drugs or weapons; owing money; and fear or secrecy. A parent or carer may also be a victim of labour exploitation.

Every learner has an exploitation screening and contextual risk map at entry, reviewed monthly. We stagger arrivals and departures, supervise transitions, and tell the commissioning local authority when a mix of placements creates risk.

If you are worried:

Tell the DSL immediately and record the concern on Care Cove Connect the same day. If a child is in immediate danger, call 999.
The DSL refers to the Sheffield Safeguarding Hub (0114 273 4855) under the Safeguarding and Child Protection policy.
Where trafficking or modern slavery is suspected, the DSL asks children's social care or the police to consider a referral to the National Referral Mechanism (NRM), the national framework for identifying and supporting victims. Care Cove is not a designated first responder, so we refer through the local authority or police. A child does not need to consent to an NRM referral.
If a learner goes missing, staff follow the Attendance and Children Missing Education policy immediately.
Where an adult family member may be a victim, the DSL considers the safeguarding implications for the child and makes sure the adult is offered support through the Modern Slavery Helpline or the police.

10. Reporting concerns about workers or suppliers

If someone is in immediate danger, call 999.
Tell the Director the same day, or the SWMC Chair if the concern involves the Director. You can also use the Whistleblowing policy.
For advice, or to report a concern, contact the Modern Slavery Helpline on 08000 121 700, or the police on 101.
The Director records the concern, decides on action and tells the commissioning local authority's contract manager where it relates to the delivery of the contract.

Buying locally first is our default. Short, local supply chains are easier to know and visit, and they keep money in Sheffield. We are committed to spending with Sheffield small and medium-sized businesses and with voluntary, community and social enterprises. Spending with Dreams Are Real CIC does not count towards our voluntary, community and social enterprise spending because it is a related party. The Administrator analyses the purchase ledger by supplier postcode, size and registration number. Where reasonable, we choose ethically and fairly traded goods, for example sports kit and equipment.

12. Training

All staff learn about modern slavery and this policy at induction. Training on child criminal exploitation, county lines and contextual safeguarding is completed by 18 December 2026, or within 8 weeks of joining for anyone who starts later, and refreshed every year. The DSL makes sure all staff also understand trafficking and the NRM. Staff who buy goods or check placements receive guidance on supplier and employer checks.

13. Monitoring and review

The Director reviews our supplier list and risks every year and prepares the annual statement of steps taken. The SWMC reviews this policy every year, or sooner after a concern, a change in law, a change to a commissioning local authority's ethical code of conduct for suppliers or a contract change.

Document control and ratification

This policy is signed off by the Designated Safeguarding Lead and the Head of Alternative Provision, and ratified by the Social Work Management Committee. It is reviewed every year, or sooner after an incident or a change in law, statutory guidance or contract requirements, and it is available to any commissioning local authority on request.

Version	Date	Summary of changes	Approved by
1.0	1 October 2026	First issue	DSL; Head of AP

Role	Name	Date
Designated Safeguarding Lead	Pamela Shaw	1 October 2026
Head of Alternative Provision	Naphtali Nembhard	1 October 2026

Modern Slavery and Ethical Sourcing