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                                                               Anti-Slavery Policy


1. Introduction
a) Legislation has been introduced by the government to prevent exploitation through slavery, servitude and forced or compulsory labour and human trafficking, to provide for the protection of victims of such practices and to penalise perpetrators of such practices.
b) For the purposes of this Policy this organisation acknowledges and works within this policy and all related legislation.
c) The organisation recognises that in its use of volunteers, who make a valued and essential contribution to its service provision, as well as to its staff, who are employed with individua contract terms of employment, it has a duty to ensure that the terms and requirements of the Modern Slavery Act, 2015 (the Act) are not contravened.
d) In addition, the organisation is often in contact with carers in the course of its various service provision and activities and regards itself as also having a duty of care for the well-being of those carers with whom it is in contact.
2. Legislation
a) The Modern Slavery Act, 2015, defines slavery and human trafficking at sections 1,2 and 4 of this Act.
b) S. 4 of the Asylum and Immigration (Treatment of Claimants Act), 2004 is also relevant.
c) Penalties are attached to contraventions of these Acts in accordance S. 5 of the Act. 4. Exploitation in the Modern Slavery Act, 2015

a) Exploitation includes securing services or other activities of any kind from children and vulnerable people by any means including force or deception
b) 'Vulnerable people' includes adults and children who are mentally or physically disabled or have a family relationship with a particular person.
c) 'Services or activities' is taken to mean purposes or situations where a person who is not a child, vulnerable adult or having a family relationship with a particular person would be likely to refuse to be used for such purposes or situations.
5. Responsibilities
a) S. 54 of the Modern Slavery Act, 2015, requires transparency in supply chains, so that an organisation such as this must:

b) provide a statement on its website and in each annual report presented at its AGMs to the effect that it has taken steps to ensure that slavery and human trafficking is not taking place:
i) in any of its supply chains, and
ii) in any part of its own business.
c) indicate, via this statement, as appropriate:
i) what are its business and supply chains?
ii) its policies, due diligence, risk assessment and management of that risk and its performance indicators to measure the effectiveness of such risk management.
iii) the training provided to its workers to guard against slavery and human trafficking.
d) The organisations workers have a responsibility under this Act and in any instance of uncertainty must immediately refer to their own line manager or the Chief Officer;
e) Ultimate responsibility under this Act rests with the Board of Trustees of this organisation who have devolved day to day responsibility on the Chief Officer.
6. Safeguarding within the organisation
a) This organisation undertakes the following:
i) Employees will not be required to carry out any tasks or activities which are
defined as exploitation in the Act (see above)
ii) Volunteers will not be required to carry out any tasks or activities which are defined as exploitation in the Act
iii) All other people with whom the organisations workers come into contact in the course of their service provision activities will not be required to carry out any tasks or activities that are defined as exploitation in the Act.
iv) Where staff and volunteers are alerted to, or become aware of situations that fall within the definitions and requirements of the Act, they must, immediately inform their line manager or the Chief Officer.
b) In any circumstances set out in s. 1 (iv) above in this Policy it is likely that appropriate action must be taken even if the person thought to be being exploited resists any such action since the staff member or volunteer may be committing a criminal offence by failing to take action. In any such instance, the Trustees may decide to take legal advice.
8. Supply Chains
a) S. 54 of the Act requires transparency in supply chains and, generally speaking,
statements regarding such transparency must appear on an organisation's website and in its Annual Report presented at each AGM.
b) Such statements will be provided by the organisation.
c) The government document 'Transparency in Supply Chains etc. A practical guide' will be used as guidance on each occasion when an item of equipment is considered for purchase or lease.
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/649906/Transparency_in_Supply_Chains_A_Practical_Guide_2017.pdf