Modern Slavery Statement and Policy
All Services
This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.
This procedure forms part of the Polaris Quality Management System in line with ISO- 9001:2015 standards and applies to all community companies unless stated otherwise.
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Procedure Owner: |
Jo August |
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Approved by: |
Polaris Board |
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Date approved: |
March 2024 |
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Next review date: |
March 2025 |
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Version No: |
03 |
All companies within Polaris are detailed in the current legal structure
This is the modern slavery statement of Polaris Community Limited and all its subsidiaries and UK companies. This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”). Not all of the Polaris Community meet the financial criteria for producing a modern slavery statement, this statement has been adopted by all the companies in the community.
This statement sets out the steps taken by Polaris Community Limited and its community of companies to prevent modern slavery in its business and supply chains.
Introduction
Our organisation continues to have a zero tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of our business dealings and relationships. We have continued to implement and enforce effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either our own business or in any of our supply chains. We are committed to improving our practices to combat modern slavery and human trafficking.
Our Structure and Business
Polaris Community Limited is the parent company, whose registered office is situated in England. It encompasses a community of companies which provide high quality foster care, including specialist placements, throughout the UK, also residential services, schools and supported and semi- independent accommodation for care leavers, family support, adoption, edge-of-care services and overseas Statutory Social Work services, as well as related services throughout the continuum of care.
Our Supply Chain
Throughout our supply chain, we are committed to high ethical standards, promoting safe and fair working conditions and responsible management of social issues. We believe we have a responsibility and opportunity to encourage sustainable business practices as well as inclusion and diversity amongst our suppliers. Our supply chains include contractors and consultants, primarily based in the UK, who provide various products and services such as:
- Social work services.
- Information technology suppliers providing equipment such as computers, laptops and mobile phones as well as software.
- Facilities management such as cleaning and security services.
- Company vehicles.
- Marketing services.
- Suppliers of materials such as stationery and office equipment.
For the minority of our suppliers that are outside of the UK, if modern slavery is identified or suspected, then the response will be tailored to the local circumstances, including engaging with local government, law enforcement, non-governmental organisations, industry bodies or trade unions.
Our Policies
We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Modern Slavery Policy reflects our commitment to acting ethically and with integrity in all our business relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking is not taking place anywhere in our supply chains. In addition to this, we have a number of appropriate policies such as:
- Human Resources related documentation including Recruitment, Whistle-blowing and Grievance Policies.
- Risk Management Policy to clarify the process for identifying, analysing and evaluating a risk.
- Safeguarding Policy to ensure that vulnerable people are not at
- Health and Safety Policy to demonstrate acceptable working
These policies encourage staff to report any wrongdoing, which extends to human rights violations such as modern slavery. All reports will be fully investigated and appropriate remedial actions shall be taken. Our modern slavery policies meet the following good practices:
- Policies are approved by senior management
- Policies are available to all staff in the organisation and communicated to them
- Relevant staff are trained in these policies
- High risk suppliers are required to adhere to our modern slavery policies
Due diligence process
Within our organisation, we have robust recruitment processes, which include undertaking document checks on candidates prior to employment to evidence they are allowed to work in the UK, performing appropriate reference checks and ensuring that staff are paid directly into a suitable personal bank account. In relation to our supply chains, we have reviewed our contractual arrangements with current and prospective suppliers to ensure they comply with the Act. This involves placing obligations upon suppliers to conduct regular modern slavery risk assessments within their own supply chains, implement appropriate controls to prevent modern slavery, and notify our organisation immediately if any supplier becomes aware of any modern slavery within their supply chains.
Risk assessment and management
Our strategy for managing risks in relation to modern slavery and human trafficking are achieved through:
- A review of Incident and Supplier Management activities, carried out by the Operational Leadership Team at their monthly meeting
- A central live portal for all staff to record specific incidents with reporting of extreme/high risk situations being escalated to senior leadership meetings
- Quarterly reviews of the incidents to inform our Strategic and Business Continuity Risk Registers and enable the prioritisation of improvement projects
- Ongoing audit and assessment against the ISO standards to identify compliance issues and identify improvement projects
Responsibilities for compliance
The Managing Directors of each business area are responsible for compliance in their respective departments and for their supplier relationships. Given the complexity and changing nature of this issue, we have formalised internal governance of modern slavery and human trafficking at both operational and senior leadership levels. To demonstrate the organisation's commitment to combat modern slavery and human trafficking in its business and supply chains, we monitor and enforce compliance with our Modern Slavery Policy.
We have a dedicated compliance team, which consists of involvement from the following departments:
- Human Resources;
- Finance
We recognise that overall accountability for risk management and internal controls are the responsibility of the Board. All risks that are identified as extreme or high risk are escalated to the leadership meeting, with exceptions subsequently reported to the Board.
Training
To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we have appropriate staff training. This provides our employees with knowledge on how to identify exploitation and modern slavery as well as the process for reporting suspected cases. During the induction process and throughout employment, training is provided to staff on topics relating to business ethics. In addition to this, we have specific modern slavery training available for our staff. We also encourage our business partners to arrange training for their staff, suppliers and providers.
Our effectiveness in combating modern slavery and human trafficking
We understand that modern slavery is not static, and will ensure that our organisation continues its leading approach to mitigating this risk in the year ahead. In order to assess the effectiveness of the measures taken by our organisation, we will continue to review the following key performance indicators:
- Staff training levels, particularly in connection with specific modern slavery training;
- Actions taken to strengthen supply chain auditing and verification;
- Steps taken to raise awareness of modern slavery and human trafficking throughout supply chains; and
- Investigations undertaken into reports of modern slavery and remedial actions taken in response.
Further steps
Following a review of the effectiveness of the measures we have adopted this year to ensure that there is no modern slavery or human trafficking in our supply chains, we intend to take the following further steps:
- Develop and report on key performance indicators; and
- Investigate modern slavery risks as identified and implement corrective actions in response to such risks within the business or supply chain as appropriate.
We are committed to continual improvement and will take active measures to combat modern slavery and human trafficking in our business and supply chains. This statement is made pursuant to section 54(1) of the Act and constitutes our community of companies modern slavery statement for the financial year. This statement was approved by the Board, which has oversight of all companies within the Polaris Community.
Jo August
Chief Executive Officer
The following companies make up the Polaris Community (please use link below):