Introduction
Dolphin Homes is a group of 3 companies providing specialist care and support for adults with learning difficulties, complex behaviour, physical disabilities, complex health needs, Acquired Brain Injury and associated neurological conditions, autism and Asperger’s syndrome.
We recognise the scale and seriousness of the problem of modern slavery, human trafficking, and most importantly the impact on its victims and we are committed to the principles of the Modern Slavery Act 2015. Dolphin Homes is committed to ensuring that there is no modern slavery, human trafficking or forced labour in any part of our business or supply chain.
To assure ourselves that modern slavery is not present in our company, we undertake robust recruitment and identity checks. We recognise that vigilance throughout our recruitment process is required as, unfortunately, the risk cannot be eradicated completely.
Employment of people from overseas potentially represents the biggest risk of modern slavery and we are mindful of the significant increase in modern slavery referrals across the health and social care sector.
As an equal opportunities employer, we are committed to creating a safe working environment for all our staff, a place where they feel confident to report any concerns.
This statement sets out the steps we have already taken and our continuing commitment to tackle modern slavery in our business and supply chains.
Training and awareness
All staff undertake Modern Slavery Awareness e-learning training. This course is part of our mandatory training and one that all staff are required to complete from the directors of the company through to the support staff offering direct support to individuals.
We will continue to raise awareness of modern slavery and communicate any additional information from the government website. HO_Modern_Slavery_Awareness_Booklet_web.pdf (publishing.service.gov.uk) via our internal communication processes, monthly manager meetings and individual staff meetings in each service. This includes information about the Modern Slavery Helpline.
Our Whistleblowing policy outlines the support we give to any individual who raises a concern in relation to Modern Slavery in any of its forms and commits to protecting those individuals in the making of any disclosure.
Recruitment processes
Our robust recruitment process extends to the use of Bank and Agency workers. The company operates a check list used by our Recruitment Team and by our Registered Managers to ensure that all checks are in place and aligned to CQC Regulation 19.
We continue to work with a range of approved recruitment agencies. All agencies are subject to our comprehensive due diligence checks. For example, all agency workers provide Personal Profiles which evidence their identity, and we require confirmation that right to work checks have been undertaken by the agency that employs them.
We have a designated Recruitment Manager who manages recruitment from International applicants and we hold a database with specific details relating to sponsorship recruitment ensuring we are recruiting safely and legally from outside the UK.
Supplier and third-party partners
We aim to, and are working towards systems which, allow our services to purchase from approved suppliers. We have implemented an audit process to complete with our preferred providers providing Agency Staff and again, a further check sits with our Registered Managers to check profile information as agency staff members are employed.
Our contracts will contain clauses relating to our mutual legal obligations to tackle modern slavery and will introduce a Business Partner Code of Conduct for our suppliers which includes a summary of the statutory requirements of complying with the principles of the Modern Slavery Act 2015.
In order to assess and identify the ongoing risks of modern slavery in our supply chain, we will ask suppliers to confirm the following:
- They do not use any form of forced, compulsory or slave labour.
- Their employees work voluntarily and are entitled to leave work.
- They provide each employee with an employment contract that contains a reasonable notice period for terminating their employment.
- They do not withhold their salaries for any reason.
- They do not require employees to surrender their passport or work permit as a condition of employment.
Monitoring our effectiveness
We will review on an annual basis the effectiveness of our internal policies which support our commitment to eradicating Modern Slavery and the measures we have taken to comply with the Act. We will as necessary, adapt our processes.
To date our checks have not revealed any concerns from our employees, external agencies, or from the public that any modern slavery practices have been identified. Our due diligence processes continue to oversee new and existing contractors.
This statement was approved by the Board of Directors on 27th September 2024
Name: Nicholas Heather
Position: Managing Director
For and on behalf of Dolphin Homes Limited, Dolphin Homes (Southern) Limited and Dolphin Care Limited.