1. Policy Statement

1.1 This statement is made pursuant to s.54 of the Modern Slavery Act 2015 and sets out the steps that Routes Healthcare has taken and is continuing to take to ensure that modern slavery is not taking place within our business or supply chain.

1.2 Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Routes Healthcare has a zero tolerance approach to any form of modern slavery and human trafficking. We are committed to acting ethically and with integrity and transparency in all business dealings and to putting effective systems and controls in place to safeguard against any form of modern slavery taking place within the business or our supply chains.

1.3 This policy describes the values, principles and procedures that underpin Routes Healthcare’s approach to any situation where it becomes aware of, or has evidence of, involvement or the risk of involvement, direct or indirect, in enterprises that subject people to conditions that meet current definitions of modern slavery, human trafficking and forced labour. It applies to Routes Healthcare and partner organisations with which it has dealings with.

1.4 Routes Healthcare implements its business strategy in an ethically, socially and environmentally responsible manner. We fully acknowledge our responsibility to respect human rights as set out in the International Bill of Human Rights (“IBHR”). The IBHR informs all of our policies related to the rights and freedoms of every individual who works for us, either as a direct Routes Healthcare employee or indirectly through our supply chain.

1.5 We are developing policies and processes which are intended to extend these commitments through our supply chain. As a healthcare provider we recognise our responsibility to identify any clients who may be a victim of modern slavery or human trafficking and we will ensure we adhere to our robust safeguarding procedures in work with our partners in following local modern slavery processes.

2. Our business

2.1 Routes Healthcare is a provider of specialist, high quality, clinically-led provider of personalised healthcare commissioned home care services for people in their own individual homes and communities. The business operates in four distinct, yet complimentary, markets of Enhanced Home Care (EHC), End of Life, Complex and Interim System Solutions and the strategic focus on longer contractual periods.

2.2 We employ approximately 1,450 healthcare workers and office staff and operate from 14 hubs across the North West, Yorkshire and North East of England.

2.3 The Routes board, led by the Chief Executive has overall responsibility for ensuring compliance with this statement and policy.

3. Our policies

3.1 We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner. These include:

3.2 Recruitment policy. We operate a robust recruitment policy, including conducting eligibility to work in the UK checks for all directly employed staff, to safeguard against human trafficking or individuals being forced to work against their will

3.3 Equal Opportunities. We have a range of controls to protect staff from poor treatment and/or exploitation, which complies with all respective laws and regulations. These include provision of fair pay rates, fair terms and conditions of employment, and access to training and development opportunities

3.4 Safeguarding policies. We adhere to the principles inherent within both our safeguarding adult’s and children’s policies. These provide clear guidance so that our employees are clear on how to raise safeguarding concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain.

3.5 Whistleblowing policy. We operate a whistleblowing policy so that all employees know that they can raise concerns about how colleagues or people receiving our services are being treated, or about practices within our business or supply chain, without fear of reprisals

3.6 Standards of business conduct. This code explains the manner in which we behave as an organisation and how we expect our employees and suppliers to act.

4. Clients

4.1 Routes Healthcare will endeavour to ensure no vulnerable young person or adult in our care is subject to any conditions that meet the Care Act (and similar) definitions of modern slavery. If the service hub has any suspicions, information, or evidence that any of its clients are victims of, or at risk of, becoming victims of modern slavery, exploitation or forced labour, it will take immediate protective action by alerting the appropriate safeguarding authority or police and apply all safeguarding procedures that then follow.

5. Employees, Consultants, Self-employed, Contractors, Casual and Agency Workers

5.1 We also do not employ individuals under any conditions that might make all parties vulnerable to accusations or suspicions that we are employing people under conditions that would amount to modern slavery and exploitation at defined. Everyone is subject to recruitment procedures that comply with both employment law and registration requirements with pay and conditions of employment that meet all statutory requirements.

5.2 If we have evidence that any of our employees are subject to exploitation and forced labour by third parties, we will exercise our duty of care to the individuals by reporting our concerns as whistle blowers to the police or local unit responsible for investigating modern slavery to decide on further investigation or action. We will not act or discriminate against the individuals if they are meeting all the required employment conditions and had been recruited in line with Routes Healthcare’s recruitment procedures.

6. Contractors & Suppliers

6.1 Routes Healthcare deal with several outside organisations as suppliers of goods and services. We know that these organisations might form part of a longer supply chain. We make all reasonable efforts to ensure that no link in the supply chain is producing goods and services made under conditions of modern slavery or which might involve human trafficking.

6.2 We expect all our contractors and suppliers to have a similar zero-tolerance and due diligence approach to modern slavery and human trafficking and only work with organisations that have a robust anti-modern slavery policy that operate in other parts of their supply chain and who comply with the Modern Slavery Act 2015.

6.3 We explain in our replies to businesses who respond to tenders and adverts for goods and services that we will check if they employ people under conditions of modern slavery and if they do similar checks with other businesses in their supply chain. In doing so, we expect those businesses to have taken all reasonable efforts to exclude their suppliers from colluding with modern slavery practices.

6.4 Individuals, particularly those responsible for procuring goods and services, are expected to report any concerns about any issue or suspicion of modern slavery in any part of their dealings at the earliest possible stage.

6.5 Anyone raising concerns about slavery or human trafficking that affects Routes Healthcare will be protected by our whistleblowing policy.

7.1 Training

7.2 Information and training about modern slavery and human trafficking is available to staff through our mandatory safeguarding children and adults training programmes, our safeguarding policies and procedures, and our safeguarding lead. It is also discussed at our compulsory staff induction training.

7.3 We are looking at ways to continuously increase awareness within our organisation and to ensure a high level of understanding of the risks involved with modern slavery and human trafficking in our supply chains and in our business.

8. KPI’s

8.1 We will know the effectiveness of the steps that we are taking to ensure that slavery and/or human trafficking is not taking place within our business or supply chain if:

8.2 – No reports are received from our staff, the public, or law enforcement agencies to indicate that modern slavery practices have been identified.


Modern Slavery and Trafficking Policy | Last Updated: 17/8/2023

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