Modern Slavery Statement 2024

This statement is made on behalf of The Disabilities Trust (company number: 02334589), trading as
“Brainkind”, pursuant to section 54(1) of the Modern Slavery Act 2015 (the “Act”) and constitutes our
slavery and human trafficking statement for the financial year ended 31 May 2024 (2023/24). This is
the 4th statement made on behalf of Brainkind and sets out the steps that we continue to take to prevent modern slavery and human trafficking in our business and supply chains.

Our structure

Brainkind is a company limited by guarantee and a national charity, registered in England and Wales
(charity number: 800797) and in Scotland (charity number: SC038972).
Brainkind is governed by its Board of Trustees, with day-to-day management delegated to the Executive Leadership Team.

Brainkind has two wholly owned subsidiaries: the Brain Injury Rehabilitation Trust (company number: 02863860) and York House Ventures Limited (company number: 04735561) which is currently dormant.

Our business and supply chains

Brainkind is a provider of complex care, specialist rehabilitation, care and support for adults with
acquired brain injuries and other neurological conditions. Placements into our services are funded by
local authorities, Integrated Care Boards and other organisations in the health and social sector, as well as directly by the individuals we support.

Brainkind is regulated by the Care Quality Commission, the Care Inspectorate Walesthe Charity
Commission for England and Wales, Estyn (Office of Her Majesty’s Inspectorate for Education and
Training in Wales), the Financial Conduct Authority, Homes England, Healthcare Inspectorate Wales,
Office of the Scottish Charity Regulator, Ofsted, Welsh Government (Social Landlords and Housing
Associations), Health Improvement Scotland and Care Inspectorate Scotland.

Brainkind has around 1,800 employees, approximately 20% of which are part time and up to 300
temporary or agency staff at any one time. We also have up to 150 of volunteers at any one time. Our
staff (including temp and agency) and volunteers are all based in the UK.

Our supply chains include medical consumables, medical equipment, catering, furniture, stationery,
waste services, utilities, fleet, travel, facilities management, IT services, agency. Our supply chain is
primarily located in the United Kingdom.

Our approach

Brainkind maintains a zero-tolerance approach to any form of modern slavery and remains committed to acting ethically, and with integrity and transparency in all business dealings. We are aware of our responsibilities towards service users, employees and the local community and expect all suppliers to Brainkind to adhere to the same ethical principles.

The Board of Trustees has overall responsibility for ensuring that Brainkind complies with its legal and ethical obligations. Trustees receive updates on the nature and requirements of the Act, and the impact on Brainkind.

All of our policies and procedures remain under review and adaptable to any changes in risks faced by
Brainkind and the health and social care sector.

Our policies, due diligence and training

Brainkind maintains clear internal governance structures at both operational and leadership levels. This includes systems and controls to safeguard against modern slavery or human trafficking within the business or our supply chain.

Employment practices

We comply with all UK employment legislation as set out in our Recruitment Policy. Right to work
documentation is checked and confirmed before any employment offer is made. All terms and conditions are shared prior to employment and policies are made available to all new staff (including temp and agency) on joining and then are available on our intranet. This includes our complaint and grievance mechanisms and whistleblowing policies, which are in our policy manager.

We only use specified, reputable employment agencies to source labour, and we always verify the
practices of any new agency we are using (ensuring that they meet our standards) before accepting
workers from that agency. We use a neutral vendor to supply the majority of our agency workers who
undertake stringent checks on agencies before they agree to work with them and then supply to us.
Brainkind has a whistleblowing policy and a dedicated whistleblowing helpline, in case of concerns about how staff (including temp and agency) or people receiving our services are being treated or about practices within our business or supply chain, without fear of reprisal.

Supply chain

Our procurement teams ensure that suppliers are carefully selected through our supplier selection
criteria and processes.

To ensure that our supply chain comply with our values we require all suppliers and partners to confirm that they adhere to the Modern Slavery Act 2015 at the outset of our business relationship and that it is reinforced, as appropriate, thereafter.

Safeguarding

We adhere to the principles inherent within our policies for safeguarding children and adults. These are compliant with Brainkind’s multiagency agreements and provide clear guidance so that our employees are aware of how they can raise safeguarding concerns about staff (including temp and agency) or service users or about practices within our business or supply chain.

Safeguarding Adults mandatory training is required to be completed by all staff (including temp and
agency) on induction and then every 3 years and is monitored by our Learning & Development team.
Upon completion of the course, all staff will have an understanding of how to safeguard adults in-line
with national guidance and understand how and when to report suspicions of abuse. Modern slavery
and human trafficking is covered within this mandatory training. Service based staff (including temp and agency) are required to complete Safeguarding Children & Young People Mandatory training on
induction and then every 3 years and is monitored by our Learning & Development team.

Further advice for our staff (including temp and agency) can be found in our safeguarding policies and procedures and from Brainkind’s Safeguarding Lead or local safeguarding champions.

Incident reporting is encouraged, and our employees are also supported by an internal Freedom to
Speak Up Guardian who provides independent support and advice to staff (including temp and agency) who want to discuss their concerns whilst also respecting their confidentiality.

A number of safeguarding resources are available on Brainkind’s intranet pages and also shared via a
monthly safeguarding blog with all staff (including temp and agency).

Assessment of risk

Risk registers are managed locally and corporately to manage risks and internal controls effectively and Brainkind’s Quality Team monitor compliance via internal audits.

We have assessed the overall risk of modern slavery to be low. However, we recognise that the risk
associated with health and social care has been highlighted in reports including the Care Quality
Commission’s State of Care Report 2023/24.

There have been no suspected or actual instances of modern slavery reported in relation to our business or supply chain for the year ended 31 May 2024. In the event of any such reports we would provide all necessary assistance to the relevant authorities.

However, we will not allow complacency and will continue to promote awareness of the signs of modern slavery and continually improve our framework to mitigate risk against it.

Progress since our last statement

Following the steps outlined in our 2023 statement:
Brainkind intends to continue to adapt and refine its procurement processes to ensure a robust legal
framework. We shall work on integrating our processes and procedures with the services that we
acquired from Sue Ryder and shall carry out a review of good practice and training over the course of
2024. We will strengthen our due diligence and supplier management framework by adding new
methods and policies to identify and address risks. We will also review the content of our training
provision to ensure that it remains fit for purpose and suited to the staff (temp & agency included) and people we support.

Targets for the year ahead

We will continue to keep our internal processes under review to identify what further steps can be
taken to ensure that our obligations under the Act are met and to mitigate against slavery or human
trafficking taking place in any part of our business or supply chain.

Some of the specific measures we will be progressing during the financial year ending 31 May 2025
include:
• adding our statement to the Modern Slavery Registry;
• continuing to monitor best practice and any proposed legislative changes in the area;
• updating supplier onboarding software to enhance compliance;
• continue review of good practice and training.

Approved on behalf of Brainkind by:
This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes
Brainkind’s slavery and human trafficking statement for the financial year ending 31 May 2024.
The statement was approved by the Board on 2nd December 2024 and signed on behalf of the Board by Kathryn Greenberg, Chair of the Board of Trustees