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Modern Slavery Statement 2022


Brainkind takes the obligations established in the Modern Slavery Act 2015 extremely seriously. Modern slavery in any form is fundamentally opposed to the aims and ideals of the Brainkind and, accordingly, our Board of Trustees have approved this statement.

Brainkind is a national charity and provider of specialist rehabilitation, care and support for adults with acquired brain injuries. Placements into our services are funded by local authorities, clinical commissioning groups and other organisations in the health and social sector, as well as directly by the individuals we support.

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.

Brainkind has effective systems and controls in place to safeguard against any form of modern slavery or human trafficking taking place within the business or our supply chain.

Safeguarding Adults, Children & Young People Mandatory training is required to be completed by ALL Staff every 3 years and is monitored by our Learning & Development team. Upon completion of the course staff have an understanding and awareness of how to safeguard adults and children in-line with national guidance and understand how and when to report suspicions of abuse.

Incident reporting is encouraged, and safeguarding guidance and training is provided to support staff to recognise all forms of abuse including Modern Slavery.

Risk registers are managed locally and corporately to manage risks and internal controls effectively and the Brainkind quality team monitor compliance via internal audits. To date, the Brainkind is pleased to report that there have been no suspected instances of modern slavery connected to our business. However, we will not allow complacency, and will continue to promote awareness of the signs of modern slavery and build a robust framework to mitigate risk against it, as detailed further below.

Recruitment & Training

Our staff and volunteers are all based in the UK and are largely directly employed and generally not in any category which is highlighted as vulnerable to modern slavery in this country.

Brainkind operates a robust recruitment process outlined in the Recruitment Policy, including conducting eligibility to work in the UK checks for all directly employed staff. We have an approved framework which is audited by the recruitment team to provide assurance that pre-employment clearance has been obtained for staff, to safeguard against human trafficking or individuals being forced to work against their will.

Compliance documentation is further checked, prior to the commencement of employment by all managers. Spot checks are completed by Brainkind’s recruitment team on a weekly basis and reports are available for audit purposes for agency staff compliance.

Brainkind utilises a managed agency provider to source temporary, fixed term and permanent employees which provides greater confidence in the workers we engage through them. As part of this contract, supplying temporary work agencies are audited against legislative compliance, including compliance with the Modern Slavery Act, and any legislative non-compliance is identified to clients.

All temporary workers are supplied and documented through a software system which verifies the identity of each temporary worker and the worker’s right to work in the UK before supply commences.

Brainkind educates its employees regarding the types of factors which can indicate that a temporary worker may be subject to undue influence and actively encourages employees to report any suspicious activity.

Modern slavery and human trafficking are covered within Brainkind mandatory training which is based on the latest government guidance. All staff are required to complete the training on induction which includes a practical knowledge assessment on the subject.

Safeguarding & Whistleblowing

As referred to above, Modern slavery training is covered in the safeguarding children and adults eLearning module. Further advice can be found in our safeguarding policies and procedures and from the Brainkind safeguarding lead or local safeguarding champions.

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 colleagues or service users or about practices within our business or supply chain.

A number of safeguarding resources are available on Brainkind safeguarding site on the intranet and is shared via a monthly safeguarding blog with all staff.

Brainkind have a whistleblowing policy and a dedicated whistleblowing helpline for employees, in case of concerns about how colleagues or people receiving our services are being treated or about practices within our business or supply chain, without fear of reprisal.

Our employees are also supported by an internal Freedom to Speak Up Guardian who provides independent support and advice to staff who want to discuss their concerns whilst also respecting their confidentiality.

Suppliers and third-party partners

Brainkind places importance on working with suppliers who treat their obligations towards modern slavery with the importance that we do.

Our procurement teams ensure that suppliers are carefully selected through our supplier selection criteria/processes wherever practicable and endeavour to ensure that our suppliers and any third-party partners with whom we work are compliant with the requirements of the Modern Slavery Act 2015.

Brainkind continues to adapt and refine its procurement processes to ensure a robust legal framework.

Approved by the Trustee Board on 28th November 2022

Kathryn Greenberg

Chair of the Board of Trustees

For and on behalf of Brainkind

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