MODERN SLAVERY STATEMENT.

Covering the period 1 June 2025 to 31 May 2026

Modern slavery is the recruitment, movement, harbouring or receiving of children, women or men through the use of force; coercion; abuse of vulnerability; deception or other means for the purpose of exploitation. It is a crime under the Modern Slavery Act 2015 and includes holding a person in a position of slavery, servitude forced or compulsory labour, or facilitating their travel with the intention of exploiting them soon afterwards. PLUS is committed to working ethically with service users, employees, suppliers and funders to ensure that our business is run without benefit from slavery. We will collaborate with other people and organisations to ensure that concerns about slavery are acted on and that these criminal offences are brought to an end. PLUS supports people with learning disabilities through the provision of high quality, innovative services, supporting people to develop more independent lifestyles within their community. Individuals are encouraged to have an active social life with the support of trained, skilled staff and volunteers. PLUS's main client group is people with learning disabilities, but services are also offered to people with mental health support needs. Housing is provided as part of a support and care package in some locations.

Our Business and Structure

PLUS is a charity, governed by a board of trustees who also act as the directors of a company limited by guarantee. It operates in south London. Day to day management is in the hands of a Chief Executive, as head of the Strategic Management Team (SMT). The SMT is comprised of the Chief Executive, Deputy Chief Executive and three Heads of Service. Service Managers are responsible for the provision of care and support within nominated services, in accordance with the Charity’s contractual and statutory obligations. The Finance Manager is responsible for the management of the Charity’s transactions, financial records and banking. The Human Resources Manager, Training & Development Manager and Administration Manager complete the central structure of the Charity. PLUS has no subsidiary company structure and employs about 140 people. As the whole organisation has a turnover in the region of £8 million, it does not come within the turnover level of £36 million at which a modern slavery statement is a statutory requirement.

Activities in which modern slavery or human trafficking could be considered to be a risk:

People Who Use Our Services

Disability can increase the risk of an individual being exploited. For adults with learning disabilities, the risks are known to be high and there is a broad range of hazards. People with learning disabilities are known to be at high risk of financial abuse and there have been media reports of people being drawn into drugtrafficking. There are particular risks around employment relationships and where someone has limited communication skills, it can be particularly difficult to define a clear line between employment and exploitation. The first defence against people with learning disabilities being drawn into slavery is a culture of vigilance within the organisation, and a clear reporting system. This is available within PLUS through the Safeguarding Procedure and the Whistleblowing Procedure. All employees receive safeguarding training and are taught skills needed to identify abuse.

Employment

Our work is staff-intensive. Salaries and agency staff are a large proportion of expenditure. For salaried and bank staff, PLUS is the direct employer and conducts a range of intensive checks on applicants before employment. The Human Resources and Development Department requires references from former employers and a complete 5-year history of career and home addresses. HR professionals working within PLUS have an awareness of the risks of modern slavery and concerns will be raised and investigated if there is any likelihood that a job applicant or employee is the subject of slavery or human trafficking. It is therefore felt that the risk is low for directly-employed staff who make up the majority of the workforce. Additional risks exist in working with staffing agencies. Agency staffing is employed to fill gaps in rotas where a post is vacant or where a worker is temporarily not available. It is always a last resort and when agency workers are used, managers must make every effort to use staff who are known to them and to service users. As the recruitment, training, employment, Income Tax and National Insurance relating to the booking are handled by the recruitment agency, it is essential that PLUS requests and holds details of how the risks of slavery and trafficking are managed by any agency we work with.

Supply Chain Considerations

The supply chain is short and simple and appears to present a relatively low level of risk. This assessment will be reviewed in case of any changes where the risk level is likely to have changed. The appointment and monitoring of staffing agencies is covered by the Contractors Policy. When taking on any new staffing agency as a contractor, PLUS undertakes due diligence to establish whether this is an ethically responsible company and whether they are trustworthy. A record of satisfactory performance must be established through taking references and a body of information about the agency must be built up by the officer within PLUS who wishes to do business with the new agency. The performance of the agency, its management and staff, is monitored over time and prompt action taken if any concerns arise or there are suspicions that an individual is the subject of slavery or trafficking. We have made clear to staffing agencies the high standards we expect from them and our ethical stance towards issues of slavery and exploitation. Our current policy is to reduce any risk still further by eliminating use of agency staffing throughout the organisation, other than for genuine emergencies when no other staffing solution is available.

Procedure For Handling Concerns

Any concerns must be reported without delay to the Chief Executive, who will appoint a manager to make an initial enquiry. The enquiry must take no more than 2 days and should only aim to establish whether there is any basis to the concerns. It is essential that any potential perpetrator is not made aware of the investigation and urgent consideration must be given to informing the Police of any concerns that an offence may have been committed. Investigation within PLUS must not proceed to a stage or into areas where a perpetrator could be ‘tipped off’ or where it could lead to someone destroying evidence or could put a potential prosecution at risk.

Protection Of Victims

One of the first considerations must be to protect people who may have been affected, and to offer them support. This could be through referral to an organisation which exists to support people who have been trafficked. It is strongly recommended to seek and follow advice from the Police on the best way to genuinely protect an individual as well-meaning actions may unintentionally increase the suffering of the individual. PLUS has a Staff Welfare Procedure which gives simple guidance to managers on how to support employees following an incident. This guidance is not a sufficient response to a case of slavery but does give advice on reassuring and supporting an employee.

Relevant PLUS Policies

Safeguarding Procedure
Whistleblowing Procedure
Staff Welfare
Recruitment & Selection Procedure
DBS & Referrals
Agency & Bank Policy
Employee Code of Conduct
Contractors Procedure

Responsibilities

Chief Executive – review of policy and implementation of changes emerging from the review. Briefing of the Strategic Management team on Modern Slavery and related issues.

Heads of Service – ensuring staffing agencies have sufficient policies in place and are checking the background of agency staff who within their own areas of responsibility.

Service Managers – vigilance over the welfare of the staff team and service users with in the area of management responsibility.

Human Resources Manager – due diligence in recruitment of bank and salaried staff. We have a robust recruitment and selection process which is regularly reviewed to ensure effectiveness. Provision of safeguarding training.