Modern Slavery

This statement sets out CaReach Ltd actions to understand all potential modern slavery risks related to its business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in its own business and its supply chains. This statement relates to actions and activities during the financial year 1 April 2025 to 31 March 2026.

As being a CQC Registered Care Provider the organisation recognises that it has a responsibility to take a robust approach to slavery and human trafficking.

The organisation is absolutely committed to preventing slavery and human trafficking in its corporate activities, and to ensuring that its supply chains are free from slavery and human trafficking.

CaReach Ltd is a Care Quality Commission (CQC) registered provider dedicated to delivering high-quality, personalised home care services. Our mission is to support individuals in maintaining their independence, dignity, and wellbeing within the comfort of their own homes.

We specialise in a range of home care services including personal care, medication assistance, mobility support, companionship, and tailored care plans designed to meet the unique needs of each client. Our team of trained and vetted carers provides compassionate, reliable support to older adults, people with disabilities, and those recovering from illness or surgery.

CaReach Ltd operates with a carefully managed supply chain that ensures quality and compliance at every stage. We source all care equipment, medical supplies, and personal protective equipment (PPE) from reputable, approved suppliers who meet industry standards and regulatory requirements. Additionally, we partner with local health and social care professionals to coordinate seamless care delivery. Our supply chain focuses on transparency, reliability, and maintaining high standards to safeguard the wellbeing of our clients.

Countries of operation and supply

The organisation currently operates in the United Kingdom

The following is the process by which the company assesses whether or not particular activities or countries are high risk in relation to slavery or human trafficking.

CaReach Ltd takes the risk of modern slavery and human trafficking very seriously and is committed to ensuring that our operations and supply chain are free from such practices.

We regularly evaluate the countries in which we operate or source goods and services by consulting credible external resources such as the Global Slavery Index, Transparency International, and reports from the International Labour Organization. Countries identified as having higher risks related to slavery or human trafficking are subject to enhanced scrutiny and monitoring.

Each business activity, particularly those involving recruitment, supply chain sourcing, and service delivery, is assessed for vulnerability to exploitation risks. We focus on areas such as recruitment practices, labour conditions, and subcontractor compliance.

For high-risk countries or activities, we conduct thorough due diligence including supplier audits, verification of labour standards, and compliance with relevant labour laws. Contracts with suppliers and partners explicitly require adherence to anti-slavery policies.

Our risk assessments are reviewed and updated regularly to reflect changes in global risk profiles and internal operations. We provide training to staff and partners to recognise and address any signs of slavery or human trafficking.

This proactive and structured approach ensures CaReach Ltd minimises risk and upholds the highest ethical standards across all aspects of our business.

CaReach Ltd recognises that certain activities within our operations and supply chain may carry a higher risk of involvement with modern slavery or human trafficking. We have identified the following activities as high risk:

1. Recruitment and Employment of Care Staff
   • Why High Risk: The care sector is known to be vulnerable to labour exploitation due to reliance on low-paid, sometimes migrant, workers. Risks include unethical recruitment fees, contract substitution, or withholding of documents.
   • Risk Decision Process: We identified this risk through sector-wide research, reports from regulators and NGOs, and internal audit findings. Enhanced vetting and monitoring are applied to recruitment agencies and direct hires.
2. Supply of Medical and Personal Protective Equipment (PPE)
   • Why High Risk: PPE and medical supplies may be sourced from countries with known labour abuses or forced labour practices.
   • Risk Decision Process: We assess suppliers’ country of origin against independent risk indices (e.g., Global Slavery Index) and conduct supplier due diligence to ensure compliance with ethical standards.
3. Cleaning and Maintenance Services
   • Why High Risk: Outsourced cleaning and maintenance often use subcontractors who may engage in exploitative labour practices.
   • Risk Decision Process: Due to common subcontracting in this sector, we assess contracts and conduct regular audits to ensure labour rights are respected.

Decisions to categorise these activities as high risk are based on a combination of:

• Analysis of industry reports and risk indexes
• Internal audits and whistleblower reports
• Consultation with suppliers and partners
• Regulatory guidance and compliance reviews

Based on this, CaReach Ltd implements additional controls, such as stricter supplier assessments, contract clauses prohibiting slavery and trafficking, and increased staff training focused on recognising and mitigating these risks.

Responsibility

Responsibility for the organisation’s anti-slavery initiatives is as follows [select the relevant areas from the list below]:

At CaReach Ltd, the responsibility for developing, implementing, and reviewing policies related to modern slavery and human trafficking lies with the Compliance and Governance Manager, supported by the senior management team. These policies are created through a collaborative process involving legal advisors, HR, and procurement teams to ensure they align with current legislation and best practices. Policies are reviewed annually or whenever regulatory updates occur to ensure ongoing effectiveness and relevance.

The overall responsibility for assessing human rights and modern slavery risks rests with the Risk Management Committee, which includes representatives from Compliance, Procurement, and Operations departments. The risk assessment process involves continuous monitoring of country-level risks, supply chain vulnerabilities, and operational practices. This process integrates data from external risk indices, supplier audits, and employee feedback to identify, evaluate, and mitigate potential risks associated with slavery and human trafficking.

Investigations and due diligence relating to known or suspected cases of slavery or human trafficking are managed by the Compliance Team, working closely with the Human Resources and Legal Departments. Their roles include:

• Conducting thorough internal investigations upon reports or suspicions.
• Engaging with external auditors or authorities when necessary.
• Implementing corrective actions and ensuring compliance with legal requirements.
• Performing enhanced due diligence on high-risk suppliers and recruitment agencies.

CaReach Ltd has implemented comprehensive training programs to raise awareness and understanding of modern slavery risks among staff and suppliers. All employees receive mandatory training during onboarding and annual refreshers that cover:

• Recognising signs of exploitation.
• Reporting procedures and whistleblowing protections.
• Ethical recruitment practices and supply chain transparency.

Additionally, we extend training sessions to key suppliers and contractors, reinforcing expectations and encouraging collaborative vigilance against slavery and trafficking risks.

The organisation operates the following policies that describe its approach to the identification of modern slavery risks and steps to be taken to prevent slavery and human trafficking in its operations [select the relevant policies from the list below and include links to the full text]:

• Whistleblowing policy The organisation encourages all its workers, customers and other business partners to report any concerns related to the direct activities, or the supply chains of, the organisation. This includes any circumstances that may give rise to an enhanced risk of slavery or human trafficking. The organisation’s whistleblowing procedure is designed to make it easy for workers to make disclosures, without fear of retaliation. Employees, customers or others who have concerns can [use our confidential helpline/complete our confidential disclosure form].
• Employee code of conduct The organisation’s code makes clear to employees the actions and behaviour expected of them when representing the organisation. The organisation strives to maintain the highest standards of employee conduct and ethical behaviour when operating abroad and managing its supply chain.
• Supplier/Procurement code of conduct The organisation is committed to ensuring that its suppliers adhere to the highest standards of ethics. Suppliers are required to demonstrate that they provide safe working conditions where necessary, treat workers with dignity and respect, and act ethically and within the law in their use of labour. The organisation works with suppliers to ensure that they meet the standards of the code and improve their worker’s working conditions. However, serious violations of the organisation’s supplier code of conduct will lead to the termination of the business relationship.
• Recruitment/Agency workers policy The organisation uses only specified, reputable employment agencies to source labour and always verifies the practices of any new agency it is using before accepting workers from that agency.

The organisation undertakes due diligence when considering taking on new suppliers, and regularly reviews its existing suppliers. The organisation’s due diligence and reviews include:

• mapping the supply chain broadly to assess particular product or geographical risks of modern slavery and human trafficking;
• reviewing on a regular basis all aspects of the supply chain based on the supply chain mapping;
• taking steps to improve substandard suppliers’ practices, including providing advice to suppliers through [third party auditor] and requiring them to implement action plans;
• participating in collaborative initiatives focused on human rights in general, and slavery and human trafficking in particular
• invoking sanctions against suppliers that fail to improve their performance in line with an action plan or seriously violate our supplier code of conduct, including the termination of the business relationship.

The organisation has reviewed its key performance indicators (KPIs) in light of the introduction of the Modern Slavery Act 2015. As a result, the organisation is:

• requiring all staff/staff working in to have completed training on modern slavery;

The organisation requires [all staff/staff working in [specify countries]/supply chain managers/HR professionals] within the organisation to complete training on modern slavery [as a module within the organisation’s wider human rights/ethics/ethical trade training programme].

The organisation’s modern slavery training covers:

• our business’s purchasing practices, which influence supply chain conditions and which should therefore be designed to prevent purchases at unrealistically low prices, the use of labour engaged on unrealistically low wages or wages below a country’s national minimum wage, or the provision of products by an unrealistic deadline;
• how to assess the risk of slavery and human trafficking in relation to various aspects of the business, including resources and support available;
• how to identify the signs of slavery and human trafficking;
• what initial steps should be taken if slavery or human trafficking is suspected;
• how to escalate potential slavery or human trafficking issues to the relevant parties within the organisation;
• what external help is available, for example through the Modern Slavery Helpline, Gangmasters Licensing Authority and “Stronger together” initiative;
• what messages, business incentives or guidance can be given to suppliers and other business partners and contractors to implement anti-slavery policies; and

what steps the organisation should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the organisation’s supply chains.

As well as training staff, the organisation has raised awareness of modern slavery issues by distributing flyers to staff/putting up posters across the organisation’s premises/circulating a series of emails to staff.

The flyers/posters/emails explain to staff:

• the basic principles of the Modern Slavery Act 2015;
• how employers can identify and prevent slavery and human trafficking;
• what employees can do to flag up potential slavery or human trafficking issues to the relevant parties within the organisation; and
• what external help is available, for example through the Modern Slavery Helpline.

Directors name:

Qaseem Ali Raza Naqvi

Date:

1^st April 2025