EMI-Care UK is not a relevant commercial organisation under Section 54 of the Modern Slavery Act 2015 because our annual turnover is below the £36 million threshold. We are nonetheless fully committed to the Act and to clause 25 of the Schedule 2 Form of Agreement. We will publish a Modern Slavery and Human Trafficking Statement before contract award covering all six elements set out below. 

a. Structure, business and supply chains 

EMI-Care UK is an English-registered limited company established in 2018 and trading since 2019, providing CQC-regulated domiciliary care and outreach support across Wokingham, Reading and Berkshire from our office in Woodley. Our supply chain is small and UK-based, comprising Citation Limited (HR, policy and accredited training), Birdie (UK-hosted electronic care management), Enrolpay (payroll), Microsoft 365 (productivity), our accountants, an insurance broker and occasional specialist equipment suppliers. We hold a Home Office Sponsor Licence under which we recruit a controlled number of overseas care workers. 

b. Policies on slavery and human trafficking 

We maintain a written Modern Slavery and Human Trafficking Policy, reviewed at least every three years in line with Schedule 1 clause 16.1 of the General Service Specification. The policy aligns with sections 1, 2 and 4 of the Modern Slavery Act 2015 and the framework’s clause 25. It is supported by our Safer Recruitment, Whistleblowing, Safeguarding Adults, Equality and Diversity, Data Protection and Lone Working policies, all maintained and updated through Citation Limited. 

c. Due diligence processes 

Every applicant completes our 16-page application form requiring five years of address history, ten years of employment history, identity verification, right-to-work and visashare-code verification with the Home Office, two references from organisational email addresses (not Gmail), bank statement corroboration of addresses, and Enhanced DBS. Where a candidate is sponsored under our Home Office Sponsor Licence, the Director personally checks share-code validity and passport authenticity, contacting the Home Office to corroborate where any doubt arises. We do not engage agencies that cannot evidence equivalent pre-employment due diligence. Suppliers are selected on the basis of competence, certification, insurance, GDPR compliance and supplier assurance. Sub-contractor clauses replicate the framework’s clause 25 obligations. 

d. Risk areas and management 

We have assessed our highest modern slavery risks as: (i) overseas-recruited care workers being vulnerable to exploitation by third-party introducers or unscrupulous sponsors; (ii) workers being placed on excessive hours, having wages withheld, or having housing tied to employment; and (iii) supply-chain risk in any contractor not directly assessed. Management controls include direct Director oversight of sponsorship; wages at no less than the National Living Wage; no payroll deductions for accommodation, equipment or training; transparent shift patterns; lawful working-time and rest-break compliance; access to whistleblowing without retaliation; and routine welfare conversations with overseas-recruited staff during supervision. 

e. Effectiveness and performance indicators 

Effectiveness is measured through completion of safer-recruitment and modern slavery training (target 100%); right-to-work and DBS currency (target 100%); number of safeguarding or whistleblowing reports concerning labour exploitation (target zero, with active reporting culture); any Home Office or Gangmasters and Labour Abuse Authority inquiry (target zero); and Citation external policy audit findings closed within agreed timescales. Findings are recorded in the quality action log and reviewed monthly by the Registered Manager. 

f. Training and capacity building 

Modern slavery awareness is included in induction and the annual safeguarding refresher, both accredited by Citation, covering recognition of victim indicators (control of documents, debt bondage, restricted movement, fear, isolation, signs of physical or psychological harm), reporting routes (the Modern Slavery Helpline on 08000 121 700, the police, Wokingham Adult Safeguarding and the Director), and care worker professional duties. Managers receive enhanced training on safer recruitment, sponsor licence compliance and supply-chain due diligence. 

On contract award, our published Modern Slavery and Human Trafficking Statement will be made available to Wokingham Borough Council on request and will be reviewed annually thereafter