Modern Slavery and Human Trafficking Policy
Approved by: Operations Manager
Effective date: 25/10/2025
Next review date: 24/10/2026
1. Policy Statement
Norwa Care Solutions is committed to conducting its business with integrity, honesty, and
transparency. We have a zero-tolerance approach to modern slavery and human trafficking
in any part of our operations or supply chains.
We are committed to acting ethically and with integrity in all business relationships,
implementing and enforcing effective systems and controls to ensure modern slavery is not
taking place anywhere within our organisation or those linked to it.
2. Purpose
The purpose of this policy is to:
• Prevent, detect, and respond to risks of modern slavery within our operations and
supply chains we work with.
• Ensure compliance with the Modern Slavery Act 2015 and other relevant legislation.
• Promote fair and ethical treatment of all workers engaged by or on behalf of Norwa
Care Solutions.
3. Scope
This policy applies to:
• All employees, agency staff, temporary workers, contractors, and consultants engaged by Norwa Care Solutions.
• All suppliers, subcontractors, and business partners who may provide goods and services to the company.
4. Our Organisation and Supply Chain
Norwa Care Solutions is a temporary staffing care agency providing qualified care assistants
and nurses to healthcare facilities and clients across the UK.
Our supply chain includes:
• Recruitment partners and staffing agencies
• Background checks and payroll service providers
• Office suppliers and business service providers
Given the nature of our work, we recognise that recruitment and labour supply are areas
where the risk of modern slavery may be heightened, and we are committed to ensuring
robust controls are in place.
5. Commitment and Principles
Norwa Care Solutions commits to:
• Ensuring all employees and workers are engaged under fair, lawful, and transparent
terms.
• Prohibiting any form of forced, bonded, or involuntary labour.
• Prohibiting human trafficking and the exploitation of vulnerable individuals.
• Maintaining systems to identify, assess, and mitigate risks of modern slavery.
• Expecting all suppliers and partners to uphold the same standards.
6. Due Diligence and Risk Management
To manage the risk of modern slavery, we will:
• Conduct due diligence on all recruitment agencies we may work with, suppliers, and
contractors before engagement.
• Require all suppliers to confirm their compliance with the Modern Slavery Act 2015.
• Monitor and review supplier performance periodically.
• Investigate and take immediate corrective action if concerns are raised.
7. Recruitment Practices
Norwa Care Solutions operates strict recruitment procedures, including:
• Verifying the identity, right to work, and background of all workers.
• Ensuring contracts clearly set out employment terms, pay rates, and conditions.
• Never charging workers recruitment fees.
• Working only with reputable recruitment and labour partners that align with our
ethical standards.
8. Training and Awareness
We will provide training to relevant staff, including managers and recruiters, to help them:
• Identify indicators of modern slavery and human trafficking.
• Understand reporting procedures and escalation routes.
• Promote awareness of ethical recruitment and employment practices.
9. Reporting Concerns
Norwa Care Solutions encourages all staff, suppliers, and partners to report any concerns
about suspected modern slavery.
Reports can be made confidentially to:
The Operations Manager at om@norwacaresolutions.co.uk
All concerns will be taken seriously, investigated promptly, and appropriate action taken.
Retaliation against anyone raising concerns in good faith will not be tolerated.
10. Monitoring and Review
The Operations Manager is responsible for monitoring the effectiveness of this policy and
reviewing it annually or following any significant changes in legislation or operations.
Key performance indicators may include:
• Number of staff trained on modern slavery awareness.
• Number of suppliers audited or verified.
• Number of reports received and resolved.
11. Policy Communication
This policy will be:
• Communicated to all employees, contractors, and suppliers.
• Published on the Norwa Care Solutions website.
• Included in onboarding materials and compliance documentation.
12. Approval
This Modern Slavery Policy has been approved and authorised by:
Operations Manager
Norwa Care Solutions
Date: 25/10/2025