Modern Slavery Statement

Financial Year: 2024–2025 | Last Reviewed: March 2025 | Next Review: March 2026 | Published under: Modern Slavery Act 2015, Section 54

Introduction

This statement is made by Cam Gray Support Services pursuant to Section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 2025.

Cam Gray Support Services is fully committed to acting ethically and with integrity in all of our business dealings and relationships, and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within our own business or our supply chains.

Our position is unequivocal: modern slavery, forced labour, human trafficking and any form of exploitation have no place within Cam Gray Support Services — in our workforce, our operations or our supply chains. We take our responsibilities under the Modern Slavery Act 2015 seriously and are committed to continuous improvement in this area.

About Cam Gray Support Services

Cam Gray Support Services is a CQC-registered adult social care provider based in the West Midlands, delivering domiciliary care, supported living and complex care services to adults with a range of needs. We operate as a regulated provider under the Health and Social Care Act 2008 and are subject to the regulatory oversight of the Care Quality Commission.

Our workforce comprises care professionals, support workers, coordinators and management staff, all of whom are directly employed by or contracted through Cam Gray Support Services. We provide services to individuals funded through local authority social care budgets, NHS Continuing Healthcare, personal budgets and private arrangements.

Our Supply Chains

As a care provider, our supply chains are relatively limited in scope compared to organisations operating in manufacturing or retail. Our principal areas of supply chain activity include:

Recruitment and staffing — including the use of recruitment agencies and employment platforms where applicable
Personal protective equipment, uniforms and care consumables
Technology, digital systems and software services
Facilities, maintenance and office supplies
Professional services including legal, financial and HR support
Training and learning development providers

We recognise that the risk of modern slavery and human trafficking exists across all supply chains, including in sectors that may not immediately appear high risk. We are committed to understanding and managing this risk in every area of our procurement activity.

Our Policies

We maintain a suite of policies that together support our commitment to preventing modern slavery and human trafficking within our organisation and supply chains. These include:

Modern Slavery and Human Trafficking Policy

This policy sets out our zero-tolerance position on modern slavery and human trafficking, our approach to identifying and managing risk, and the responsibilities of our staff and suppliers in upholding our standards.

Recruitment and Employment Policy

Our recruitment policy ensures that all workers are employed freely and willingly, that identity and right-to-work checks are carried out rigorously for every member of staff, and that no individual is charged a fee in connection with obtaining employment. We do not use zero-hours contracts as a means of creating dependency or vulnerability in our workforce.

Whistleblowing Policy

We encourage all members of our team to report any concerns about modern slavery, exploitation or unethical practices — whether in our own organisation or in our supply chains — without fear of retaliation. Our whistleblowing policy provides clear and accessible routes for raising concerns, including to an external reporting body where appropriate.

Safeguarding Policy

Our comprehensive safeguarding framework requires all staff to be alert to the signs of exploitation and abuse — including indicators of modern slavery and trafficking — and to report concerns promptly through the appropriate channels. Safeguarding training is mandatory for all staff before they begin working with service users.

Supplier Code of Conduct

We expect all organisations we work with to uphold standards consistent with our own. Our Supplier Code of Conduct sets out our expectations regarding fair employment practices, worker welfare, and compliance with all relevant legislation — including the Modern Slavery Act 2015.

Due Diligence

We take a proportionate, risk-based approach to due diligence across our operations and supply chains. Our due diligence processes include:

Enhanced right-to-work and identity verification for all employees and contractors, including overseas workers
Enhanced DBS checks at the criminal records bureau level for all staff working with vulnerable adults
Supplier screening and assessment prior to entering into procurement relationships
Ongoing monitoring of supply chain relationships, particularly where labour supply is involved
Contractual obligations requiring suppliers to comply with the Modern Slavery Act 2015 and to flow down equivalent obligations to their own suppliers
Regular review of recruitment agency relationships to ensure ethical employment practices

Where concerns are identified through our due diligence processes, we investigate promptly and take appropriate action — up to and including termination of supplier relationships where serious concerns are substantiated.

Risk Assessment

We have assessed the areas of our business most likely to present a risk of exposure to modern slavery or human trafficking. Our assessment identifies the following as the areas of highest relative risk:

Workforce and Recruitment

The care sector has historically been identified as a sector where workers — particularly those who are newly arrived in the UK or from overseas — can be vulnerable to exploitation by unscrupulous recruiters or employers. We mitigate this risk through robust direct recruitment practices, thorough identity and eligibility verification, and proactive engagement with our workforce to ensure that all staff are employed on fair and transparent terms.

Agency and Contract Labour

Where we use agency workers or contractors, we apply additional scrutiny to ensure that those individuals are being treated fairly by their principal employer. We only engage with recruitment agencies that can demonstrate compliance with relevant legislation and our own standards.

Procurement of Goods and Services

While our procurement activity is limited in scale, we recognise that goods such as PPE and uniforms may originate from supply chains with a higher risk profile. We seek to address this through our supplier due diligence processes and our Supplier Code of Conduct.

Training and Awareness

We are committed to ensuring that our staff have the knowledge and awareness needed to identify and respond to modern slavery and human trafficking. Our approach to training includes:

Mandatory modern slavery awareness training for all staff as part of their induction programme
Refresher training on a regular basis and whenever significant legislative or guidance updates occur
Specific training for managers and senior staff on recognising indicators of exploitation in the workforce and supply chains
Integration of modern slavery awareness into our broader safeguarding training framework
Clear internal guidance on how to report concerns, including awareness of the National Referral Mechanism

We ensure that all staff are aware of the indicators of modern slavery — including debt bondage, document confiscation, restricted movement, threats and coercion — and know how to report concerns quickly and safely.

Indicators and Reporting

Staff are trained to be alert to the following potential indicators of modern slavery or human trafficking in the individuals they support and in their own working environment:

Signs of physical abuse, malnourishment or neglect inconsistent with the individual’s known circumstances
Individuals appearing fearful, anxious or unwilling to speak freely in front of others
Evidence that an individual’s identification documents are being held by a third party
Individuals living in overcrowded, inadequate or controlled accommodation
Workers being collected and dropped off at irregular hours or showing signs of being controlled
Individuals appearing unaware of their location or unable to speak for themselves

Any member of staff who suspects that a person may be a victim of modern slavery or human trafficking should report this immediately to their line manager or our safeguarding lead. Where there is an immediate risk to safety, the police should be contacted directly. Staff are also made aware of the Modern Slavery Helpline (0800 0121 700) and the National Referral Mechanism as routes for reporting concerns and accessing support for potential victims.

Progress and Next Steps

During the period covered by this statement, we have made the following progress in strengthening our approach to modern slavery prevention:

Reviewed and updated our Modern Slavery and Human Trafficking Policy
Strengthened our supplier due diligence procedures and introduced our Supplier Code of Conduct
Embedded modern slavery awareness content into our mandatory staff training programme
Reviewed our recruitment practices to ensure all right-to-work and identity checks are consistently applied
Raised awareness of the National Referral Mechanism among all staff

In the coming year, we intend to take the following steps to further strengthen our approach:

Introduce a formal annual modern slavery risk review across our operations and supply chains
Enhance our supplier engagement processes to include proactive modern slavery questionnaires
Review our whistleblowing and reporting mechanisms to ensure they are as accessible and effective as possible
Continue to invest in staff training and awareness, including scenario-based learning

Approval and Sign-Off

This statement has been reviewed and approved by the senior management of Cam Gray Support Services and is published on our website in accordance with our obligations under Section 54 of the Modern Slavery Act 2015. It will be reviewed and updated annually.

Approved by: The Senior Management Team
Organisation: Cam Gray Support Services
Registered Address: 205a Tettenhall Road, Wolverhampton, WV6 0DD
CQC Registration: Registered provider of adult social care services in England
Date of Approval: March 2025
Next Review Date: March 2026