Modern Slavery and Human Trafficking Statement 2024–2025

Introduction

British Eldery Ltd (trading as BE Care) is committed to providing exceptional, compassionate care that upholds the fundamental dignity and rights of every individual. This commitment extends unequivocally to all individuals involved in our business, including our employees, service users, and those within our supply chains.

We maintain a strict zero-tolerance stance towards modern slavery and human trafficking and are dedicated to acting ethically and with integrity in all our business relationships. We recognise the heightened and specific risks of labour exploitation within the social care sector, both in direct employment and through our supply chains. We are committed to implementing and enforcing robust systems and controls to prevent slavery and human trafficking from occurring anywhere within our operations or supply chains.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31 March 2025. It details the steps taken during this period to prevent modern slavery.

This statement has been approved by the Board of Directors of British Eldery Ltd.

Our Business and Structure

British Eldery Ltd (BE Care) is a provider of domiciliary care and supported living services across the UK. Our registered office is in Wolverhampton, with operational locations throughout the country. We are registered with the Care Quality Commission (CQC), and all our services are delivered in accordance with the Health and Social Care Act 2008 (Regulated Activities) Regulations 2014.

Our workforce consists of dedicated care professionals, including Care Assistants, Support Workers, and administrative staff. We employ both permanent staff and utilise a limited number of agency workers to ensure safe staffing levels. Our supply chain includes providers of goods and services such as:

• Recruitment agencies (a critical focus area for ethical recruitment practices)
• Uniform and Personal Protective Equipment (PPE) suppliers
• Medical equipment and consumables providers
• Subcontracted services (e.g., cleaning, security, and catering)
• IT and software services
• Professional services (legal, financial, consultancy)

We have identified that the most significant modern slavery risks to our business are present within our own recruitment practices and our use of third-party recruitment agencies, particularly in the international recruitment of staff, and our extended supply chains for goods such as uniforms and PPE, which may be sourced from high-risk geographies.

Our Policies and Governance

We uphold several internal policies designed to ensure ethical and transparent business conduct:

• Human Rights and Modern Slavery Policy: Reinforces our zero-tolerance approach and provides guidance on identifying and reporting modern slavery.
• Whistleblowing Policy: Empowers all employees, service users, and stakeholders to report concerns confidentially and without fear of retaliation.
• Recruitment and Right to Work Policy: Mandates robust vetting procedures for all employees, including verified eligibility to work in the UK.
• Supplier Code of Conduct: Requires all suppliers to adhere to our ethical standards, including explicit compliance with the Modern Slavery Act 2015.

Ultimate responsibility for modern slavery initiatives rests with the Board of Directors. Day-to-day operational responsibility for implementing this policy, monitoring its effectiveness, and overseeing training rests with our Head of Quality and Compliance.

Due Diligence Processes in Our Operations and Supply Chains

In our direct operations:

• We conduct rigorous right-to-work document checks for all employees to mitigate the risk of human trafficking.
• We pay all employees at least the national living wage and clearly communicate all terms and conditions of employment.
• We predominantly offer guaranteed hours contracts to provide income stability and do not use zero-hours contracts as standard practice.
• We foster an open culture supported by Wellbeing Champions and dedicated safeguarding leads.

In our supply chains:

• We employ a risk-based approach to assess modern slavery risks, prioritising high-risk categories such as recruitment and imported goods.
• Our standard contractual terms include clauses requiring compliance with the Modern Slavery Act 2015.
• We conduct due diligence questionnaires for new suppliers, focusing on modern slavery policies and practices.
• We require all recruitment agencies to be licensed by the Gangmasters and Labour Abuse Authority (GLAA) and to uphold ethical recruitment practices.

Training and Awareness

We invest in comprehensive education to ensure our colleagues can recognise and respond to the risks of modern slavery:

• Modern slavery awareness training is mandatory for all new starters during induction.
• Annual refresher training is tailored to the care sector, highlighting common risk indicators.
• Safeguarding training for care staff includes modules on identifying modern slavery, acknowledging that service users could also be victims.
• Training completion rates are monitored and reported to senior management quarterly.

Key Performance Indicators (KPIs)

We measure our effectiveness in preventing modern slavery through:

• Percentage of staff completing mandatory modern slavery and safeguarding training — Target 100%
• Number of modern slavery-related concerns raised via whistleblowing channels — Monitored and reported to the Board
• Percentage of high-risk suppliers providing evidence of compliance — Target 100%

Commitment to Continuous Improvement

We are committed to continuous improvement in our efforts to prevent modern slavery. Key objectives for 2025–2026 include:

• Formalising our supplier risk assessment process and completing a comprehensive supply chain risk map.
• Enhancing due diligence for onboarding new suppliers.
• Strengthening contractual audit rights to verify compliance.
• Promoting a culture of vigilance and transparency throughout the organisation.

Approval

This statement was approved by the Board of Directors of British Eldery Ltd on 24 June 2025.

Signed: S Kontham
Chief Executive Officer
For and on behalf of British Eldery Ltd (BE Care Ltd)

Date: 24 June 2025

British Eldery Ltd, registered in England and Wales, No: 13930191.
Registered Office: 53 Newbridge Crescent, Wolverhampton, West Midlands, WV6 0LH, United Kingdom.